Last updated on October 2nd, 2023

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, 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 (Directive on privacy and electronic communications)

1. General provisions

1.1. Elyland Investment Company Limited (hereafter referred to as «We» or «Company») takes all the necessary measures to process fairly and to protect the personal data of players of the game “Draconius GO: Catch a Dragon!” (hereafter referred to as «Game»).

1.2. This policy (hereafter referred to as «Policy» or «Privacy Policy») as well as the End User License Agreement (EULA) and all its addenda, regulate issues related to the collection, storage and processing of personal and other data of the players participating in the Game, which the Company collects as a result of You using the Game. To ensure transparency and security, Our Privacy Policy as set forth below will inform You about the nature, scope, and purpose of the personal data processed by Us. This Privacy Policy also explains how personal information (personal identifiable information, personal data) is collected, used and disclosed by Us while using the Game, or any related services made available through the Game, or when You otherwise interact with Us.

1.3. We reserve the right to update this Privacy Policy at any time without prior notice. We will process data in accordance to the Privacy Policy that you have consented to at the time of your consent. Upon a change in Policy, we will alert you with a conspicuous in-Game banner notice; your continued use of the Game and/or its services will constitute Your consent to the updated Policy. Use the “Last Updated” date in this Policy to determine when it was last changed.

1.4. Please note that We may combine the information We collect from You independently with the data that You provide Us with.

1.5. Capitalized terms that are used in this document signify the same concepts as those in the EULA.

2. Information on the person (controller) who controls the processing of players’ personal and other data in the Game:

Elyland Investment Company Limited, HE 266867, address: 7 Florinis, Greg Tower, 2nd floor, 1065, Nicosia, Cyprus. You can contact Us via [email protected]

3. What do we mean under personal identifiable information or personal data?

3.1. Personal data or personal identifiable information means any information relating to an identified or identifiable natural person. The definition of personal data now encompasses not only natural person’s explicit identifiers like name or address, but also any online identifiers depends on kind of device which is used (IP address, Your device ID etc.) together with other personal data. We would like to clarify if We collect the IP addresses of User but does not link the IP address to any particular consumer or household, and could not reasonably link the IP address with a particular consumer or household, then the IP address would not be “personal information”.

4. Categories of information We collect

4.1. We collect, process, or use the following categories of personal and other data:

• Your nickname, email address, time and date of registration in the Game;

• Information on Your whereabouts, speed and route in the Game while playing it;

• Information about Your in-Game transactions;

• Your identifiers in social networks and age-related interval, if You log in the Game using such networks;

• Your name, address, other data that you have provided while contacting Us via telephone, email or in any other way, especially using the contact forms in the Game or on the Website of the Game;

• Technical information such as Your IP address, which is used to connect Your device to the internet, information identifying Your device, Google advertising ID (or advertising ID for users of iOS), Your internet browser data, the operating system on Your device, the trademark and model of Your device, the time settings, the time of logging into the Game, information regarding Your usage of the Game (what Game sections You visit, how long the game process takes etc.), and demographic data (gender);

• Data that You have sent to Us through an online survey or support ticket;

• User behavior and interests (all the actions a user performs on a website or mobile application which includes factors like time on page, the number of pages visited, how user interact with different features, and also friction they encountered while using the product).

5. Children’s data

5.1. We understand that Our Game can be used by children. We will process personal data in relation to children according to all legal requirements and will do Our best to safeguard it. For the purposes of this privacy policy, “children” are individuals who are under the age of sixteen (16).

Our Services are not intended for children under the age of 13. Though Our Services do not target Children as the primary audience, we may collect age information before allowing /not allowing a user to proceed for certain Services. For users who identify themselves as Children (from 13 till 16 years old), We obtain legally valid parental consent. If We learn that We have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, We will take reasonable measures to promptly remove that information from our records.

6. When do We collect information?

6.1. We collect information from You when You register in the Game, log into the Game, play, surf the Website of the Game, subscribe to a newsletter, fill out a form or enter information on the Website of the Game, contact Us, respond to a survey or marketing communication, or use certain other Game features.

6.2. We may receive information about You from third parties, for example, if You decide to log into the Game using any of Your accounts on other platforms. We may combine such information received from third parties with the data that You provided Yourself or that has been collected automatically. All kinds of information will be processed according to this Policy.

6.3. If You do not ask Us to delete certain data beforehand, We will store it for the period indicated by law, or necessary for the realization of the purposes for which We have collected it. In any case We may retain your personal information so long as Your in-Game account is active.

7. Purposes for processing information according to this Privacy Policy

7.1. We collect and process your personal data in order to:

• Fulfill Our duties as specified in EULA;

• Provide You with the services in the Game and access to the Game that You expect from Us and customer support per Your request;

• Provide You with information about the Game and the services in the Game, e.g. notifications about changes in the Game, and/or rules that regulate the process of the Game;

• Improve the Game and services it offers, including technical part of the Game, making sure players abide by the Game rules, ensuring players’ safety in the Game;

• Process transactions and send notices about Your transactions;

• Resolve disputes and troubleshoot problems;

• Prevent potentially prohibited or illegal activities, and enforce Our EULA, Game Rules or other legal documents;

• Ensure the security of Our Game;

• Concerning the Stored Credential: to analyse transaction risk levels for US;

• Show You Personalized Advertisement.

7.2. Beyond these purposes, We process Your data only if You have granted express consent for its stated purposes or according to legitimate interest.

8. What is the legal basis for processing Your personal information?

8.1. We are committed to protecting Your privacy and handling Your data in an open and transparent manner and as such We process Your personal data for one or more of the following reasons:

• For the performance of a contract. We process personal data in order to offer services based on contracts (EULA) with Our customers but also to be able to complete the procedure so as to enter into a contract with prospective players. The EULA terms and conditions provide more details of the relevant purposes.

• For compliance with a legal obligation. There are a number of legal obligations emanating from the relevant laws to which We are subject as well as statutory requirements (i.e. financial reporting, paying taxes). Such obligations and requirements impose on Us necessary personal data processing activities for compliance with, for example, court orders, tax law or other reporting obligations.

• For the purposes of safeguarding legitimate interests. We process personal data so as to safeguard the legitimate interests pursued by Us or by a third party. A legitimate interest is when We have a business or commercial reason to use Your information. But even then, it must not unfairly go against what is right and best for You. Examples of such processing activities include: initiating legal claims and preparing Our defense in litigation procedures: measures to manage business and for further developing Our Game and related services.

• You have provided Your consent. Provided that You have given Us Your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. We process Your User’s behavior and interests only after receiving Your consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of Your revocation will not be affected.

9. Transfer of information to third parties

9.1. We do not sell or rent Your personal information to third parties. We do not transfer Your personal data to third parties, with the exception of cases as specified in the Privacy Policy.

9.2. We may use third party companies and individuals for the purpose of developing and supporting the Game, providing access to the Game on Our behalf and services in it (e.g., without restriction, hosting and operating the Game, database management, web analytics pertaining to the processing of payments, detecting fraudulent activities, and improving the Game, or helping Us in analyzing the practices of Your usage of the Game). Such third parties may have access to Your personal data within the context of performing such work on Our behalf. These processors may be located outside the European Union. Please note that the Company grants access to any information under the condition that the third party ensures the safety of the information to which it may have access according to the data protection laws and the GDPR.

9.3. In particular, We work with (or may work with in the future) network advertisers, advertising agencies, providers of analytics services and other providers, which: provide Us with information regarding the traffic on the Website, including the pages visited and actions taken by a player; support Our advertisements on other websites, mobile applications and other places on the internet; provide Us with information on the usage of the Game and the effectiveness of Our advertisements. Our service providers may collect certain information about Your visits and actions in the Game, as well as other websites or services. They may also install and gain access to their own tracking technologies on Your technical device (including cookies and web beacons) and may use this information to show You targeted advertisements, provided You give Your consent to these activities.

9.4. We may also share Your personal information with other entities of our corporate group. Such disclosure is regulated by our internal corporate privacy policies.

9.5. It must be noted that we may disclose information about You for any of the reasons set out hereinabove, or if We are legally required to do so, or if We are authorized under our contractual and statutory obligations, or if you have given Your consent to do so. All data processors appointed by us to process customer data on our behalf are bound by contract to comply with the GDPR provisions.

9.6. Under the circumstances referred to above, recipients of personal data may be, for example: supervisory and other regulatory and public authorities; external consultants, financial and business advisors; auditors and accountants; marketing operators; card payment processing companies; file storage companies, archiving and/or records management companies, cloud storage companies; companies who assist us with the effective provision of Our services to You by offering technological expertise, solutions and support; website and advertising agencies.

9.7. Our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures. We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose Your personal information to a regulatory or law enforcement agency if We believe it to be necessary to protect the rights, property, or personal safety of Our Company, its customers or any third party.

10. Email communications

If you have given Us Your email for purposes of communication or promotion, we will Use Your data to contact You or send promotional emails relating to Your interests. You may revoke Your consent to being contacted by email for promotional purposes any time, by clicking on an unsubscribe link or replying directly stating Your wish to unsubscribe.

Further, with Your consent, We may make use of email tracking technology to obtain data on if You open an email or if you click on links in an email. This data will be used only in automated ways to help improve future marketing messaging and/or to prioritize follow ups based on perceived communications relevance. Without Your consent, We will not make use of personal data unique to You, such as your IP address, Your device and browser information, or the time and number of times You open an email or click on a link.

11. Cross-border data transmission

Your personal data may be stored on servers that are located beyond the borders of Your country of origin or residence. We take all technical and organizational measures to ensure the security and safety of any of Your personal data that may be stored and processed outside of Your local jurisdiction. Personal data of the EU residents is kept within EU territory.

12. Changing or deleting Personal data or other information on a player, and refusal to provide such data

12.1. If You wish to find out what information about You is being stored, You may do so by sending Us a request at this email: [email protected]. You can also send Us a request to delete or change Your personal data. Please note that in the case of deletion of data, some or all of the Game’s functions may become unavailable to You.

12.2. At Your request, We will delete Your personal data and will make a commercially reasonable effort to delete any other information related to You. However, certain data will be stored on Our servers even after the deletion of Your personal data. For example, some personally-non-identifiable information related to You may be stored in Our archives for the purposes of administration. Besides, the requirement of information deletion is conditioned by the need of complying of legal obligations and resolving possible disputes. You should also understand that it is not always technically possible to completely remove certain information from Our databases.

12.3. Additionally, We will not delete any information that You Yourself have posted publicly in the relevant sections of the Game. Please note that neither You nor the Company can delete all copies of any information that has been previously transmitted to other persons in the Game.

13. How do We protect Your information?

13.1. Our servers and other devices as well as software used in the Game are scanned on a regular basis for security holes and known vulnerabilities in order to make Your user experience as safe as possible.

13.2. We use regular malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We provide training to Our employees and subcontractors on data protection best practices and require them to enter into a confidentiality agreement. In addition, all personal information You supply is encrypted via Secure Socket Layer (SSL) technology.

13.3. We implement a variety of security measures when a player interact with the Game, places an order, enters, submits, or accesses their information to maintain the safety of Your personal information. However, while We use all reasonable efforts to protect Your personal information, We cannot guarantee the absolute security of Your data submitted through Our Game.

14. Do We use “cookies”?

14.1. A cookie is a small text file that a website stores on your computer or mobile device (mobile app uses technology called a webview) any of them hereafter referred to as – “device” when You visit the Game or use application of Game. First party cookies are cookies set by the website of Game. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies. Persistent cookies are cookies saved on Your device and that are not deleted automatically when You quit Your browser, unlike a session cookie, which is deleted when You quit Your browser.

14.2. How do We use cookies?

We use “first-party cookies”. These are cookies set and controlled by Us, not by any external organisation. However, in Game You will have to accept cookies from external organisations.

The 3 types of first-party cookie we use are to:

• store User preferences;

• make Our Game operational;

• gather statistic/analytics data (about User behaviour).

Visitor preferences

These are set by Us and only We can read them. They remember:

• if You have agreed to (or refused) our Game’s cookie policy;

• if you have already replied to our survey pop-up (about how helpful the site content was) – so you won't be asked again.

Operational cookies

There are some cookies that We have to include in order for certain web pages to function. For this reason, they do not require your consent. In particular:

• authentication cookies;

• technical cookies required by certain IT systems.

Authentication cookies

These are stored when You log in to Game. This allows Us to analyze Your Game usage and your selections (e.g. your login name, language, or region).

Analytics cookies

We use these purely for internal research on how We can improve the services in Our Game. The cookies simply assess how You interact with Our website – as an anonymous user (the data gathered does not identify You personally).

Also, this data is not shared with any third parties or used for any other purpose. The anonymised statistics could be shared with contractors working on communication projects under contractual agreement with the Company.

Advertisement cookies/Third-party cookies

Our Game displays content from external providers. To view this third-party content, you first have to accept their specific terms and conditions. This includes their cookie policies, which We have no control over.

But if You do not view this content, no third-party cookies are installed on Your device. Third-party providers (third-party partners) in Game are:

These third-party services are outside of the control of the Company. Providers may, at any time, change their terms of service, purpose and use of cookies, etc.

14.3. How can You manage cookies?

You can manage/delete cookies as you wish - for details, see aboutcookies.org

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved information (e.g. saved login details, site preferences). For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser.

15. Ads

15.1. Ads Served in Mobile Apps: When You play mobile application Game, We or Our Advertising Partners may use one or more of several different identifiers of Your mobile device, including Apple Identifier For Advertising (IDFA) or Android Advertising ID (AAID), to target and deliver ads to You in Game. This means that Your device identifier may be accessed by third-party ad networks and used to (a) help manage the number and types of ads You see; (b) track the source of installs related to ads seen in other apps; and (c) identify Your interests and behavior and target advertising to You based on those interests and behavior.

If you do not want to receive interest-based in-application advertisements on your mobile device, you may reject your consent.

See below for descriptions about the cookies used on Our site and how You can opt out from them.

16. How long We keep Your Information:

How long we retain Your personal information depends on why We collected it and how We use it, but We will not retain Your personal information for longer than is necessary for Our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

17. Contact details

If You have any questions concerning the procedures We use to process Your information, or information related to You in the Game, kindly submit them at the following email: [email protected] or via the contact form on the Game’s Website.