Reforged Studios Oy (“Reforged Studios”, “we”) is an online game service provider providing the website reforgedstudios.com as well as online games for natural persons through mobile applications available for download from App Store and Google Play (jointly the “Services”).
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
User Data is personal data collected directly from you or other Users of the Services. We may collect User Data from you in a variety of ways, including when you register to or use the Services or when you subscribe to a newsletter or communicate with us. Further, please note that we also collect details of any transactions and payments the Registered Users carry out through the Services.
User Data that is necessary in order to use the Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between the Registered User and us as well as for the compliance with our legal obligations.
When the Registered User registers to the Services and creates a user account, the Registered User needs to provide us with the following information:
User Data you give us voluntarily
We may also collect and process the following User Data provided voluntarily:
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the Services:
We use various technologies to collect and store Analytics Data and other information when you visit the Services, including cookies and web beacons.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
The Services use certain web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Services.
There are several purposes for the processing of your personal data by Reforged Studios:
To provide the Services
Reforged Studios processes personal data of the Registered Users to be able to offer the Services to the Registered User under the contract between the Registered User and Reforged Studios.
We also use the data for example to handle the Registered User’s payments or any refunds (where applicable). If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
For our legal obligations
We process data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes
Reforged Studios may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For communication and marketing
Reforged Studios may process your personal data to contact you regarding the Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Services to you.
For quality improvement and trend analysis
We may also process information about your use of the Services to improve the quality of the Services e.g. by analyzing any trends in the use of the Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
We process personal data of the Registered Users to perform our contractual obligations towards the Registered Users and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
Reforged Studios stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.
We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.
We do not share your personal data with third parties outside of Reforged Studios’ organization unless one of the following circumstances applies:
We may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, IT, sales and marketing services providers) to process it for us and to payment service providers to process Registered Users’ payments to us.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Services, the processing is typically based on their policies and standards.
For legal reasons and legal processes
We may share your personal data with third parties outside Reforged Studios if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Reforged Studios, you or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
With your explicit consent
We may share your personal data with third parties outside Reforged Studios when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
Most personal data relating to a Registered User’s user account with the Services will be deleted immediately after the Registered User has deleted his/her user account with the Services. Thereafter, a part of the personal data relating to a Registered User’s user account with the Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a Registered User’s user account with the Services will be deleted within a period of 10 years after the Registered User has deleted its user account with the Services, with the exception of personal data required in certain rare situations such as legal proceedings.
We will anonymize Analytics Data of Users as soon as possible.
Right to access
You have the right to access and be informed about your personal data processed by us. You may request a copy of your personal data. In addition, we give Registered Users the possibility to view certain data through their user account with the Services.
Right to withdraw consent
In case the processing is based on a consent granted by you, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Services. For instance, using the online games provided by us may become impossible if you apply your right to restriction of processing.
Right to data portability
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.