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MINION MASTERS PRIVACY POLICY

This is BetaDwarf Aps’ ("BetaDwarf Entertainment", "us," "we," "our") Privacy Policy for the free-to-play game, Minion Masters (the "Game"). This document ("Policy") explains BetaDwarf Entertainment’s policies for the collection, storage, use, and disclosure of user-related information for the Game and www.minionmastersthegame.com website ("Website") and all respective and related pages. BetaDwarf Entertainment abides by applicable privacy legislation.

BetaDwarf Entertainment develops video games across multiple platforms. With this development, we collect information from our customers, visitors, and users ("you," "your," "user," "users") of the games and related websites. This policy only applies to the Minion Masters Game and Website, and therefore is not applicable to any third-party websites you may link to from our Website and Game.

By visiting our Website and playing our Game, you automatically consent to this Policy and to our collection, storage, use, disclosure, and deletion of your data as outlined in this document. This Privacy Policy has been constructed to ensure Minion Masters Website and playing the Game.

PLEASE NOTE THAT THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME, SO PLEASE CHECK BACK REGULARLY TO STAY INFORMED OF ANY CHANGES. MATERIAL CHANGES TO THIS PRIVACY POLICY WILL BE POSTED ON THE SITE. YOUR CONTINUED USE OF THE SITE OR THE SERVICE, OR ACCESSING YOUR ACCOUNT, FOLLOWING SUCH CHANGES, CONSTITUTES AND SIGNIFIES YOUR FULL ACCEPTANCE OF SUCH CHANGES.

THE INFORMATION WE COLLECT

BetaDwarf Entertainment respects the privacy of its online visitors and recognizes the importance of protecting the data collected about you. BetaDwarf Entertainment collects personally identifiable data given by the user in the voluntary registration step of this Website as well as with registration on the PlayStation®4 and Xbox One game systems.

The Website registration process collects:                                                                                  

• Email Address

• User-Created name

When you sign up for, download, use or play Minion Masters, or are involved in Minion Masters events certain data is collected. This data may include:

The user's personal data from the Steam server, in accordance with the licensing agreement with Valve including but not limited to

• Steam User ID

• Steam display name

• Steam avatar

• Country of residence

• Steam currency settings

• VAC trust status

• Log of user activity within Minion Masters (including, but not limited to: login time, logout time, log of matches played, number of wins and losses, gathered experience points, events)

• Matchmaking Rating (MMR)

• IP address

• Country (identified based on IP address)

• Any other data which you supply us via our services

For purchasing in-game content – additionally:

• Your device/platform, purchases made with virtual or real currency (including transaction dates, currencies, value, products of transaction)

If you contact our technical support – additionally:

• Other data required to help you with any queries or support matters, such as data collected in crash logs that are gathered by your device or the technical parameters of the device you use to play Minion Masters.

You may also be asked to voluntarily provide us with personally identifiable data in online surveys. This data may include your name, email address, user name, birthday, demographic information, game experience, hardware specs, hobbies, occupation, platform preferences, additional contact information, and other game-related information.

In order for you to play Minion Masters or access other services, we need to process the data described above. In case you do not agree to provide us with the above-mentioned data, you will not be able to play Minion Masters, take part in esports tournaments or use other services.

Additional data we will collect from you is from Google Analytics™ about Website visitors, including browser information and country location. We also collect our visitor's IP addresses, domain name, geographic information, Gameplay statistics and scores, user ranks, and computer related technical data. None of this data is personally identifiable. This anonymous data is used for marketing purposes and enables us to better meet the needs of our customers. We may also enable and store "cookies" which collects data based on your user habits so we can improve our website and pinpoint issues. You always have the option to disable cookies, however, it may affect some website features.

Please remember when you are using support, forums, or purchasing merchandise/in game credits packages, you are dealing with a third-party. You may be asked to provide payment information, such as a credit card number, holder name, and holder address. That data will remain with said third-party and be applicable to their Privacy Policy. However, we may share personal information, such as the names of users, with trusted third-party service providers for reasons such as for order purposes/order statuses.

By accepting this Policy, you are confirming you are also agreeing that all data provided by you is true and complete. If believed otherwise, we reserve the right to delete your account.

As of May 2018, this is all the data we collect. As we roll out the next stages of Minion Masters, this portion of our privacy policy will be amended as necessary.

HOW DO WE HANDLE YOUR PERSONAL DATA?

The data we collect from you is stored on our secure servers in Europe or – only if necessary – by those of our trusted Partners. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

How long are we going to store your data? We will retain your personal data only for as long as needed in order to fulfil the purposes outlined in this Privacy Policy. In certain special cases, a longer retention period might be required by law, such as for tax reasons, accounting purposes or other legal requirements and obligations.

When we will no longer require your personal information in order to provide our game related services to you, we will either delete it or anonymize it. In particular:

1. we will keep data that is associated with your Minion Masters account for the duration of the agreement to access Minion Masters services (i.e. until you close your Minion Masters account and request deletion). Following account closure, limited data that we collect about you will still be retained for an additional few years for tax, legal and accounting purposes;

2. if you contact us and don’t have a Minion Masters account, we will retain correspondence with you as long as necessary to assist you, followed by a period necessary for legal or accountability purposes;

3. for marketing purposes, we will store data as long as we have valid consent, and we will delete or anonymize it without undue delay and no later than within 30 days from the moment we receive a request to unsubscribe.

HOW WE USE THIS INFORMATION

LEGAL BASIS FOR DATA PROCESSING. This data is used for the purposes of registering an account for you, verifying your identity, maintaining your account, debugging and technical support, and contacting you with information about Minion Masters as we produce more content or change the Site/Game.

When we process personal data about you, we do so only as necessary to provide you the Site/Game services you use (i.e. to perform the agreement between us), to meet our legal obligations or to fulfill the so-called “legitimate interests” of BetaDwarf Entertainment, or in accordance with the other cases described below. To clarify, by legitimate interests we mean lawful purposes that could be reasonably expected (protecting the security of the data we process, marketing and services as well as ensuring our marketing is relevant for you, conducting anti-cheat analysis and anti-fraud checks). When we rely on the legitimate interest, we consider and balance any potential impact on you and your rights. For other purposes, we will ask for your consent and you will be entitled to withdraw this consent at any time with no impact on the validity of the processing before your consent has been withdrawn.

Your data may be used for the following purposes:

• to carry out our obligations arising from any contracts between you and us, such as providing access and allowing you to play Minion Masters,

• to ensure enjoyable gameplay through the analysis of players’ data,

• to maintain the ranking of Minion Masters’ players,

• to calculate conversion rates and other elements of Minion Masters’ performance,

• to organize official events and award points to participants of third-party events,

• to maintain technical support services for game users,

• to identify incidents of game misuse,

• to maintain, improve or develop Minion Masters,

• for tax, legal and accounting purposes,

• for the accountability purposes as defined by EU legislation (GDPR),

The anonymous data we collect is unidentifiable and used for the sole purpose of analytics. We may use IP addresses to troubleshoot problems. Traffic and other anonymous/non-personal identifiable data may be shared with potential business partners and advertisers in an aggregated format.

BetaDwarf Entertainment may use aggregate or anonymous data which will not be linked to identify individuals for various other uses for it and/or third parties.

WHO WE SHARE THIS INFORMATION WITH

We may share your data with the following Trusted Partners who were engaged by us to help deliver our services and functionalities to you. Please rest assured that we always provide our partners with the minimum data necessary for them to achieve the purpose of their cooperation with us. We may share your information for legal purposes if we believe you are violating laws pertaining to the property rights of BetaDwarf Entertainment and the users of our Website/Game, as well as to ensure the safety of our users and the public or if we are required by law to share data with the police or other government authorities.

Minion Masters may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.

BetaDwarf Entertainment may disclose personal data to another entity purchasing (including for diligence purposes prior to purchase) the assets of BetaDwarf Entertainment, provided that entity abides by this or a similar privacy policy. If they do not, users will be notified on the Website and via email.

THIRD-PARTY LINKS

Our website contains links to third-party websites. Once you have been redirected to other websites, any data you provide is subject to said-third party websites’ Privacy Policy.

SECURITY

Personal data is acquired securely and stored in a combination of paper and electronic files to prevent unauthorized access. They are protected by security measures appropriate to the nature of the data. Only trained BetaDwarf Entertainment employees have access to personal data and abide by our procedures and protocols. However, due to the online nature of the Game, it is important to remember no online data is ever fully protected. There is always a risk the data you transmit to us may be lost to and/or misused by a third-party. By using our Website and Game, you are acknowledging and accepting this unavoidable online risk of data loss and/or misuse.

IN-GAME CHAT, ONLINE FORUMS AND PROFILE

You may choose to disclose information about yourself in our online forums or in-game chat/chatrooms when you play Minion Masters or utilize the Website. Information that you disclose in chat rooms, on the forums is public data, and there is no expectation of privacy or confidentiality in either place. Please see our Terms of Use Agreement  and End-User License Agreement  on this point and for other guidelines.

PROTECTING DATA OBTAINED FROM MINORS

No services or content on this website is designed or intended for children under 16 years of age. If you are under 16 years of age, the Website and Game are not intended for you and therefore you are not permitted to access the Website or Game. BetaDwarf Entertainment does not deliberately process any personal data of minors below 16 years of age.

YOUR RIGHTS AND ACCESSING INFORMATION

In case of any concerns or questions about your privacy, please contact us and we will do our best to assist you, or if for whatever reason you believe the personal data we have about you is inaccurate and requires change, please notify us through Minion Masters Support at support@betadwarf.com on the Website and we will make the desired changes. You may also contact Minion Masters Support at support@betadwarf.com if you desire your data to be deleted from our database. If, however, you feel we have not satisfactorily dealt with your concern, you can report it to your local data protection authority.

You have the right to object to the processing of your personal data at any time, such as for marketing reasons. You can do so by contacting us at the following email address: at support@betadwarf.com

You have the following additional rights:

● You have the right to access data held about you;

● You may contact us to request that we delete your personal data from our system;

● You may ask us to rectify/correct your personal data, if appropriate;

● You may ask us to restrict the processing of your data;

● You have the right to transfer your data to another entity;

● You have the right to file a complaint with a data protection authority.

You can exercise these rights by contacting us at support@betadwarf.com.

Under California law, California residents who have an established business relationship with us have the right to request certain data with respect to the types of personal data we have shared with third parties for their direct marketing purposes, and the identities of those third parties within the immediately preceding calendar year, subject to certain exceptions. All requests for such data must be in writing and sent to:

BetaDwarf ApS

Rentemestervej 80

2400, Copenhagen NW, Denmark

This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your data shared rather than providing the above-described data. You may exercise that choice by contacting us at the address listed above.

CHANGES TO THIS PRIVACY POLICY

BetaDwarf Entertainment has the right to amend or change this policy from time to time by posting an updated version on our Website. It is your responsibility to check the policy to ensure you accept any new terms. Once we change the Privacy Policy, it will become legally binding 30 days after we post it online. Unfortunately, if you do not agree to those changes (regardless of whether you email us), we must then ask you to cease using our Software/Websites.

This policy was last updated on 2018-05-07.

Notwithstanding the general terms of this policy, the collection, use, storage, disclosure, and deletion of personal data may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

CONTACT US

For more information on BetaDwarf Entertainment and privacy, please contact us at info@betadwarf.com

BY USING BETADWARF ENTERTAINMENT’S MINION MASTERS WEBSITE AND GAME, YOU SIGNIFY THAT YOU HAVE READ AND AGREE TO THE CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO OUR POLICIES, PLEASE DO NOT USE OR PLAY THE MINION MASTERS GAME.