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[UPD] New version of Privacy Policy comes into force from 28th of January

Discussion in 'Archive' started by Pazak, Jan 22, 2014.

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  1. Pazak

    Pazak Innova Group

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    Dear users!

    We're implementing a new version of Privacy Policy starting January, 28th. So make sure to carefully read it (the changed parts are under green titles).

    Privacy Policy

    Innova takes care about the security of your personal data. This document (referred as “Privacy Policy†or “Policyâ€) contains information about User's data collected by Innova and terms of data processing when using services of Innova. This policy includes all annexes to it, which are integral parts of it.
    Without acceptance of this privacy policy you may not use our services. By accepting this policy you make the explicit and specific consent to the processing of your personal data in accordance with the purposes and in the manner described herein.
    This policy applies to all official websites of Innova, where it is placed (published) and through which you get access to our services, as follows:

    • eu.4game.com
    • lineage2.eu

    This policy is based on the principles set forth in the directive of October 24, 1995 directive EU 95/46/EC and the modified Luxembourg Law of 2002 on protection of individuals in relation to the processing of personal data (hereinafter the “Law on Personal Dataâ€).

    The purpose of processing of your personal data is specified in this policy. We will notify you on any changes in advance and ensure of your consent.

    Innova does not transfer your data to anyone, except for those specified in this policy or as provided by the law on personal data, and this may be related to the provision of our services and performance of contracts you have concluded with Innova. If such transfer to third parties is related to any other purpose we will ask for your explicit consent to such transfer.

    Innova does not sell your personal information and does not receive benefits from any treatment of your data. Innova does not use your data for advertising or promotion of products and services of third parties, other than those listed here.

    Innova does not collect data in relation to Users' racial and ethnical origin, their political, religious or philosophical beliefs, trade union membership, genetic, health or sex life. You should be aware that in case you at your own discretion post (publish) your personal data on forums or use them as your login or as character's names (disclose), your data become available and known to the public and you become responsible for the consequences of such disclosure.

    Innova does not enter into a contract or collect data of persons under the age of 18. Persons above 13 years but below of their legal age of full legal capacity in their country of residence may enter into a contract with Innova only through consent of their legal representatives (parents, adoptive parents or guardians). Such legal representatives also agree to the processing of user's personal data. At any time Innova may contact with the User and request contact details of legal representatives and/or their consent mentioned above.

    Where applicable, all User's rights and obligations to this policy are exercised exclusively through their legal representatives.

    Personal information provided by the User for purposes of performance of the agreement

    Innova collects and processes your personal data for the purposes of the registration (creation) and operation of a 4game account. For example, but not limited to: Accessing to the 4game account, formation and performance of the agreement, game services and game access, processing of support tickets, payments acceptance etc.

    For these purposes Innova requires and collects the following “compulsory dataâ€:

    1) Obligatory data, such as:

    • E-mail address
    • User's ID in social network that is used for registration at 4game
    • Place of user's residence


    2) In order to perform agreements in respect to the game service, Innova may collect “additional data†such as:

    • Cell phone number
    • Full name
    • Date of Birth
    • Sex
    • Partial number of User's ID document

    Providing this additional data is not always necessary, but might become obligatory for the relevant game. We will inform you about it in the appropriate agreement regarding the game.

    These additional data are also collected for the purpose of protection of your account from hacking and hacker attacks. You may also freely provide such information to Innova without our request.

    Innova also may collect non-personal information and store it separately from the personal data as described below in the policy. Such non-personal information can be connected to personal data in case mentioned in this policy.

    Compulsory data provided by users are stored for the whole validity period of relevant agreements with Innova, but in any case for accounting or tax records such data are kept for the period no longer than 5 years after the termination of the User agreement, if there would be no legitimate reason to keep it longer.

    Compulsory data is necessary for the provision of Innova's services. Request of deletion of such data will result in your inability of using Innova's services.

    Furthermore, compulsory data may be collected in the following cases:

    • While contacting Innova via e-mail, fax, phone or mailing address of Innova;
    • While contacting the Support Team;

    Innova keeps correspondence with the User (Support calls (tickets)), notifications sent to the User's e-mail and received from Users, which can be used to analyze the improvements made in services, answers to Users' questions, while restoring access to the User's account, in case of loss of payment, etc.

    While restoring access to your account (for example, in case of fraudulent access and/or hacking attempts), in case of loss of payment, suspected fraud, Innova may request personal information from you in paper form or in the Support program. providing this information by e-mail is not desirable, because it cannot guarantee the security of the data, and left to your discretion. This information is stored for 1 year after the termination of the User agreement if there would be no legitimate reason to keep it longer.

    Payment data collection for purposes of using fee-based services

    When the User tops up his or her 4game account via payment systems (payment agents), specified by 4game, payment data is exchanged between Innova and the payment system that includes:

    • User ID in the billing of Innova;
    • User ID in the payment system
    • Payment (transaction/order) ID
    • Date and time of payment (transaction/order)
    • Amount of payment (transaction/order)
    • Currency of payment (transaction/order)
    • Signature of authenticity of the request (payment)

    For example, when you top up your 4game account via the payment system PayPal, the following information is additionally processed:

    • E-mail of the payer (User),
    • Payer (User) ID
    • Status of the payer (User) confirmed or not)
    • Name of the payer (User)
    • Address of the payer (User).

    When using credit cards the following information may be additionally processed:

    • Name of the cardholder;
    • Masked card number — 12 symbols and last 4 digits;
    • Country code (if applicable);
    • Address (if applicable).

    Payment data is stored for 5 years as required by the financial and tax legislation.

    Collection of data for participation in promotion (marketing or advertising event)

    Innova may use your data, including e-mail and/or phone, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about services of Innova and its affiliates. If you do not wish to receive such information, you can unsubscribe from such e-mails following the instructions as described in the corresponding messages or via 4game account interface.

    Collection of data for service notification

    Innova may also use your e-mail and/or phone information for sending service notifications, for example, in case of password restoring, reply to your request or other messages directly related to controlling access to services of Innova. You can disable this feature at any time, but you will be unable to use such features, for example, you will not be notified if there was a login to your account.

    Collection of non-personal data for improvement and development purposes

    In order to provide quality services and to justify your expectations of the services, Innova collects anonymous data:

    • Name and version of the Operating System,
    • The size of Ram
    • The size of available disk space,
    • Parameters of the network channel and internet connection such as network bandwidth and delay from the User's computer to servers of Innova, trace route information between your PC and servers of Innova, etc. The company processes such data also for evaluation in development plans, performance of updates and bug-fixing.

    This information is stored for 1 year and helps to prevent or resolve technical issues at the beginning or during the use of services of Innova.

    IP (Internet Protocol) address

    When you visit websites and or use services of Innova, we may gather and store the information about your IP address to determine your approximate geographic location, which allows us to provide you with information and services available or intended for the territory where you are.

    Also, information about the IP address is used to prevent illegal use of Innova's services if there is reasonable suspicion, in order to ensure the security of Innova's servers (i.e. blocking of concurrent IP addresses). The data on the IP address is stored for 1 year.

    Collection of data for organization of game process

    Innova collects data on the game process, the so-called log files (information on the actions made by the character in the game generated by the software, fixed in symbolic non-personal form), as well as the content of in-game chats (correspondence). These data may be used by Innova for decisions to ban a game account or User's character, according to the rules of the relevant game.

    Such data are not personal data and stored for 1 year.

    If game account or character was banned based on logs or chat correspondence, such data are stored for 3 years after the violation if there would be no legitimate reason to keep it longer.

    In case with dispute with the User, log files, chats are stored during the period of the dispute.

    In the event of litigation between Innova and the User or in case Innova has request from the authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.

    Security measures

    Any information sent to us is encrypted (scrambled) using Secure Socket Layer (SSL) technology. This is industry standard encryption technology that protects your data whilst being sent over the internet from being intercepted and misused by third parties.

    Innova has put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security, and correctly use the information collected.

    Data storage

    Innova stores data and information during the time periods specified in this policy or until receiving your request for removal of personal data, if there is no legitimate reason to keep them longer.

    Personal data cannot be deleted or anonymized when it is necessary to comply with legal requirements. If you wish to change and/or remove your personal data then you may lose the ability to use the services of Innova from the date when your request is completed. When your data is incorrect or inaccurate you may either amend it on your own or ask Innova's specialists to do this.

    Financial information cannot be changed and/or removed at your request unless you provide Innova with the documentary approval of necessity making such changes.

    Innova doesn't delete the data if any violation or abuse has been occurred from Users side or Innova has been summoned not delete the data by a governmental authority request or a court order. If a User requests the removal of all his personal data, while a prior request(s) from that User is still being processed, such data can be deleted only when the User has recalled/cancelled all previous requests.

    Innova stores the log files within the periods specified in section “collection of data for organization of game processâ€.

    The data are stored separately. Your data may be combined with other data collected by Innova in exceptional cases, for example, in case of a violation by Users of the agreement with Innova, the rules of the game, the availability of a dispute between Innova and the User, conduct of financial control and accounting, etc.

    The user can modify and/or delete the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having the access to his private account. All changes are logged.

    Data transfer to third countries

    Innova subject to necessity of rendering game services at a high level and for avoidance of service's standstill may transfer personal data specified in this policy to its servers permanently located in Russia, Brazil and USA. Your personal data transferred to such servers is collected and used only for backup purposes and for facilitation of User's connection to our servers.

    All our servers in Russia, Brazil and USA are located in designated data centers, protected from access and interfering of any third party except for our authorized employees. Data transfer process is encrypted and protected from any unauthorized access as well.

    Innova does not give your personal data to any public authorities unless Innova is obliged to do it by corresponding court or any other legitimate request.

    Please note that Innova transfers your personal data entirely to its own servers. Innova ensures protection of such data in Russian, Brazil and USA at the same level as it is in Europe.

    By accepting this privacy policy you provide Innova with explicit consent of your personal data transfer to our servers located in the third countries (Russia, Brazil and
    USA) in the manner set forth above.

    E-mail collection for the CBT/OBT

    Before Innova publishes new game title it usually runs close and open beta testing (CBT and OBT). During the CBT/OBT Users are offered an opportunity to participate in testing which is run in order to pinpoint errors and problems in games functioning, game mechanics and localization flaws, and test the interface and other elements of the game. During and after the testing all participants have a chance to inform Innova about the flaws and bugs and other information concerning the testing. This is common practice in online gaming industry, which helps us make game process more comfortable for Users.

    For the purposes of running the CBT/OBT Innova may obtain e-mail addresses of Users who are interested in participating in testing (hereinafter – “participantsâ€). All e-mail addresses are given by Users voluntarily.

    Participants may in particular cases by the decision of Innova obtain access to the CBT/OBT by registry on 4game and creation of his/her individual account.

    The participants receive notifications via e-mail of the start of the CBT/OBT and related information. In order to take part in the CBT/OBT it is required to accept the Rules (Terms and Condition) of the testing published by Innova. These rules are posted on 4game.com in advance to the testing. The rules include the necessary instructions for becoming a participant.

    Innova does not give e-mail addresses of the participants to any third party for mailing/advertising/data forwarding that has no connection to the game; however e-mail addresses of the participants may become available to the right holder companies and Innova's affiliates that may be located in- or outside the EU region. However, in any case, collected e-mail addresses are used for the purposes of the CBT/OBT only.

    When participant decides to terminate his/her participation in the CBT/OBT and/or stop receiving notifications from Innova (and its affiliates) or right holder company concerning the CBT/OBT, such participant should inform Innova about his/her decision via e-mail: innova@inn.eu.

    A participant may stop receiving (cancel) notifications from Innova (and its affiliates) at any time without termination of his/her participation in the CBT/OBT by changing notifications settings in its individual account.

    E-mail address of such participant will be deleted from the mailing list within reasonable time.

    Auto delivery of updates

    Since rendering game services requires periodic updates of software, Innova provides you with such updates from time to time. Usage of current version of software is strongly recommended. 4game application will periodically check with Innova for available updates. You agree that updates will be automatically downloaded and installed onto your computer. You also agree with all changes in software provided by corresponding update.

    Disclosure of information

    You are required to provide only accurate information and data belonging to you.

    You have the opportunity at any time:

    • To contact Innova on the issues relating to the processing of your personal data, issues related to this policy;
    • To obtain information about what your personal data and for what purpose is processed by Innova, and whether they were disclosed (within the period of preceding two years).

    The requested information is provided to you in electronic form. Provision of it on another data medium is possible at the sole discretion of Innova or in cases when such obligation is required by the applicable law.

    This information is provided upon your request sent as specified in the contact section. You will receive a reply within a reasonable time period.

    The data collected will be treated confidentially and used only by Innova or Innova's affiliate (Innova Systems LLC.). Your data are stored on Innova's servers in tier 4 data center in Luxembourg. If Innova makes a decision to store the data outside the EU we will strictly follow the legal requirements of the applicable law including getting necessary approvals and authorizations if necessary. Depersonalized data can be transmitted to the right holder (NCSoft, The Republic of Korea).

    Data with User's e-mail can be processed by the Innova's Partners (Innova Systems LLC) which shall treat the personal data strictly in accordance with this document and to use it only for services related purposes or transactions on behalf of Innova.

    This policy and the collected data shall be binding upon and shall inure to the benefit of Innova's successors and assigns (for example, in case of merger/incorporation, transfer of rights to provide service under the license, etc.).

    Without your consent the data may be disclosed in cases required by legislation, for example, at the request of the competent authorities.

    We particularly draw your attention to the fact that Innova will never ask you to provide your personal information in the way it becomes public, such as forums and chat rooms, which may accompany the provision of Innova's services, or in the name of the game character or in the selection of username.

    Once you disclose your personal data, including posting them on forums using your personal data as name of game character, you should be aware that these data are publicly available and can be used by third parties, and Innova ceases to be responsible for the safety of such data.


    User is always entitled to request information about any of his/her data that Innova has stored, as well as request for correction or deleting of any of his/her personal data.
    User shall contact the following and also provide user name, e-mail address and other necessary information regarding subject of his/her request:

    Innova Co. S.à r.l.
    26-28, Rue Edward Steichen
    l-2540, Luxembourg
    e-mail: innova@inn.eu

    If this document is modified in any way, Innova will place an updated version of it on the following pages: eu.4game.com.

    Annex no 1 to the privacy policy

    4game cookie policy (hereinafter referred to as the cookie policy)

    This cookies policy is our policy related to cookies used on 4game.com and related domains and subdomains our web-sites. This cookie policy is annex no 1 to our privacy policy and by accepting privacy policy, you agree with the terms and conditions of this cookie policy without any exceptions.

    Below we explain what cookies are, why we use it on 4game.com and related domains and subdomains (“our websitesâ€), what types of cookies exist and how you could disable the cookies that we use.

    About cookies

    Cookies are text files, usually very small files, or pieces of information, that may be stored on your computer, phone or tablet computer when you visit our websites. Technically, cookies are files sent by our server to your web browser and stored by your web browser. Then the information may be sent back to our websites each time your browser requests a page from our server or may be transmitted to third party website if it is a third party cookie (please, see below). This enables us and our partners to identify and track your web browser.

    There are two main types of cookies: Session cookies and persistent cookies. Session cookies are deleted from your computer when you close your web browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date. We use both.

    Why we use cookies

    Our websites uses cookies. Our purpose of exploiting cookies is to make our websites easy-to-use, to obtain clear understanding to your preferences and needs. We may also implement cookies to understand your track to our websites (for example, when you open our web site through hyperlinks on our partner's web sites and so on). Thus, information may be transmitted from our websites to your web browser and conversely, to another party of our behalf or to another party according to its privacy / cookie policy (in respect of third party cookies). Another reason why we need cookies is statistic.

    Our cookies

    The following cookies may be used on our websites (the list is not full, please see below):

    {tr}Cookie NameType of CookieDescription{tr}l4g.maintenance.inprogresspersistent (30 sec.)Game server status inquiry{tr}l4g.maintenance.lastupdatetimepersistent (60 sec.)Game server status inquiry{tr}l4g.maintenance.statusespersistent (60 sec.)Game server status inquiry{tr}auidpersistent (1 year)User's ID{tr}captchaidsessioncaptcha{tr}inn-userpersistent (15 days) or session according to User's actions4game authorization key{tr}inn-user-ppersistent (15 days or 4 hours)4game authorization key{tr}inn-langpersistent (120 days)Language ID{tr}pidpersistent (90 days)4game partner's ID{tr}pid-prioritypersistent (90 days)4game partner's ID{tr}pid-query-paramspersistent (90 days)inquiry get-settings{tr}regpersistent (90 days)User's ID(new User){tr}inst_{service_id}sessiongame status{tr}ext-http-referrerpersistent (90 days)external source of transit to 4game{tr}isbrowserunsupported6persistent (365 days)web browser status{tr}pt_storagepersistent (3 month)history of latest payment{tr}ctokensessiontoken for post-inquiry{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}
    Third party cookies

    Simultaneously with our cookies on our servers may we may use third party cookies. We work with various reputable companies and have a number of partners that may set cookies in your web browser on our behalf when you use and visit our websites.

    The following third party cookies may be used on our websites:

    {tr}Cookie NameType of CookieThird Party{tr}__utmapersistent (2 years)google{tr}__utmbpersistent (30 min.)google{tr}__utmcsessiongoogle{tr}__utmzpersistent (1 year)google{tr}__ascpersistent (30 min)google{tr}__aucpersistent (1 day)google{tr}_ym_visorcpersistent (30 min.)yandex{tr}fbm_212042692151625persistent (1 year)facebook{tr}fbsr_212042692151625persistent (2 hours)facebook{tr}vk_app_2337221persistent (2 hours)vk{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}{/tr}
    Simultaneously with third party cookies in our websites may be used third party local storage technology. This technology is similar to cookies but with an enhanced capacity. We may use local storage of our following partners: YouTube, Facebook, Google+ and Twitter.

    It should be noticed, that such lists (our cookies and third party cookies) are relevant as from the date the cookie policy comes into force. We may update these lists from time to time. This is because cookies are flexible things and they may be changed occasionally. However, all cookies have the same purpose described above and an appearance of new cookie generally will not have significant impact on you. Please, be aware of it. You may look through current cookies used on our websites in this cookie policy.

    You may receive additional information in respect of third party cookies by visiting relevant third party site (e.g. Facebook.com, Google.com and so on).

    How to refuse (delete) cookies

    The best way to disable cookies is to change your web browser's settings to delete cookies that have already been set and to not accept new cookies.

    We do not know what exact type of web browser you use, but we believe that all or almost all web browser has special section related to cookies in its settings. In case of any trouble you may visit help pages of your web browser. if you access our websites from different computers (different web browsers on one computer) please make sure that all of web browsers have same settings according to your personal preferences.

    We particularly draw your attention to the fact that if you do not like the idea of cookies and intend to refuse it, you probably will not obtain full possibilities we offer on our websites. Game services may work not as good as it pretends to work. moreover, unfortunately it may not work in whole.

    If you have any questions about cookie policy, you may contact us by email or by writing to us at:

    Innova Co. S.à r.l.
    26-28, Rue Edward Steichen, l-2540, Luxembourg
    Effective date: January 28, 2014.
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