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PRIVACY POLICY

Purpose & Intro

This Privacy Policy (“Policy”) aims to give you a clear vision and understanding on how your personal data is collected and processed whenever our users (“Users”, “You” or “Your”) play PERLTEC (“We”, “Us” or “Our”) games (or “applications”) or otherwise access any of Our other content, services, products, victorianquest.com or other connected with Us websites provided by PERLTEC, together referred in this Policy as “Services”. Therefore, it is important to read this Policy together with any other policies herein.

We are devoted to protection of privacy of its Users giving them the best technical and virtual social gaming experience.

This Policy consists of such key points:

  1. Who and how to contact?
  2. What Data, in which way and on which legal basis is collected by Us?
  3. How Data is used and with whom We share it?
  4. How You can access, update, manage or delete Your Data?
  5. How Do We protect Your Data?
  6. How Do We protect children’s privacy?
  7. How You can use your rights as a Data subject?

By using the Services, You understand, agree and have no objections to collection, disclosure, storage or use by Us of Your information as described in this Policy. If you disagree, deny or simply do not want Us to collect, store, share or use Your information in the ways disclosed in this Policy, You should immediately stop the use of Our Services.

We can update or change the Policy from time to time, therefore we recommend and advise You to occasionally or regularly review the Policy.

Users in certain jurisdictions have a right to access Personal Data held about themselves, in accordance with applicable law(s).

Policy Updates

This Policy was last updated on October 04th, 2023 (“Effective Date”).

If there will be any material changes in this Policy, We will duly inform You and other Users by placing a respective notice on victorianquest.com or its more compact equivalent in the game or via other appropriate options available. We recommend to check this Policy from time to time or at least once (1) per three (3) months.

1. Who & How to Contact

PERLTEC is responsible for the provided Services and protection of Your Personal Data. If you have any specific or personal (not generally understandable) question(s) about Your Personal Data or in connection subject(s), You can contact Us via e-mail at compliance@victorianquest.com.

You can reach Us via Our in-game support section and at: John Kennedy, 8, IRIS HOUSE, Floor 3, Limassol, 3106, Cyprus and/or contact@victorianquest.com.

2. What Data, on Which Legal Basis & in Which Way is Collected by Us

In this Policy the Personal Data or Personal Information is any individual (personal or objective) information about specific or duly (means, not anonymous/anonymized) identifiable person. For instance, Your name, personal living or email address, as well as IP addresses and device-related identifiers.

We collect Personal Data only to the extent necessary to fulfill basic functions and connected activities in the scope of provided Services within available fair, transparent and reasonable means. We collect Personal Data directly from the Users, however, there are circumstances when it will be necessary or technically possible to collect information only from third-party sources (outlined below in the Policy).

Generally, We will process your Personal Data based on such given legal bases:

  1. Legitimate Interest (GDPR (Directive 95/46/EC), art. 6(1)(f) & 6(1)(b)). Ensuring smooth, secure and optimized experience of Our Services, including but not limited to any following updates or improvements to Services, fulfilling Our contractual obligations before Users.
  2. Legal Obligations (GDPR, art. 6(1)(c) & 6(1)(d)). Complying with processing and protection of Users vital interests or those of another person (like another User) entrusted to Us.
  3. User Consent (GDPR, art. 6(1)(a)). We provide all necessary and legally required information for Your review to provide or not Your consent to freely process Personal Data.

Every correspondence with Users is logged and stored within Our system. Whenever You provide Us with other information which is not explicitly disclosed in this Policy (like financial data), You give Us Your explicit consent for processing such data for the intended purpose.

We will duly inform Users when providing Personal Data is mandatory. We neither sell Personal Data of Our User nor intend to sell it in future.

2.1. Users Data Provided by Third-Party Application(s)

Whenever You use Our application or any Our other Services on connected third-party application(s) or connect Our Services to any third-party application (like social networks – Facebook), We may receive some specific information about You from respective third-party application provider. The size and format of received information will depend from: settings used in Our game; the third-party application; settled User privacy settings; and other data settings (like friends’ or contact’s privacy settings, if any).

We may process some or all of the below mentioned information about You shared by the connected third-party application provider:

  • Chosen profile name.
  • Game connected social network ID.
  • Profile Picture or its URL.
  • Friends or Contacts Public data.
  • Device information used to receive Our Services and physical location (city & country).
  • Other publicly available information on the connected third-party application.
  • Any other information that You or the connected third-party application provider shares with Us.

2.2. Cookies

We do not use cookies on Our website. Nevertheless, cookies are small files consisting of numbers and/or letters that are stored in your web browser that provide the possibility to recognize your device which you use to visit the website. Those files do not include names, contact or other personal data, due to the fact that they generally contain anonymous information which is used or required for the better user experience and overall Website secure functionality.

For the purpose of better Cookies understanding and making a well-informed choice, we recommend to visit a respective browser Cookies guide or visit www.aboutcookies.org or www.allaboutcookies.org.

2.3. Directly Shared with Us Users Data.

Whenever You use Our Services (either via a social network or application(s)), You may provide Us information directly (for instance, during Your account set-up), which We store in Our Systems and use it only for the purpose described in this Policy. Your directly shared information may include or consist of Your:

  • E-mail address when you contact Our customer support team via e-mail.

2.4. Users Payment Data

We neither collect nor intend to collect or store Users financial information (like cards credentials or connected information).

2.5. Users Support Data

Except as provided in this Policy and herein, whenever You ask for the help for Our support team, We will collect and store provided contact (email), request/issue, game play or connected to Our Services information, and Your unique User ID. All communication between You and Our support team (including but not limited to any information shared within such communication) will be stored in Our System in order to provide better support and improve Our Services. In case if We will detect or be informed that a User is younger than 18 (or than 16, depending on the country of User origin), the provided contact information will be used once during providing of a one-time response. Afterwards, We will delete Your information from Our system.

3. How Data is Used and with Whom We Share it

3.1. How Data is Used

We collect and store information to provide Our Services fully and create the best gaming experience for Our Users. There are other uses for the collected and stored information by Us, like:

  • To create Your game account and provide the ability to play Our games.
  • To operate, optimize, improve or fix Our Services and give You the best possible gaming experience.
  • To provide technical support and best respond or assistance within created User inquiries.
  • To protect and guarantee (to the extent possible) safety of Our Users.
  • To protect, safeguard and guarantee Our rights and property connected with provided Services.
  • To foresee and/or prevent fraud or possible illegal activities and enforce respective measures within our Terms of Services.
  • To manage and provide personalized advertising experience.
  • To notify Users about: in-game updates; content or promotional offers; surveys with rewards; or other events sponsored or managed by Us or Our partners.
  • To conduct research activities.
  • To fulfill and comply with Our legal obligations, and if necessary, use our legal rights to resolve any disputes which may arise with You or other Users.

3.2. With Whom We Share Your Data

General Cases. We can use, disclose or publish aggregated and/or analytical non-personalized information (collective non-personalized data, which has no intention to disclose your personal information like, “50” percent of User between the age of “20-40” who live in “City” are “women/men”) about Our Users for industry or game analysis, analytics, advertising and other connected business purposes.

Third-Party Services Providers. We use third-party companies’ services (like software, data analyzing, hosting and advertising) to duly provide Our own Services. With each such third-party company We have contractual relations which require these third-party service providers to maintain confidential shared information with legally binding obligations not use or share in any way possible Your Personal Data and keep such data duly secured.

Merger & Acquisition or Sale. In case if PERLTEC will follow the merger & acquisition or sale of all or part of its assets (like sale of a game) with another company, We may disclose or transfer all of Your information (including Personal Data) to the successor/buyer taking to the account Your personal/individual interests. Respectively, We will take all reasonable efforts to let You and other Users know (as described in Policy) about such a process before transferring Your Personal Data.

4. How to Access, Update, Manage or Delete Your Data

Data Access & Update. Any User can review, change or delete the Personal Data simply submitting a request via an in-game support section or directly via compliance@victorianquest.com email.

Manage of Data from Third-Parties. To manage, update or change Your information which We receive from a third-party platform where You play our game (like Google, Apple, Microsoft, Amazon or other), You will need to follow respective instruction of such a third-party application and do a privacy set-up (privacy settings). As soon as We receive Your information from respective third-party applications, such information will be stored and used by Us in accordance with this Policy.

Data Deletion. If You do not use Our Services or simply do not want Us to use Your Personal Data, You can send a request via an in-game support section or directly via compliance@victorianquest.com. After the receipt of such a request, We need to authenticate Your identity and ask for your confirmation (for authentication and deletion processes). We will provide a final answer within thirty (30) days from the date of Your authentication confirmation.

It is important to notice, that certain records may or will be kept at Our database for such purposes:

  • To detect and prevent any security incidents, defend against malicious, harmful, fraudulent or illegal activities, and/or prosecute responsible persons for such actions.
  • To identify, debug and fix/repair errors or bugs that deteriorate Our Services functionality.
  • To internally use Your Personal Data in a due and lawful manner that is compatible with a purpose/reason such Personal Data was provided.
  • To comply with imposed on Us legal obligations.

Legal Notice! If you have earlier provided (sent or posted) content on Our Services, We may no longer be able to delete provided information.

5. How We Protect Your Data

5.1 Security, Safety & Compliance with Applicable Law(s)

PERLTEC has implemented, tested and adopted reasonable technical and organizational measures to secure and safeguard Your Personal Data from unauthorized access, use, disclosure or accidental loss in both online and offline formats. Our team is committed to create even stronger measures to protect Our Users Personal Data, therefore, we will continue to take all reasonable steps (both technical and organizational) to ensure security of collected and stored Users Personal Data in accordance with this Policy.

Even while We use all reasonable and technically available measures to protect Our Services, databases and records, there can be no guaranties given regarding Websites or Internet transmission security. Therefore, We cannot guarantee that some sort of breaches will never appear (like hacking attack, unauthorized access, data loss or similar) or that implemented technical and organizational measures won’t be overcome by third parties to use Your Personal Data illegally.

User information (including any communication between User and Us) may be accessed, monitored, checked and disclosed as needed to provide Our Service, as follows:

  • When We have a legal obligation in response to lawful requests from public authorities (including but not limited to national security, law enforcement request/requirement, legal process (police or court order) and etc.).
  • To comply or correspond with any laws or regulations applicable to Us.
  • When We have a strong believe or evidence that Our Services are used as an instrument in committing a crime. And/or We believe that reporting/sharing such criminal activity data with other companies, public authorities can bring additional fraud protection, financial risks reduction and new mechanisms of precautions/preventions of crimes.
  • To protect and safeguard the rights (including Terms of Services) and property of PERLTEC and other applicable third parties.

We may transfer, store and process Your Personal Data within Our companies or share it with service providers based outside EU and/or EEA for the purpose stated in this Policy. However, We take all necessary and adequate measures to keep Your Personal Data, during the transfer, at the same secure level outside the EU and/or EEA as it is within EU and/or EEA and as it should be in accordance with this Policy.

5.2. Data Retention

We retain Your Personal Data for/to:

  • as long as it is necessary to fulfill the purpose for which such information was collected;
  • as necessary to comply with applicable business or legal requirements imposed by law;
  • to comply with any legal, accounting or other reporting obligations;
  • to resolve disputes and protect Our property and assets;
  • to conduct Our business activities and enforce Terms of Services or Agreement Terms.

To identify the appropriate retention period, we take into account: the size; quantity; nature and sensitivity of the personal data, including but not limited to the potential risks of harm from unauthorized use or disclosure of your personal data; the purposes for the personal data to be processed; and the applicable legal (regulatory) or other possible requirements.

Some information may be retained for several years even after You stopped playing Our games or use Our Services, until it is necessary to fulfill Our legal obligations or defend Our legal rights.

6. Children Privacy

Our games and Services are intended for use by individuals of age of 18 (or younger, or older if the local laws in Your applicable jurisdiction so accept or require) for amusement purposes only. PERLTEC does not knowingly collect Personal Data from anyone under the age of 18 (or younger, or older if the local laws in Your applicable jurisdiction so accept or require) based on age restriction laws imposed in Your country of origin. If We learn that an individual who is under age of 18 or under other minimum age restrictions has knowingly or unknowingly provided Personal Data to Us, We will immediately take actions for the deletion of such information.

We respect the privacy rights of its Users. Therefore, if a parent and/or a legal guardian believes that his/her child has knowingly or unknowingly submitted Personal Data to Us, he/she can contact Us via compliance@victorianquest.com. After the receipt of the letter and learning that it relates to a child under age of 16 or under respective country minimum legal age restrictions, We will immediately take necessary steps to delete the provided Personal Data.

7. Data Subject Rights

You as a data subject, can contact Us at any time to obtain an answer on questions related to protection of your Personal Data or if You are willing to use any of mentioned Rights:

  • To Withdraw the Consent (GDPR, art. 7(3)). You can contact Us with a request to revoke previously provided consent.
  • To Access the Data (GDPR, art. 15). You can contact Us with a request for a copy of Your provided Personal Data or related information stored about You.
  • To Correct the Data (GDPR, art. 16). You can contact Us with a request to correct any inaccuracies, missing or changed Personal Data (like e-mail).
  • To Erasure the Data (GDPR, art. 17). You can contact Us with a request to delete Your Personal Data as explicitly stated and permitted by law.
  • To Limit Data Processing (GDPR, art. 18). You can contact Us with a request to stop or limit processing of Personal Data as explicitly stated and permitted by law.
  • To Data Portability (GDPR, art. 20). You can contact Us with a request to receive Your Personal Data in portable form (structured, commonly used and machine readable) for the purpose of transfer (where technically feasible).
  • To Object Way of Data Handling (GDPR, art. 21). You can contact Us if You disagree with any processes of collecting Your Personal Data as stated in this Policy.
  • To Complain to the Supervisory Authority (GDPR, art. 77). If needed, You can directly contact the data protection authority.

The response on the requests will be provided within thirty (30) days from the receipt of the request via compliance@victorianquest.com. Notwithstanding the above-mentioned response period, it can be prolonged for additional thirty (30) days based on complexity of the request and the amount of other pending requests. In addition, We may reject in fulfillment of the request with appropriate and relevant justification of such a rejection.

If You have any other questions, comments or concerns about Our Policy, or any other (in relation) issue, You can contact Us via an in-game support section or directly via compliance@victorianquest.com.

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