··· Privacy Policy – Game ···

Welcome to Triassic Games! The following privacy policy provides a simple overview of what happens to your personal data when you play Sea Power: Naval Combat in the Missile Age (our “Game”) and services, and how it is used. This policy is intended to inform the users of our Game about the nature, scope, and purpose of the collection and use of personal data by us in accordance with Germany’s Federal Data Protection Act (“BDSG”) and the General Data Protection Regulation (“GDPR”).

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which any personal data is, or is likely to be, processed. In this sense, Triassic Games, KrautApps GmbH, Pfarrweg 3, 83549 Eiselfing, Germany (“Triassic Games”, “we”, “us”, “our”) is the data controller. If you have any questions about data protection at Triassic Games in general, you can reach us using info@triassicgames.com.

WHAT IS PERSONAL DATA?

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR DATA?

The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:

Consent: This is where we have asked you to provide explicit permission to process your data for a particular purpose.

Contract: This is where we process your information to fulfill a contractual arrangement we have made with you.

Legitimate Interests: This is where we rely on our interests as a reason for processing; generally, this is to provide you with the best services in the most secure and appropriate way. Of course, before relying on any of those legitimate interests, we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

Legal Obligation: This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We may collect and process the following Personal Data about you:

a) Personal Data that you give us:

This is information about you that you give to us. It may include, for example, your name, email address, and phone number when you contact us. The legal basis is the initiation of a contract with you and your consent.

b) Information collected through Steam

Our Game is offered on Steam by Valve Corporation “Steam” (P.O. Box 1688 Bellevue, WA 98009). Steam  on our behalf, collects certain information from your Steam account as permitted by the terms of the Steam platform and your privacy settings on Steam. We have no influence or control over how Valve Corporation processes your Personal Data. You can find more information about data processing in Steam`s Privacy Policy.

b) Information collected when playing Sea Power: Naval Combat in the Missile Age

When designing our game, we have made sure that no Personal Data is processed by us. However, the game requires certain technical information to be stored locally on your device. This includes save games and certain system information (operating system, processor, Memory (RAM), and other hardware, and software, including drivers) and we have no influence over your savegames and system information. In terms of syncronizing save games and other information required by Steam please refer to Steam`s Privacy Policy.

c) Information collected through crash analytics

We use Sentry.io a cloud-based crash analytics service of Functional Software (45 Fremont Street, 8th Floor, San Francisco, CA 94105) that monitors the stability of our Game. Performance eros and crashes errors are reported to us via Sentry.io and can be analysed. By integrating Sentry.io, Functional Software may collect and process information (including personal data). It cannot be excluded that Functional Software also transfers the information to a server in a third country. We cannot influence which data Sentry.io collects and processes. In addition, in the event of a crash, certain crash dumps and log entries are saved locally on your device. You can find more information about data processing via Sentry in Functional Software`s Privacy Policy.

d) Information collected through Support tickets and requests

If you create a support ticket, we will request Personal Data and, where applicable, non-Personal Data in accordance with your request; this may include your name, email address, and other support-related data that you voluntarily provide. If you submit a support ticket, we process the data for the purpose of processing and handling your ticket.

Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce privacy safeguards strictly. The legal basis of the data processing is our obligation to fulfill the contract and/or our legitimate interest in processing your support ticket.

e) Information collected when you join our Discord

We process the Personal Data that arises when you use our community services. In particular, this requires you to join our server and community on Discord. If you contact or connect with us via Discord, we and Discord are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent, or, in some cases, the initiation of a membership, if any.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

STORAGE AND RETENTION

Your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

WHEN DO WE DISCLOSE YOUR PERSONAL DATA?

We may share your information with organizations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support our game and our services. If you wish to learn more about how the relevant provider processes your personal data, please follow the links embedded in the above-mentioned provider’s name.

Typically and unless otherwise stated in this policy, data may be shared on the basis of our contractual and pre-contractual obligations. Equally, if you have consented to it, or where we have a legal obligation to do so or on the basis of our legitimate interests (e.g., when using agents, hosting providers, tax, business and legal advisor’s, accounting, and similar services that allow us to perform our contractual obligations, administrative tasks, and duties efficiently and effectively). If we commission third parties to process data on the basis of a so-called “processing agreement”.

We may also disclose information in other circumstances, such as when you agree to it or if the law, a court order, a legal obligation, or a regulatory authority asks us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our rights, property, or personal safety of our staff, the game and its users.

HOW WE SECURE YOUR PERSONAL DATA

In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorized persons, we use appropriate technical and organizational security measures. We have also implemented numerous security measures, for example, encryption or need-to-know access, to ensure the most complete protection of Personal Data processed by us.

DATA BREACHES AND NOTIFICATION

Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

YOUR RIGHTS AND PRIVILEGES

a) Privacy rights

    You can exercise the following rights:

    • The right to access;
    • The right to rectification;
    • The right to erasure;
    • The right to restrict processing;
    • The right to object to processing;
    • The right to data portability;

    b) Updating your information and withdrawing your consent

    If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

    c) Access Request

    In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

    d) Complaint to a supervisory authority

    The supervisory authority on federal level is the Federal Commissioner for Data Protection and Freedom of Information (BfDI) (www.bfdi.bund.de) is the Federal Commissioner for Data Protection. The Bavarian Data Protection Commissioner (BDPC) in Munich is the supervisory authority responsible for Bavaria (www.datenschutz-bayern.de). However, we would appreciate the opportunity to address your concerns before you contact the BfDI or the BDPC.

    e) What we do not do

    • We do not request Personal Data from minors and children;
    • We do not process special category data without obtaining prior specific consent; and
    • We do not use automated decision-making, including profiling.

    HELP AND COMPLAINTS

    If you have any questions about this policy or the information we hold about you, please contact us by email using info@triassicgames.com.

    CHANGES

    The first version of this policy was issued on Friday, 11th of October, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.