Register keeper:
Frozenbyte Oy (Frozenbyte)
Business ID: 1736734-3
Krogiuksentie 17, Helsinki 00340
Person responsible for register issues:
Frozenbyte Privacy Team
[email protected]
Name of register:
Frozenbyte marketing
Purpose of processing personal data (use of register):
This Privacy Policy applies to our mailing lists and our websites, including separate websites for our games.
The register has two purposes. One purpose is to send emails containing news about our current and upcoming games.
The other is to collect anonymized information using analytical services and cookies. We use this data to create statistics, provide better services to our customers as well as analyze and further develop our Services.
The data will be stored indefinitely unless the registered asks otherwise. However, most of the information we store is not personal data, because a person can’t be identified directly or indirectly using this data.
Data content of the register:
We have two distinct mailing lists, one for press and one for users/everyone. You can unsubscribe from the mailing list anytime you want by contacting us, or by clicking the “Unsubscribe” link at the bottom of the emails we have sent you.
Frozenbyte Press Mailing List
A mailing list for press and content creators such as YouTubers or streamers who have signed up by contacting us, or sites that have publicly listed contact information for news/tips from the games industry.
Data content:
- Name
- Website URL
- Location (Country)
- Language
Frozenbyte Mailing List
A mailing list open for anyone who signs up.
Data content:
- Name
We also store information which is not personal data, because a person can’t be identified directly or indirectly using this data. This data is collected when you use our sites and services. Here is a list of anonymized information that we collect:
Analytics data. We use analytical services and other tools (such as Google Analytics) on areas of our Services which enable us to collect your anonymized IP address or other identifier, usage data relating to our Services as well as information on your device properties. Based on this data we may create statistics, provide better services to our customers as well as analyze and further develop our Services.
Ad serving. We and our partners may use ad serving technology to provide advertisements of interest to you within the Services (for example within the Android application). In this connection we and our partners may collect and use information about you, such as your Service session activity, device identifier, MAC address, IMEI, coarse geo-location information and IP address.
You may also see our own advertisements in other services. If you click such advertisements and install our game, we may share a device identifier with the advertiser to verify installs.
Cookies and other identifiers. We and our partners may use cookies and other identifiers (such as clear gifs or pixel tags). With cookies and other identifiers, we and our partners can provide a better user experience.
Cookie information is stored in your browser and performs functions such as recognizing you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.
We recommend enabling all cookies on our sites to give you the best browsing experience possible. You can opt-out at any time by disabling cookies on your browser. If you disable cookies, some parts of our Services may not function properly. You may delete the cookies from your device at any point after using our Services.
Regular sources of information:
Information is given by:
- People and companies who sign up for the mailing list
- People and companies who have given permission to be added to the mailing list
- People who use our site and services
Regular conveyance of data and transfer of data outside the EU or European Economic Area:
We may process your data outside the country where you live in (for example if you are an EU citizen, outside the EU or the European Economic Area). This can happen if, for instance, the service provider of our analytical services is located outside your country. In such cases, we will take steps to ensure that your personal data is processed lawfully and in accordance with this privacy policy.
We transfer information only to countries with guaranteed adequate level of protection as defined by the EU General Data Protection Regulation (GDPR) or to an organization, which adheres to the EU-US Privacy Shield.
We may publish aggregated or de-personalised data based on our users’ information (such as statistics) provided that such information does not identify you.
Refund and payment request
We do not process orders or payments and therefore we do not have any possibilities to process or manage possible refund requests or any other requests or questions relating to your payments or orders. Therefore, if you have any refund requests, we encourage you to directly contact the company that has given you an order receipt and is the company processing your orders and payments. In many cases, it means the company that is providing a market place for their customers (e.g. Apple, Google, Steam).
Principles of register protection:
All data is handled confidentially. All of your data is protected in accordance with generally acceptable industry standards and although no system is 100 % secure, we take reasonable steps to safeguard your data from unauthorized access. We may use partners and contractors to process data for us in accordance with this privacy policy and in such cases we take steps to ensure that your data is kept secure.
Rights of the data subject:
You have the right to request an overview of the personal data we process about you.
You also have the right to request correction of incorrect information if you have identified any errors in the data. You may require the controller to correct the data if the data is considered by you to be misleading, unnecessary, incomplete or outdated for the purpose of the processing.
You have a right to request deletion of personal data, and to restrict or object to our processing of your personal data.
You may also have a right to data portability.
Please note that most of the data we collect is anonymized so in most cases we are not in a position to identify you.
To file a request, please contact [email protected]. All requests must be sufficiently identified, justified, clear and concern the requester themself.
In the request please specify:
– What data you want to erase, rectify or inspect. Please specify what the data is linked to, for example information gathered because of playtesting or mailing list.
– The justification for the erasure or the changes proposed by you
– Your name and contact details (such as your email address or telephone number)
Please note that we do not handle insufficient requests and we cannot erase accounts or data handled by external parties, for example Steam or Discord.
If the request is unfounded or unreasonable, we have the right to refuse the request. Please be aware that we may continue processing your data, if we have a lawful basis for doing so.
Please note that erasure of your data might lead to you not being able to use our Services anymore.
In order to fulfill requests, we may need to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide detailed information about the account to which the request relates to or proof of identity.
We will reply to requests within one month. Please note that we might have to extend the processing period by two months if necessary because of the complexity or number of requests. We will let you know of any delays within one month.
To find out more about data protection and your rights, please check the official site of The Office of the Data Protection Ombudsman.
Last updated: 17th March 2021
