Privacy Policy

1. Introduction

SKYNET S. A. S respects the privacy of its online visitors and customers of its services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR") and the Swiss and EU Privacy Shield Frameworks.

2. Personal information
The following types of personal information may be collected, stored, and used by Gamera:
- information about your computer including your IP address, geographical location, browser type and version, and operating system;
- information about your visits to and use of Gamera website, length of visit, page views, and website navigation paths;
- information, such as your email address, that you enter when you register with our website;
- information that you enter when you create a profile on Gamera website – such as your name, address, phone and email;
- information that is generated while using Gamera website, including when, how often, and under what circumstances you use it;
- information relating to services you use, or transactions you make through our website, which includes your name, address, telephone number, email address, and credit card details;
- information contained in any communications that you send to us by email, including its communication content and metadata;
any other personal information that you send to us.

Why Gamera Collects and Processes Data
Gamera collects and processes Personal Data for the following reasons:
a) where it is necessary for the performance of our agreement with you to provide a full-featured gaming service and deliver associated Content and Services;
b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
c) where it is necessary for the purposes of the legitimate and legal interests of Gamera or a third party (e.g. the interests of our other customers), except where such interests are overridden by your prevailing legitimate interests and rights; or
d) where you have given consent to it.
These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), who has access to it (section 4. below), how long we store it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).

3. What Data We Collect and Process
3.1 Basic Account Data
When setting up an Account, Gamera will collect your email address, country of residence and your address. You are also required to choose a password. The provision of this information is necessary to register a Gamera User Account. During setup of your account, the account is automatically assigned a number (the "Gamera ID") that is later used to reference your user account without directly exposing Personally Identifying Information about you. 
3.2 Transaction and Payment Data
In order to make a transaction on Gamera (e.g. to purchase Subscriptions ), you may need to provide payment data to Gamera to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to Gamera, which Gamera will process and transmit to the payment service provider of your choice to enable the transaction and perform anti-fraud checks. Likewise, Gamera will receive data from your payment service provider for the same reasons. 
3.3 Your Use of Games 
In order to provide you with services, we need to collect, store and use various information about your activity in our Services. "Content-Related Information" includes your Gamera ID, as well as what is usually referred to as "game statistics". By game statistics we mean information about your games' preferences, progress in the games, playtime, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.
3.4 Tracking Data and Cookies
We use "Cookies", which are text files placed on your computer, to help us analyze how users use our services, and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics or website functionality. The use of Cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our website.
When you visit any of our services, our servers log your global IP address, which is a number that is automatically assigned to the network your computer is part of.
3.5 Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on visitors' computers, to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on servers in the United States. On this website, IP anonymization has been activated. The IP addresses of users visiting Gamera will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and shortened there. On behalf of the website operator, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Google will not associate the IP address transferred in the context of Google Analytics with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that in this case you may not be able to use the full functionality of this website.
Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: 

4. Disclosing personal information
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information:
to the extent that we are required to do so by law;
in connection with any ongoing or prospective legal proceedings;
in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
Except as provided in this policy, we will not provide your personal information to third parties.

5. How Long We Store Data
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
In particular:
If you terminate your Gamera User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.
In certain cases Personal Data cannot be completely deleted in order to ensure the consistency of the gameplay experience. For instance, matches you have played that affect other players' matchmaking data and scores will not be deleted; rather, your connection to these matches will be permanently anonymized.
Please note that Gamera is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
If you withdraw your consent on which a processing of your Personal Data we will delete your Personal Data without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.
If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

6. Your Rights and Control Mechanisms
The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their Personal Data. While other jurisdictions may provide fewer statutory rights to their citizens, we make the tools designed to exercise such rights available to our customers worldwide.
As a resident of the European Economic Area you have the following rights in relation to your Personal Data: 
6.1 Right of Access. 
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. 
6.2 Right to Rectification. 
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. 
6.3. Right to Erasure. 
You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion. 
As a result of deleting your Gamera User Account, you will lose access to Gamera services, including the Gamera User Account, Subscriptions and game-related information linked to the Gamera User Account and the possibility to access other services you are using the Gamera User Account for.
We allow you to restore your Gamera User Account during a grace period of 30 (thirty) days from the moment you request deletion of your Gamera User Account. This functionality allows you not to lose your account by mistake, because of your loss of your account credentials or due to hacking. During the suspension period, we will be able to finalize financial and other activities that you may have initiated before sending the Gamera User Account deletion request. After the grace period, Personal Data associated with your account will be deleted. 
6.4 Right to Object. 
When our processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR / section 2.c) of this Privacy Policy, you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. 
You also have the right to lodge a complaint at a supervisory authority.
6.5 Right to restriction of processing of your Personal Data
You have the right to obtain restriction of processing of your Personal Data under the conditions set out in article 18 of the GDPR.
6.6 Right to Personal Data portability
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in article 20 of the GDPR. 
6.7 Right to Post-Mortem Control of Your Personal Data
If French data protection legislation is applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of Personal Data after your death in accordance with article 40-1 of the Act No 78-17 of 6 January 1978 on Information, Technology, Data Files and Civil Liberties.

7. Children
The minimum age to create a Gamera User Account is 13. Gamera will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, Gamera requires parental consent before a Gamera User Account can be created and Personal Data associated with it collected. Gamera encourages parents to instruct their children to never give out personal information when online. 

8. Contact Info
You can contact Gamera's data protection officer at the address below. 
building A, apt. 69, Kvishkheti street, Tbilisi, 5707, Gergia

9.Security of your personal information
We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
All electronic financial transactions entered into through our website will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email.

Revision Date: December 26, 2019