This privacy statement was last updated on June 1, 2023. Alawar Entertainment, Inc., a Delaware corporation, and its affiliates (collectively, "Alawar") has created this privacy statement in order to disclose our information gathering and dissemination practices for the internet website company.alawar.com and others (collectively, "Website"). While some of Alawar's Websites are deemed to be a U.S. websites, Alawar abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the processing, collection, use, and retention of data from the European Union. Alawar will be the data controller within the meaning specified in The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). Upon reading this privacy statement, you will know:
- The organization collecting the information.
- What Personal information of yours or third party Personal information is collected from you through the Website.
- How the information is used.
- With whom the information may be shared.
- Information relating to the use of this Website by children, and how parents can access their children's information.
- The kind of security procedures that are in place to protect the loss, misuse or alteration of information under Alawar's control.
- What choices are available to you regarding collection, use, distribution and other processing of the information.
- How you can access, rectify, erasure Personal information collected and processed about you.
Questions regarding this statement should be directed to the Alawar Data Protection Officer by emailing email@example.com
or writing at the following address:
Alawar Entertainment, Inc.
244 Fifth Avenue, Suite F164
New York, N.Y. 10001
To return to the Alawar home page, please use the "Back" button on your browser.
Word from the Company
In the sense of GDPR "Personal information" means any information that identifies directly or indirectly a particular individual, such as individual’s name, postal address, e-mail, telephone number.
Third Party Websites
Alawar does not control the information collection and distribution policies on Internet domains other than those Internet domains that are under the control of Alawar itself. When you are on the Alawar Website, you may be directed to other sites that are beyond our control. These other sites may independently process data, solicit personal information, or send their own cookies to you. Alawar is not responsible for any use of the information including click-stream data created when using such third party sites.
Some of the Websites are United States websites and are subject to the laws of the United States. Alawar will disclose personal information without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to Alawar guests, visitors, associates, or property (including this Website), or to others. Laws related to Personal information vary by country. For example, personal information processed in the European Union is subject to the EU Directives and Regulations concerning personal data, privacy and electronic communications, including but not limited to The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector.
Alawar may be required by law enforcement or judicial authorities to provide Personal information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, we will provide this information upon receipt of the appropriate documentation. Alawar may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.
B. COLLECTED INFORMATION
Information We Collect
As a visitor to the Website, you can engage in many activities without providing any Personal information as described above in Section Browsing above. In connection with other activities, such as subscribing to periodic newsletters sent by Alawar, requesting customer support, Alawar may ask you to voluntarily supply us with certain Personal information about yourself. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, Alawar may ask that you provide us Personal information, including but not limited to your e-mail address, and non-personal information related to the configuration of your Device, your experience in our services and products. This information is requested in conjunction with contacting us for customer support. In addition, as noted below, minimum information is requested if you choose to subscribe to our newsletter service.
You never have to answer any questions, and you can decline this exchange of information at any time. However, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
We do not collect any Credit Card and payment information.
You are provided an opportunity on the Alawar Website to subscribe to a periodic newsletter. This newsletter is a marketing tool that allows Alawar to inform you of new products or services, as well as other news relevant to the company. The subscription service requires you to provide your email address.
While the subscription and customer support lists are maintained by a trusted third party affiliate, the lists remain the sole exclusive property of Alawar. Your email address is not shared with any third party and will not be used to send you unsolicited communications. A link is provided to allow you to request the customer support and change your subscription preferences, including cancellation of your subscription.
When processing is required in order to comply with a legal obligation to which we are subject, we may also obtain information about you from our partners, e.g. from our advertising partners. We only use the data controlled by our partners in accordance with their legitimate instructions and applicable laws.
In addition, we may use the information made publicly available, e.g. through YouTube, Facebook, Instagram, LinkedIn and Twitter, in order to find out your opinion about Website and our products, so that we could take them into account while improving our Website and products.
Alawar may collect information about the use of the Website, its products, such as the types of services, products used, in-game activities, statistics and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. Alawar may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.
Alawar is the sole owner of the information it gathers on the Website, its products. Alawar will only share your information with outside parties in ways that are described in this privacy statement or if we are required to do so by law or in the good-faith belief that such action is necessary in order to conform to the edicts of the law, cooperate with law enforcement agencies, or comply with a legal process served on our Website.
Online Tracking Technologies
. Our Website uses "cookie" technology. "Cookies" are short pieces of data generated by a web server that a website stores on a user's computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us. In addition, cookies are used to:
- measure usage of various pages on our Website to help us make our information more pertinent to your needs and easy for you to access;
- provide functionality such as online orders, Alawar's services and other functionality that we believe would be of interest and value to you.
Cookies do not, under ordinary circumstances, corrupt or damage your computer, programs, or computer files.
You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
✓ Other Third-Party Identifiers
We use the following Google Analytics cookies:
_ga (also known as _rollupGa). The cookie is used to collect information and report website usage statistics. It expires after 2 years.
_gid (also known as _rollupGa_gid). The cookie is used to distinguish users. It expires after 24 hours.
_gat. The cookie is used to throttle request rate. It expires after 1 minute.
_gac_. This cookie contains campaign related information for the user. AdWords website conversion tags will read this cookie in an anonymous form. It expires after 90 days.
We use the following Doubleclick cookies:
IDE and DSIS. This cookie enables features in Google Analytics that are not available through standard implementations. Advertising features include: remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers. The cookies expire after 2 years.
You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout. Further information can be found under http://www.google.com/analytics/terms/gb.html (Google Analytics Terms of Service & Privacy). Please note that on our Website, Google Analytics, Google Optimize and Doubleclick code is supplemented by "gat._anonymizeIp();" to ensure an anonymized collection of IP addresses (so called IP-masking). Also, you can prevent Google Analytics, Google Optimize and Doubleclick to collect such data on behalf of Alawar by clicking on the following link: https://tools.google.com/dlpage/gaoptout.
. We may also use advertising identifiers of third party advertising companies for recognizing your Device, serving ads on our behalf that may be relevant to your interests, understanding the usefulness to you of such ads, measuring advertising effectiveness, allowing more effective targeted advertising. Depending on your Device, you can choose to change or limit the transmission of your advertising identifier by going into your Device settings.
✓ Social Media Widgets
Information for Software Developers
From time to time, companies or individuals who develop software may access this Website in an effort to enter into a business relationship with Alawar. Contact information for this purpose is posted on our Website. For these individuals and entities, in addition to information related to your business, Alawar reserves the right to request Personal information including but not limited to your full name, physical address, email address, telephone contact number, employer, etc. This information will normally be requested only in those situations where you are contacting Alawar in the capacity of an agent or representative of an established business, and only in those circumstances where the information is required in order to consummate a business relationship. You may elect not to provide Personal information. However, failure to provide the requested information may hinder Alawar's ability to do business with you.
Information Relating to Children
The Alawar Website and any products or services available on that site are not directed at children under 13 years of age and, therefore, the Children's Online Privacy Protection Act ("COPPA") does not apply. However, we recognize that children under the age of 13 may access this Website and subscribe to the newsletter. The collection of information is covered above.
Parents and Legal Guardians may request from us to review, delete or stop the collection of the Personal information of their child. You may do so in one of two ways. If you know the email address, follow the instructions below regarding Choices and Rights Available to You or you may contact us by letter, or email using the address information provided at the bottom of this page.
C. USE AND DISCLOSURE OF INFORMATION
How your Personal information is used
Alawar acquire, hold, use and process Personal information based on the legal grounds, in order to fulfill contract with you and for the legitimate business purposes outlined herein and according to Article 6(1) of the GDPR. We will use your e-mail address to send a confirmation and, if necessary, might use the other information to contact you for help to process the service, products you have selected. If you subscribe to a service, for example, the information is used to register your rights, if any, to technical support or other benefits that may be made available to subscribed users. Your Personal information is also used to keep you informed about product upgrades, patches, special offers, features on our Website and other products and services of Alawar and selected third parties if you have so opted to receive such communications.
Alawar uses the information required for our detection, investigation and prevention of cheating in the products, on the Website and end user license agreement violations only for the purposes of detection, investigation and prevention of such cheating. If the data can be used to prove that cheating or another fraud or end user license agreement violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations.
Securing the Transmission and Storage of Information
Alawar operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by our users.
Disclosure of Information to Third Parties
Alawar does use the services of third parties, such as e-mail service providers, web hosting, data management and storage service providers, marketing, advertising companies for delivery targeted advertisements, business partners providing services, products that you have requested or may be of interest to you that act as independent contractors on behalf of Alawar. These parties are contractually prohibited from processing Personal information for any purpose other than for performing legitimate contractual obligations or to comply with applicable legal requirements.
We do provide non-personal information to certain service providers for their use on an aggregated, anonymized basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of Personal information to entities outside of the Alawar's affiliates for their use without your approval.
In the event that all or substantially all of Alawar's stock and/or assets are transferred or sold to another entity, Alawar may transfer Personal information to the acquiring entity. If, as a result of such a business transition, your Personal information will be used in a materially different manner, you will be given choice consistent with our policy regarding notification of changes.
Choices and Rights available to you
You can always choose whether or not to disclose Personal information and that choice will not prevent you from using the Alawar Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information.
Please inform us if any of the personal data we retain about you is inaccurate.
You can choose at anytime to opt out of receiving emails from Alawar or from having your Personal information shared with selected companies. If you want to opt out, you can do so by editing your preferences with respect to email or the sharing of information. If you elect to "opt out" we will not, as applicable, share your Personal information with third parties or send you emails.
You have the right to obtain deletion by Alawar of Personal information concerning you by writing at firstname.lastname@example.org or regular mail at Alawar Entertainment, Inc. 244 Fifth Avenue, Suite F164 New York, N.Y. 10001. If you request us to erasure your Personal information we will delete all Personal information about you, except for the data that are required for our compliance with the requirements of applicable laws or for our detection, investigation and prevention of cheating in the products, on the Website and end user license agreement violations.
Alawar is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing service if you have asked us not to do so, and issuance of these types of communications are rare.
You may access and correct your Personal information and privacy preferences, opt out of receiving emails, newsletters, the sharing or retention of any Personal information, by writing at email@example.com or regular mail at Alawar Entertainment, Inc. 244 Fifth Avenue, Suite F164 New York, N.Y. 10001.
To ensure that your request is honored, you must provide Alawar with information sufficient for us to accurately identify and access your records. Alawar reserves the right to contact you to verify that we have accurately identified your record.
Where processing of your Personal information is based on legitimate interests according to Article 6(1)(f) of the GDPR, you can use your right to object at any time. If you object we will no longer process your Personal information unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defence of legal claims.
You also have the right to lodge a complaint at a supervisory authority.
D. PRIVACY-RELATED INQUIRIES AND COMPLAINTS
or Alawar Entertainment, Inc. 244 Fifth Avenue, Suite F164 New York, N.Y. 10001.
Please note that if you provide Alawar with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), Alawar cannot guarantee that your most recent privacy preference will be honored.