PRIVACY POLICY

Games is at the core of everything we do

Last Updated: April 8th, 2022

We at Ragnarok Studios AS, a Norwegian corporation with registered offices at Lilletorget 1, 0184 Oslo, Norway (“Ragnarok Studios”) respect your privacy and therefore provide you with this Privacy Policy to inform you about what data we collect and how it is used.
Regarding Personal Data collected and processed under this Privacy Policy, Ragnarok Studios is the controller. The purpose of this Privacy Policy is to explain how we collect, store, use, transfer or disclose your Personal Data. Personal Data means any information that can identify you, directly or indirectly, such as for example your name, location data or online identifiers.

This Privacy Policy applies to the game “Galaxy Resistance Pinball TD”, which we at Ragnarok Studios provide you as the user with as well as to any related services such as specific websites or other services (the games, websites and services herein after referred to as “Properties”). We may display advertisements from other companies and other content that links to websites provided by other companies in the Properties. We at Ragnarok Studios cannot control or be held liable for these third parties’ privacy practices and content. If you click on any link or advertisement provided by another company, please understand that you are then leaving the Properties and any Personal Data you provide will not be covered by this Policy.

Ragnarok Studios reserves the right to change this Privacy Policy at any time by posting an updated version online at . Therefore, please review the Privacy Policy frequently to ensure you are aware of any changes. If we make a substantial change to the Privacy Policy, we will provide you with a notice through the Properties or by email. This Privacy Policy was last updated on .

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
The EU’s General Data Protection Regulation (“GDPR”), gives you certain rights to your Personal Data. These rights can be found (primarily) in chapter 3 of the GDPR and include:

• Right of Access – You have the right to request information concerning if we process your Personal Data and if we do, you have the right to know what kind of Personal Data;
• Right of Rectification – You have the right to request that we correct and rectifiy any inaccurate or incomplete Personal Data concerning you;
• Right to Erasure – You have the right to request that we delete your Personal Data. Note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights and comply with technical and legal requirements and constraints related to the security and operation of our Properties;
• Right to Restriction of Processing – You have the right to request that we temporarily or permanently cease processing of some or all of your Personal Data;
• Right to Data Portability – You have the right to receive a copy of your Personal Data for the purpose of transferring them to another service provider;
• Right to not be the subject of Automated Decision Making -- You have the right not to be subject to a decision based solely on automated processing. Including profiling, which produces legal effects on you or otherwise significantly affect you;
• Right to Withdraw Consent – You may at any time withdraw your consent to the processing of any Personal Data based on your consent, without it affecting the lawfulness of any processing done before you withdrew your consent;
• Right to Object – You have the right to object to our processing of your Personal Data for a certain purpose or to object to your Personal Data being used for direct marketing; and
• Right to lodge a complaint with a supervisory authority – If you believe that Ragnarok Studios has infringed your rights or otherwise infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular an authority established in your Member State. Accordingly, we offer transparency and access controls to help users take advantage of those rights, as limited and expected under applicable law:
• Privacy Settings accessed via your account page – allows you to exercise choices about the processing of certain Personal Data.
• Notifications settings accessed via your account page – these settings allow you to choose which marketing communications you receive from us. If you have any questions about your privacy, your rights, or how to exercise them, please contact us using the information provided to you in the “HOW TO CONTACT US” section of this Privacy Policy.

THE DATA WE COLLECT AND USE
Below, we have set out which categories of data we collect, a description of that data, the legal basis we are using for collecting that data, and the purpose of collecting the data. If you have objections or further questions regarding e.g. a purpose for a particular processing or would like a more granular description of the data collected, please contact us in accordance with the “contact us” section. The Personal Data we collect from you Categories of Personal Data (ex. in parenthesis) Description Legal Basis Purpose Identity Data (Player ID, display/user name) Data which is used to directly identify you - usernames, titles, avatars. Necessary for the performance of a contract (Art. 6(1)(b)) The Data is necessary for Ragnarok Studis to be able to provide the service. Contact Data (email address, postal address) Data stored for us to be able to contact you. Consent (Art. 6(1)(a)) In certain circumstances you may provide us with contact information, such as when you wish to contact us via our contact form – please note that we save the contact information you provide in such circumstances, to be able to reply to you. You may also choose to participate in so-called “give-aways”, in which you may receive physical items. To receive such items, we will request your postal address, which you are free to not disclose, but will then not be able to receive the item in question. Location Data (city, language, country) Data regarding location of the user. Legitimate interest (Art. 6(1)(f)) We use location data to keep track of which servers globally are being strained, and using that data to improve your experience by addressing e.g. latency/ping issues. All Location Data is non-specific, and thus cannot locate you individually, other than to give generalized and broad indications (such as a municipality). Technical Data (operating system, hardware information) Data regarding technical information of the device used. Legitimate interest (Art. 6(1)(f)) This data is collected in connection with crash reports, meaning it is used to assess how and why there was a malfunction in your interaction with the Properties, a purpose we consider to be a legitimate interest.

Age data Data used to identify your age, birthday or similar information. Consent (Art. 6(1)(a); Legitimate interest (Art. 6(1)(f)) In specific situations, such as you applying for a job with us, we will ask you to provide us with information about your age. Providing such information is optional at such time.

Outside of this, we collect data on age ranges, which is broad and generalized enough that we consider it anonymized, and as such does not qualify as Personal Data under the GDPR.

Please see our Terms of Use for information on our rules regarding age limitations on access to the game. We may ask that you provide us with generalized age data to confirm that you are of proper age to access our services, and to ensure that we comply with regulatory demands – ensuring this is within our legitimate interests. Aggregated, anonymized Data Data which has been collected and subsequently anonymized for use in aggregated data sets. Not applicable. Anonymized Data is not subject to GDPR regulations and as such, it may be freely used. Nevertheless, we wish to inform you that we use anonymized data to better understand customer behaviour and how to improve the Properties.

SHARING YOUR PERSONAL DATA
For some of the processing of your Personal Data, we use Firebase (www.firebase.google.com). The data which Firebase processes on our behalf is either included in the list above, or does not fall within the definition of Personal Data. Firebase may use the data which they collect for their own purposes, in which case Firebase are the controllers for that Personal Data and their use of it – please see the Firebase Privacy Policy for more information on this subject. The Personal Data which they process for our purposes and means are, as previously stated, included in the list above. Outside of this, we do not share your Personal Data.

TRANSFERS TO COUNTRIES OUTSIDE THE EU AND EEA
We transfer and share your information to third parties (including service providers operating on our behalf) which are located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. When your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur if we (or an applicable processor) have implemented what we believe to be appropriate safeguards in accordance with the GDPR, such as EU Commission approved standard contractual clauses, which are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals. We do not transfer data outside the EU/EEA unless we judge that your Personal Data enjoys equivalent protection as if in the EU/EEA.

KEEPING YOUR DATA SAFE
We implement the appropriate technical and organizational measures to ensure that your Personal Data is collected, processed and stored as securely as possible. However, there is no such thing as perfect security and complete online or offline security can never be guaranteed, so you should always be careful when sharing your information online. We have implemented various policies such as encryption, access and retention policies to guard against unauthorized access and unnecessary retention of Personal Data.

DATA RETENTION AND DELETION
We will not retain or keep any Personal Data for longer periods than what is necessary for the purposes outlined in this Privacy Policy. We will delete your Personal Data which we process for the performance of a contract or on the basis of consent, if you terminate your contract with us, withdraw your consent or where you request us to delete your Personal Data in accordance with this Privacy Policy. However, we may still retain information where we have a legitimate interest to use your Personal Data. For example, to resolve disputes, enforce our user agreements such as our Terms of Use, or to comply with legal requirements.

CHILDREN
The Properties are not directed to children under the age of 13. We do not knowingly collect Personal Data from children under 13 years old in the Properties or in connection therewith. If you are under 13 years, please do not use or access the Properties. 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 13 has accessed and/or used the Properties and provided Personal Data to us, please contact us through the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information. If we learn that we have collected and processed Personal Data of a child under the age of 13 years, we will take reasonable steps to ensure the erasure of the Personal Data from our systems. This may require us to delete the child’s account to the Properties.

HOW TO CONTACT US
If you have any questions, complaints or comments regarding how we process your Personal Data or our Privacy Policy, please contact us at:

Email: contact @ ragnarokstudios . com