Privacy Policy

HiTech Powerup OÜ, with registered office at Sepapaja 6, Tallinn 15551, Estonia (“CAERSIDI”) respects your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you may understand the ways in which we do and do not use the information you transmit when accessing and playing games, accessing and using website, platform, software services and related services (hereinafter the “Games”). Please note that your access and/or playing of the Games on our Platform constitutes your acceptance of this Privacy Policy as well as our Terms of Use.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY PLEASE DO NOT ACCESS THE PLATFORM AND/OR PLAY THE GAMES.

1. Definitions

“Applicable Data Protection Legislation” means any legislation in force from time to time which implements the European Union Directive 95/46/EC and Directive 2002/58/EC and the General Data Protection Regulation (“GDPR”) 2016/679 of April 27th, 2016 and is applicable to this Privacy Policy and all other applicable laws and regulations that may apply to the transfer of Personal Data.

“Personal Data” shall mean any information relating to a Data subject; an identifiable person is one who can be defined, directly or indirectly, notably by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Contact data and Service Data are Personal Data.

“Contact Data” means any names, phone numbers, e-mail addresses and certain financial details held within commercial systems to conduct the Parties’ relationship management and billing transactions between the Parties.

“Controller”, “Data Subject”, “Personal Data”, “Process/Processing” and “Processor”, shall have the same meaning as in the European Union Directive 95/46/EC or the General Data Protection Regulation 2016/679 of April 27th, 2016.

“Service Data” means any Party’s Personal Data (that is not Contact Data) held within the Parties’ systems, applications or databases and that may be accessed, processed, used or stored as a consequence of performing the services under the Privacy Policy.

“Third Country” means a country that is: (i) outside of the European Economic Area; and (ii) not the subject of a formal decision by the European Commission, made pursuant to Section 25(6) of the European Union Directive 95/46/EC or under Article 45 (1) of the General Data Protection Regulation 2016/679, stating that that country ensures an adequate level of protection for personal Data.

2. Collection of information

Information collected through the Platform

In order to access to the Platform and play the Games you must register an account with CAER SIDI. To create an account you are required to provide certain mandatory information such as your name, your email address, account login etc. which is mandatory in order to be able to establish an account. CAER SIDI collects financial information on the terms and conditions set out in this Privacy Policy. CAER SIDI does not use financial information for any purpose other than processing payments. Further you may, but may not be required to, provide certain voluntary information such as date of birth, screen name, your personal profile on the Platform, interests in and use of various games, products and services, and any other personal or preference information which you may choose to voluntarily provide.

CAER SIDI may also collect and process other information when you interact with the Games online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifier such as a device identifier of any of your computer(s) or device(s) that are used to access the Platform. Such information will be collected and processed irrespective of whether you only access the Platform or if you actually play the Games. CAER SIDI may also collect and process certain information when you as a user with a user account interact with the Games such as the information in your personal profile, the relationships you form in the Games, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit information through various channels.

Information collected through other sources

CAER SIDI may also collect information about you from other sources, such as third party sites or platforms, newspapers, blogs, instant messaging services, and other End Users of the Platform through the operation of the Platform in order to provide you with more useful information and a more personalized experience.

3. Cookies and logs etc.

Cookies. A cookie is information a website places on your computer’s hard drive so that the website is able to remember your preferences and/or which pages you visited on the website and make your visit more efficient and enjoyable. CAER SIDI may use cookies to determine the number of unique players of the Game over a given period, or to remember user account details, etc. so that the need for multiple log-ins is eliminated. It may combine information collected through cookies to any Personal Data submitted online when using the Games to help personalize a user’s access to and playing of the Game. Cookies may be blocked on your computer by indicating this in the preferences or options menus in your browser.

Logfiles. Log files are files that log actions that have occurred on a website. CAER SIDI may collect data in the form of log files and may use such log files to gather statistics about End Users user habits and to assess overall Games activity, including how many "hits" a particular web page is getting and other navigational data. These entries are generated anonymously, and enable CAER SIDI to track interest in specific promotions, troubleshoot technical concerns, and provide End Users with content that may be of interest to them. Log files are used internally only, and are not associated with any particular user, computer, or browser.

Web beacons. The Platform may use a variety of technical methods for tracking purposes, including “Web beacons” etc. Web beacons are small pieces of data that are embedded in images on the pages of the Platform. We may also use these technical methods to analyze the traffic patterns in the Games such as the frequency with which End Users accesses various parts of the Games etc. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML emails that we send our End Users to determine whether our End Users have opened those emails or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is personally identifiable.

4. Use of information – Purpose and legal basis

CAER SIDI will use information about you for the following purposes in accordance with applicable laws:

Age identification

To identify your age for data protection purposes, for example to determine the legal requirements for processing of Personal Data. We request that anyone under the age of 16 not send any Personal Data about themselves over the Internet unless sent under the supervision of their parent or guardian. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 16 has accessed and/or played the Games and provided personally identifiable information to us unless sent under the supervision of their parent or guardian, please contact us at support@caersidi.net or the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information. This in compliance with Article 6(1)(c) of the GDPR.

Information is provided by you or collected in or in relation to the Platform and/or collected from other sources in order to:

  • send souvenirs, keys and other physical items in accordance with your orders;
  • provide, operate, improve and maintain the Platform, Games experience and services, your account(s);
  • personalize the Platform, content, loyalty programs and related services to you;
  • send technical notices, updates, security alerts;
  • for support and troubleshooting reasons;
  • send support and administrative messages;
  • provide news and information about the Games, our Platform and products;
  • monitor the end users playing of the Games and activities in the Games;
  • facilitate sharing on social networks;
  • provide adults with advertising in accordance with given consent and/or permissible laws;
  • provide children reasonable contextual advertisements in the Games accordance with permissible laws;
  • identify, fix, and troubleshoot bugs and service errors, provide software updates etc;
  • resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our Privacy Policy and policies;
  • survey end users opinions about the Platform and related matters through surveys or questionnaires;
  • communication reasons related to the Games and related matters;
  • manage the Platform and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties;
  • present offers and/or information relating to the Platform and the games that you might like;
  • make recommendations to you;
  • personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

Processing of this information is necessary for the purpose of performance of a contract to which you are party in order to support the operation of the Platform facilitate the delivery of requested products and services and enable maintenance and update of the Platform under Article 6(1)(b) of the GDPR and purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR ("the balancing-of-interest rule"). Disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

5. Storage of Personal data

With respect to processing of Personal Data CAER SIDI is Data Controller. CAER SIDI shall (i) Not keep the Personal Data for longer than is necessary for the purposes of performing the Privacy Policy unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules; (ii) Store, process and use the Personal Data for the sole purpose of performing the Privacy Policy; and (iii) Ensure that their employees and employees of their affiliates and subcontractors involved in the performance of the Privacy Policy comply with the provisions of this Privacy Policy (iv) Implement all reasonable technical and organizational measures to protect your Personal Data against any accidental or unlawful destruction, accidental loss, unauthorized alteration, communication or access, (v) Where applicable report to you, upon its occurrence, any unauthorized access, disclosure, use, modification or destruction of your Personal Data, (vi) Refrain from exporting or transferring your Personal Data to any Third Country, and from collecting, using or Processing Personal Data within any Third Country, unless prior to the transfer we have ensured that an adequate level of protection of the Personal Data has been implemented in accordance with the terms and conditions stated in section 9 of this Privacy Policy (International Data Transfers). Personal Data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with us has ended.

6. Information we share with third parties

As a general rule we will not share Personal Data that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.

Notwithstanding the forgoing, we may share information about you with certain third parties based on the legal basis in Articles 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR as follows:

  • Third Party Agents and Contractors

    We may share information about you with third party agents and contractors in order to provide the Games to you, for ongoing development, for analytical purposes etc. We will only provide information to such third party agents and contractors for their performances of their specific assignments for us and consistent with this Privacy Policy, and for no other purposes and provided that such third party agents and contractors have ensured an adequate level of protection of the Personal Data in accordance with all Applicable Data Protection Legislation and/or though Privacy Policy with us.

  • Third parties

    When required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity.

  • Courts, law enforcement agencies, legal authorities etc.

    When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of CAER SIDI, the Games, end users etc.

  • Other end users

    In order to provide certain Games features.

  • Advertising networks

    For advertising purposes. We may share your advertising ID with advertising in order to serving behavioral advertisements to you within the Platform if you have given consent in accordance with Article 6(1)(a) of the GDPR.

Where applicable certain third parties’ use of Personal Data will not be covered by this Privacy Policy. In such instances you must review such third parties’ privacy policies.

7. Payment information

In order to access the complete Game, certain premium Games functions, levels, content and features etc. you may be required to pay certain fees. When purchasing such features and functions etc. you may be asked to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 16 or older to make purchases in the Games, however children under sixteen may access to the Platform and play the Games under the supervision of a legal guardian.

Once End Users have successfully entered valid credit card information etc. and completed the order process, a purchasing account will be created and maintained for them. CAER SIDI will use the information provided to process the End User’s order and to send order confirmations via email, as well as to make future purchases easier for the End User. CAER SIDI does not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with its third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate CAER SIDI’ business (e.g. processing orders and payments).

8. Security

CAER SIDI has taken reasonable steps to ensure that the personally identifiable information it collects is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the Personal Data collected from our Platform’s End Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with the Platform, that we store on our systems or that is stored on our service providers' systems.

Please note that CAER SIDI may provide other games that are operated and hosted by third parties who may have their own information collection practices. Those other games are governed by their own privacy policies, which may be substantially different from CAER SIDI’ policies.

Any improper collection or misuse of User Content or information provided on the Platform is a violation of the Terms of Use and should be reported to CAER SIDI at support@caersidi.net.

9. International Data Transfers

We may transfer and share your information to third parties (including the Games providers) which may be located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) wh