Published by APL Publishing Ltd., 60/2, Melita Street, Valletta VLT 1122, Malta (hereinafter referred to as the ‘’Company’’ or the ‘’Administration’’), the owner of exclusive rights to the Game respects the right of Users to the confidentiality of Personal Information. The Company understands the importance of protecting the information received from Users. The Company approved this Privacy and Cookies Policy (hereinafter referred to as the ‘’Policy’’) to inform Users about the collection and use of their Personal Information.
This Policy provides the conditions, procedures, and purposes of collecting, using, processing, storing, disclosing, transferring and deleting of the User(s)’s Personal Information, as well as the conditions of the User(s)’s Personal Information protection. This Policy explains how a User can view, update and request to delete Personal Information as stipulated under the Governing Law. This Policy also provides the conditions, procedures, and purposes of the use and storage of cookies by the Administration.
The End User License Agreement (hereinafter referred to as the ‘’Agreement’’), Game Rules and other documents published in the Game and Game Services are an integral part of this Policy. In its turn, this Policy is an integral part of the Agreement, Game Rules and other documents of the Game and game services.
This Policy is only applied for the websites and other services of the Game and does not cover other websites and services.
Any use of the Game and its Online Facilities and/or clicking “Accept” at the registration form means that you are acquainted and agree with this Policy, and unconditionally accept all its terms.
If you do not agree with any conditions of this Policy, you have no right to further use of the Game and its services, please leave this website and do not use the Game.
Any capitalized terms contained herein shall have the same meaning as has been assigned to them in the Agreement.
1. The Company is committed to respecting the privacy of the User whilst complying with all applicable data protection laws as established under the Governing Law. The Company ensures that the User’s Personal Information is processed fairly, lawfully and in accordance with good practice and it is only collected for specific purposes which are known and accepted by the User when the User chooses to make use of the Software, the Game and the Internet Site.
2. The Company is registered with the Data Protection Commissioner in Malta and adheres to the Data Protection Act, Chapter 440 of the Laws of Malta and any other relevant regulations, legal notices and/or similar rules in Malta.
3. This Policy covers the following resources of the Game: the interactive multi-user online game «Tanki Online. Version 2» , the chat room of the Game, the forum of the Game, Tanki Online Wiki, Tanki Online News (hereinafter collectively referred to as the “Game Services”), as well as all the online forms, internal forms and means of communication used in the game services and in the Game client for collection of personal information.
4. The Company assures that all that is reasonably possible has been put in place in order that Personal Data is at all times:
a. processed in accordance with User’s rights;
b. processed fairly and lawfully;
c. obtained only for a specific and lawful purpose;
d. adequate, relevant and not excessive to the purpose of collection;
e. accurate and updated;
f. kept in a secure manner;
g. not kept longer than is necessary for the purpose of collection;
h. not transferred to jurisdictions which do not ensure adequate protection of Your Personal Data; and
i. is only utilized for the reasons disclosed herein.
5. Personal Information received by the Company can only be accessed by the Company’s employees and representatives as well as the affiliates of the Company in possession of the required clearance. All persons who have access to such Personal Information are required to comply with the terms of this Policy and are contractually obliged through their employment contract or other agreement to keep such information strictly confidential even after the employment with the Company has been terminated.
6. The Company is committed to take all possible organizational and technical measures to protect the User’s Personal Information from illegal or accidental access, destruction, alteration, blocking, copying, distribution, as well as other illegal actions of third parties.
7. The Company has adopted the best practices when it comes to the principle of protection of e-mail communication with User and protection of any other method of communication which might be necessary from time to time.
8. Data protection legislation may differ in different countries. The Company will aspire to follow the conditions of this Policy as much as possible and will protect the User’s Personal Information as much as possible, regardless of where it has been collected and/ or how it has been transmitted.
9. The Company may only transfer Personal Information to third countries if the third country has an adequate level of Personal Information protection or if such transfer is required for conclusion or performance of the Agreement or other contract in the User’s interests, or if such transfer is required to protect the User’s interests, or if the Company provides adequate guarantees in relation to Personal Information protection.
Collection of Personal Information
10. The Administration shall have the right to request from the User any information in order to enable the use of the Game, which may include the information provided in the course of filling special forms in the Game and Game Services, including the information provided during registration, subscription to services, publication of materials and request for other services, including e-mail, IP address, phone number, identification data (ID) in social networks, username, password and other information.
11. The Administration may request any information required to organize and conduct events in the Game when the User registers to participate in such events initiated by the Administration.
12. If User starts correspondence with the Administration or submits a report about problems with the Game or Game Services, the Administration has a right to store all this correspondence.
13. The Administration may ask the User to take part in surveys and request certain information in the course of surveys, but this is not a mandatory procedure and any User may refuse to participate.
14. The Administration may collect and process the details of transactions and the User’s payment data when a User avails himself of any Paid Service.
15. The User’s browser or a client program may transfer certain information about the details of visits to websites of the Game and Game Services, including the information about traffic, log-files, the data about geographical location of the User’s computer and its possibilities, and other information. The User hereby accepts that the Administration may use this information for the purposes and in the procedure established in this Policy.
16. The Administration may request other information from the User to perform some actions, such as sex, age, date of birth, and game preferences.
17. The Administration may collect, process and use other information specified in the Agreement, and any of the documents forming an integral part of the EULA.
18. If in the registration form of the Paid Services or any other registration form used in the Game or Game Services, the User furnishes any Personal Information, such provision means that the User has expressly given his direct and definite consent to this Policy, to the Agreement and to any document forming part of the Agreement, and such provision means that the User has expressly given his direct and definite consent on collecting, processing, using, storage, disclosure, transferring, cross-border transfer (transferring to third countries) and destruction of any User’s personal information, for the purposes of provided by this Policy, the Agreement and any documents forming part of the Agreement
19. Personal Information shall only be collected for legal purposes and in particular shall be collected for the hereunder reasons:
a. verification of User’s details;
b. registering an Account with the Company;
c. promotion and marketing of activities;
d. compliance with applicable laws;
e. appropriate and qualitative providing the User with any additional services that the Company may offer, such as technical support relating to the Game; and
f. performance and fulfillment of the Agreement and of all the documents forming an integral part of the Agreement by the Company, by its suppliers and/or by any third party acting on its behalf.
20. The Administration shall have the right to collect and make any use it deems fit of any information which is not deemed to be Personal Information according to the Governing Law, and the User hereby accepts that the Company may disclose to any third parties such non-Personal Information.
21. The User has the right to object to the processing and collection of his Personal Information and has the right to withdraw such consent at any time, except where otherwise determined by the Governing Law. Whenever such a User withdraws his consent, he understands and accepts that this may have a negative influence on the quality of the Game and Online Facilities as well as may cause the impossibility of access to the Game and/ or Game Services and the User hereby agrees that the Company shall have no liability for any loss and/ or damage to the User’s Personal Information in such case.
Use and processing of Personal information
22. The User hereby further accepts that the Company shall have the right to store and process the Personal Information provided, which the Company deems necessary in order to make use of the Game. The User further accepts and understands that all activities within the Game are logged.
23. The Personal Information that is disclosed by the User is collected and processed by the Administration for the purposes of appropriate and qualitative provision of Game Services to the User, for the purpose of development and improvement, to perform the Agreement and other actions specified in the Agreement, Game Rules and this Policy. The processing of Personal Information are collection, recording, systematization, classification, storage, accumulation, updating, modification, grouping, blocking, use, disclosure, transfer to the third parties, dissemination, destruction, deletion, and other actions necessary for the performance of the Agreement.
24. The Company does not sell the User’s Personal Information and does not disclose such information to third parties, except as provided in this Policy. The Company may disclose the general demographic and statistical information to business partners or advertisers. This is not directly related with the Personal Information and cannot identify a specific User.
25. To ensure proper provision of services, the Company has the right to transfer Personal Information to other persons or organizations that provide hosting services, payment services, services related to sending e-mails, and to moderators. These persons and organizations have the right to use the received personal information for the sole purpose of providing services to Users and are to be bound by the terms ensuring the proper use of the Personal Information.
26. The User accepts that the Company shall have the right to transfer the Personal Information provided to any affiliates of the Company for the purpose of appropriate and high-quality provision and improvement of Game Services and for the purpose of improving of Game Services, for the performance of the Agreement, Game Rules and this Policy.
27. If the Company merges with another company in the future through the process of reorganization and/ or merger and/ or sale and/ or acquisition and/ or liquidation and/ or through any other process, the User(s)’s Personal Information may be transferred along with the Company or its part, or it may be sold as part of the Company.
28. The User accepts that the Company shall have the right and the obligation to disclose Personal Information when ordered to do so by a decision deriving from the Governing Law and/or any other reputable jurisdiction and/ or when ordered to do so by order of the Regulatory Authority and/or when ordered to do so by order of the Data Protection Commissioner and/or in the event of User being directly and/or indirectly involved in any crime which somehow involves the Game and/or the Company’s services.
29. The User agrees that if the Company receives a claim from third parties (copyright holders) concerning the User’s infringement of the rights to Materials placed in the Game and/ or Game Services, the Company shall have the right to transfer the information about such User to the third party (copyright holder).
30. If the User enters in the Game and/or registers in the Game through sites of third parties and/ or through sites of partners of the Company, such persons can request, collect and process personal information of the User for the purpose of appropriate and high-quality service. Privacy and cookies policies of the third parties will be applied in that case. User accepts that the Company shall have the right to transmit User’s Personal information to such persons for the purpose of appropriate and high-quality provision of Game Services, performance of the Agreement, Game Rules and this Policy.
Storage of personal information
31. The Company will take all the necessary measures for the proper and safe storage of the User’s collected Personal Information in accordance with the conditions of this Policy. All information provided by User is stored on the servers of the Company .
32. The Company shall use a standard technology which includes firewalls to ensure the safety of the Personal Information.
33. The User is obliged not to disclose or transfer his/her identity or account details, which are used for authorization in the Game, to third parties. User is fully responsible for storage of his account information.
34. If User becomes aware that his/her account information have been stolen and/ or are in the possession of any third party, User shall immediately inform the Company about such circumstances so that the Company can take the necessary measures. In such cases the Company cannot guarantee the safety of User’s Personal Information and User hereby accepts that the Company shall not be held liable for any use of this Personal Information.
35. When User communicates inside the Game or Game Services (using a chat room, forum, etc.), the User understands that such communication takes place through the Company ’s Server and agrees that this data may be collected, stored and studied by the Administration. The Administration is not responsible for the confidentiality of the Personal Information and/ or other information which the User discloses to other User(s) through the Game, Game Services or other services associated with the Game (using a chat room, forum, social networks, etc.) and the Administration shall have the right to consider such information as being available within the public domain.
Cookies, IP-addresses and log-files
36. The Administration may collect and process information about the User’s computer, log files, including IP-address, type of operating system, browser and e-mail client, information about the traffic, date and time, details of visits to game services, user activity, information about accesses, settings, system notifications. This information about the Users’ actions in the Internet Site, is collected and stored for the purposes of systems administration, ensuring due functioning of the Game and Game Services, for the purposes of safety and strengthening of protection and ensuring system integrity (prevention of hacker attacks, unauthorized access.
38. Cookies stored in a User’s computer/ any other equipment through which the User makes use of the Game and/or its Materials have amongst others but without limitation, the following functions:
a. the provision of access to secured areas which User has requested, without these Cookies, services you have requested like secure login areas cannot be provided.
b. Visit Cookies – remembering the choices and/ or settings User has made and to enable User recognition when making use of the Game. Without such Cookies the functionality of the Game may be impaired.
c. Voting (Survey) Cookies – marking the items of any survey for which User has cast a vote and prevent User from voting again in the same survey.
d. Loading Balancing Session Cookies- improving the Game’s loading time by spreading workload and timing optimization of game services. Without these Cookies the functionality of the Game may be lost.
e. User Interface customization cookies which make it possible to save the User’s interface settings in case of repeat entry to the Game and game services.
f. Cookies placed and used for synchronization with the User’s data in social networks.
g. Performance (Analytics) Cookies – collecting anonymous information on how User makes use of the Game.
h. Advertising Cookies – delivering User with the most relevant advertisement and help improve the effectiveness of advertisement campaigns. User hereby accepts and agrees that the Company may make use of these cookies for its own advertisement campaigns.
39. The Administration may also allow certain third parties to put and make use of their own web performance (analytics) and advertisement cookies on the User’s equipment and to collect information from the Company’s Cookies, for the purposes of storage and analysis of information about the Users’ preferences and to improve the quality of services. At this case such third parties are bound by this Policy. The Administration guarantees that it shall exclusively allow reputable third parties to make such use.
42. Administration guarantees that the stored cookies are safe for Users and absolutely necessary for normal functioning of the Game and game services and for providing of services to Users by the Administration.
43. The cookies are stored for no more than one year. The terms of cookies storage by the third party shall be established by such third party.
44. User may at any time refuse to accept cookies and disable cookies by changing his/her browser settings. Disabling Cookies may have a negative influence on the quality of the Game and the Online Facilities and may also cause the impossibility to access the Game and the Online Facilities and User hereby agrees that the Company shall have no liability for any loss and/ or damage to User information in case User has disabled cookies.
Obtaining and Changing User’s Personal Information
45. User shall have the right to contact the Administration at any time in order to obtain a copy of User’s Personal Information which the Company has stored and to have any inaccuracies corrected where appropriate. User shall have a right to request that his Personal Information be erased, rectified, amended or completed. To contact the Administration regarding User’s Personal Information User should send e-mail on email@example.com.
Refusal to provide any Personal Information
46. Any Personal Information provided by the User to the Administration is provided on a voluntary basis. Nonetheless the Company cannot guarantee that the Game and/ or game services shall function properly and/or shall function at all in case of failure to provide any Personal Information when requested.
Social Network Sites
47. User hereby confirms that he understands and accepts that by making use of the Game through any Social Networking Site or other site of third party may also subject User to their terms and conditions.
Changes of the Policy
48. This Policy is valid as of the date of the last version. This Policy may be changed, amended, replaced in any form and at any time without prior or following notification of User, so we recommend to look through this Policy from time to time to be informed of all changes. Any further use of the Game and game services means unconditional acceptance of the modified version of this Policy.
Contacts with Administration
49. If you have any questions, remarks, complaints or comments regarding this Policy, please contact us at firstname.lastname@example.org. We will consider your questions as soon as possible.
50. The Administration may decline unreasonably frequent requests, which require disproportionate technical efforts, jeopardize the privacy of other Users or are extremely impractical.
51. If User starts any correspondence with the Administration or submits a report about problems with the Game or game services, the Administration shall have the right to store all this correspondence.