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Privacy Notice

Updated May 30, 2021

This Privacy Notice explains how Frogwares Ireland Limited (“Frogwares”, “we”, “us”, “our”) and its websites: https://frogwares.com/, http://store.frogwares.com/, https://sherlockholmes.one/ (“Websites”), collect, process, use, share, and disclose your personal data, and how you can exercise your privacy rights when you visit our Websites or use our Products (“Products”) and Services (“Services”).

If you do not agree with the terms of this Privacy Notice (“Privacy Notice”, “Notice”), do not access or use our Websites, Services, Products or any other aspect of Frogwares’ business.

1. Data We Collect

A. Personal Data That You Share with Us

Name/Surname
Email address
Phone number
Address
We may also collect other non-personally identifiable information relevant to customer requests, tech support, and/or offers such as a DXDiag file that contains information about a customer’s hardware including a type of graphics card being used, your interests and preferences.

B. Information We Automatically Collect

IP Address

  • Information gathered based on cookies:
  • Location
  • Age (if you stay signed in your Google Chrome account, and have age indicated in your Google profile. In case you stay signed out, it is based on Google Analytics assumption)
  • Gender (if you stay signed in your Google Chrome account, and have gender indicated in your Google profile. In case you stay signed out, it is based on Google Analytics assumption)
  • Traffic referrer
  • Types of pages a user visits
  • Duration of page usage visiting
  • Interaction with website elements (button clicks, video views, etc.).

C. Personal Data That We Get from Others

If you purchase games from store.frogwares.com, we will collect payment information from Xsolla, our payment provider: IP, geolocation, User ID, email, country, credit/debit card expiry date, payment method, type of card, card issuer, ZIP code. In case our provider changes its privacy policy and data collection, the categories of personal data related to payment information might also vary.

D. Non-personal Data

For Support, we may collect your System data to provide you personalized customer support and to guide product improvement and customer support decisions. This data includes the content of your support requests as well as things like product version number, driver dates and version numbers, operating system details, hardware information (processor name, amount of memory, graphics card installed). It also includes error information provided by our Product.

2. How We Collect Personal Data

When browsing Frogwares’ Websites, in order to learn more about our Products or to contact our technical support, you may voluntarily provide some personal information, such as your name and email address when you intend to contact game support and fill in your personal data in the online form to send us a message or you wish to subscribe to our newsletter. You might also provide information online via cookies or similar technologies when you visit our Websites.

We collect personal data to better understand information about our customers and Websites’ visitors so we can improve our Services.

We also get information on user actions on our Websites (for example, like watching a video) while using cookies and specific tracking scripts (like Facebook Pixel and Google Analytics). As a result, using Google Ads becomes possible in relation to such users. However, we do not know and cannot identify the individual who pushed a button or watched a video, we just see an anonymized ID number.

3. How We Use Your Data

Usually, we only collect personal data from you when:

  • we have a legal obligation to collect and process personal information from you;
  • we have your consent to do so;
  • we need your personal information to fulfill a contract or request from you and provide you with the Services, for example, customer support Services;
  • the processing is in our legitimate interests (when we use advertising or marketing campaigns, analyze your gaming activities, protect, improve or suggest our Products and Services, etc.)
  • provided that it does not override your rights.

4. How We Share Personal Data

We use third-party service providers that help us deliver the Services and allow us to operate our business.

Third-party service providers are also used to understand our audience’s interests better, adapt our content to our users’ interests, and communicate with them outside of our Websites.

We currently use Mailmunch (mailing list management), Mailchimp (mailing list management), Google Analytics (website usage analysis, marketing effectiveness measurement), Facebook Pixel (helps measure the effectiveness of advertising, reach our fans on Facebook), Twitter Universal Website Tag (helps measure the effectiveness of our advertising, reach our fans on Twitter).

Please check the privacy policies and notices of the third parties that help us to run our business:

https://mailchimp.com/legal/privacy/
https://legal.mailmunch.com/privacy/
https://policies.google.com/privacy?hl=en-US
https://www.facebook.com/policy.php
https://twitter.com/en/privacy
https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

Third-party websites

Frogwares’ websites may provide links to third-party websites.

Frogwares does not make any representations or warranties with respect to such third-party websites. You should be aware that the owners and operators of such third-party websites might collect, use or transfer personal data under different terms and conditions than Frogwares. Upon linking to a third-party website, you should inform yourself of the privacy notices and policies of such third-party websites.

Xsolla

Xsolla is a payment services company that provides us with payment and billing tools.

Once you want to make a purchase of our product, you are transferred to Xsolla’s website. Consequently, your data is collected by Xsolla.

To understand how Xsolla collects your data, read their privacy policy using this link: https://xsolla.com/privacypolicy

5. Retention Periods

We will retain personal data for as long as you use the Service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.

6. Your Rights

Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Frogwares processes about you, for example:

  • Right to information;
  • Right of access;
  • Right to rectification;
  • Right to erasure (“right to be forgotten”);
  • Right to restriction of processing;
  • Right to data portability;
  • Right to object;
  • Right not to be subject of automated individual decision-making.

In case you have any request to exercise your rights or make a complaint, please send an email to marketing@frogwares.com.

In any case, you also have the right to lodge a complaint with the competent data protection authority.

7. Your California Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”) grants certain rights to our users who are California residents to access or delete the personal information that we have collected about them, to opt-out of the sale of their personal information by us to a third party, and not to be discriminated against for exercising these rights.

· Access

Right to Know of Personal Information Collected. You have the right to request what personal information we collected, used, disclosed, and sold about you within the preceding 12 months.

· Deletion

Right to have Personal Information Deleted. You have the right to request the deletion of your personal information that we collect or maintain.

· Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to “opt-out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA). You have the right to request us to not sell your personal information at any time (the “right to opt-out”). However, we do not sell personal information to third parties.

· Non-Discrimination

Right to Not Be Discriminated Against for Exercising Your Privacy Rights You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.

8. International Data Transfers

When you use our Websites, Services, and Products your personal data may be sent, accessed, used, and/or stored outside of the country or region where you live. We may transfer personal data to our affiliates, vendors, contractors, business partners, and other third parties as described in this Privacy Notice, and by using our Websites, Services, and Products you consent to such transfer.

Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in the place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards or otherwise ensure that such transfers meet applicable local legal requirements.

9. Cookies

We use cookies and similar technologies to help us personalize our website for you, remember your preferences, understand how users are using our website, and help customize our marketing offerings. By visiting our Websites, you can control the use of cookies by disabling some of them. For more information, please read our Cookie Policy.

10. Data Security

Frogwares is committed to protecting the security of your personal data. We use state-of-the-art security technologies, policies, and procedures to protect your personal data from unauthorized access, use or disclosure. We guarantee that your data is kept confidential and secure.

11. Children’s Privacy

We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, email, address or phone number, or any personal information, without their parent’s or guardian’s prior permission.

We consider visitors of our Websites as children if they are under the age of 16 unless more stringent regulation applies in their country of residence.

No personal information should be submitted to Frogwares by users under the minimum legal age required in their place of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their country of residence.

If you believe that your child has submitted personal data to Frogwares without your consent, please contact us at marketing@frogwares.com. Frogwares will take reasonable steps to delete such information as soon as possible.

12. Changes

Frogwares may update this Privacy Notice from time to time. When we update the Notice, we will revise the updated date above and post the new Privacy Notice. We recommend that you review the Privacy Notice each time you visit the Websites to stay informed of our privacy practices.

Frogwares may modify or update this statement when necessary to reflect customer feedback and changes in our Products and Service. Your continued use of the Service or Products after any modification to this statement will constitute your acceptance of such modification and updates.

13. How to Contact Us

If you have any questions, comments or concerns about the use of your personal information, please send us an email to marketing@frogwares.com.