LAST UPDATED 25 MAY 2018
Contents and Scope
Kru Interactive, Inc. ("KRU") respects the privacy rights of our online visitors and players and recognizes the importance of protecting the information that you may choose to share with us. This Policy explains the use of information collected via our website at www.kru.com and affiliated sites owned and/or operated by KRU (collectively, the "Site"), customer service operations and game service.
In general, we collect your Personal Data when you voluntarily provide it to us, such as when you register with our website or place an order for software, products or services. We also collect information when you voluntarily play our MMORPG games, provide feedback or participate in competitions. In addition, the Site may use "cookies" to gather non-personally identifiable information.
We may track broad website usage information as well as aggregated usage of website community features, such as downloads and forums. This is in addition to the Personal Data collected during the registration process, and is not personally identifiable.
We do not collect or store customers' credit card or other financial information. We do not process credit card transactions on our Site, instead using third-party credit card processing services to accept payments from customers. We receive and store the transaction results from the credit card transaction companies. Customers are notified prominently when they leave our Site and are taken to a third-party credit card transaction provider, and have the option not to proceed further. For details on the privacy policies of our payment processors, kindly refer to the privacy disclosures on their websites before you decide whether to engage in a financial transactions on our Site.
The Personal Data that users voluntarily provide to us may be transferred outside of the country in which the user resides. Specifically for residents of the European Union ("EU"), some of your personal data may be stored digitally on servers located outside of the EU, including in "cloud" or other digital storage services, subject to the safeguards described below. If you do not agree to such storage, you may terminate your account at any time and, for EU users, have the right to request access to or deletion of the personally identifiable data we store about you.
We do not utilize web beacons or other technological means of tracking users of our Site and games. We may use server-side log files as part of our operational functions. The data held in log files includes your IP (Internet Protocol) address, browser type, e-mail application, Internet service provider, referring/exit Web pages, computer platform type, date/time stamp, and user activity (e.g., feature usage, user rankings, game statistics). KRU may use server log data to analyze trends and administer the services offered through the Site. IP addresses are not tied to any Personal Data. The software enabling the Site may have associated log and temporary files that are stored on KRU's servers. The foregoing information is collected on an aggregated and anonymous basis. When any game is updated or "patched," our patch routine may check your computer to see that you have the most recent version of game-specific files.
Voluntary Disclosure of Personal Data
You may choose to disclose Personal Data in our online community features, blogs, in-game chats or other public forums, directly to other users while using the Site service. Please be aware that such information is public information and you should not expect privacy or confidentiality under these circumstances. KRU shall not be liable in any way for such disclosure of Personal Data.
Use of Information Collected/GDPR Compliance
We use your Personal Data for operational purposes only. For example, we may use your information to send you administrative communications either about your account with us or about features of our Site, including any changes to this Policy. Whatever the purpose may be, we only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives. We do not profile, target or otherwise deliver advertising or unsolicited content or services to our users by use of their Personal Data. We attempt to limit access to Personal Data about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.
We do not share Personal Data with, or transfer Personal Data to, any third-party companies without explicit notice and consent from you. We only engage in "processing" of your Personal Data as defined under the GDPR (collecting, storing and using such information), after you affirmatively consent to provide it to us, in a manner compatible with EU regulations; we endeavor to keep your information accurate and up to date, and not keep it for longer than necessary. If we decide in the future to transfer any of your Personal Data to third parties, we will do so after notice to you and only and only with "appropriate safeguards" or under another GDPR-approved transfer mechanism, such as pursuant to a Data Protection Agreement which contractually requires that data will be processed only for limited and specified purposes consistent with your consent, that the recipient will provide the same level of protection, and that the recipient will notify Kru if it makes a determination that it can no longer meet those obligations.
In conformance with the GDPR, users in the European Union may have the right to: (i) request access to their Personal Data; (ii) request rectification of their Personal Data; (iii) request deletion of their Personal Data; (iv) request restriction of processing of their Personal Data; (v) request data portability; and/or (vi) object to the processing of their Personal Data (including objection to profiling). Access information includes, among other things, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. If you would like to make such a request, please contact our Data Protection Officer as provided at the conclusion of this Policy.
California Online Privacy Protection Act Compliance
Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your Personal Data to outside parties without your consent. As part of the California regime, users of our Site may make changes to their information at any time by signing into their account on our server.
Compulsory and Law Enforcement Disclosures
We may disclose Personal Data to proper authorities when required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Children's Online Privacy Protection Act Compliance
We are in compliance with the requirements of United States Children's Online Privacy Protection Act (COPPA). We do not collect any information from anyone under 13 years of age. Our Site, games and services are all directed to people who are at least 13 years old or older. If you are under 13, you are not permitted to become a user and should ask your parent or guardian to establish an account in their own name.
Protection of Your Data
We use reasonable technological and physical safeguards to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it.
Hyperlinks and Other Websites
Our Site may contain links to websites operated by others. This Policy only applies to this Site. Privacy policies for these third-party sites and services may be different from our Policy. You access these third party sites and services at your own risk so when you link to other websites, you should read their privacy policies.
Storage, Update and Removal of Your Data
In general, we will only retain your information for the time necessary to realize our legitimate business purposes and to comply with the law. However, we continue to store anonymous or aggregated information, such as website visits, without identifiers, in order to improve our services.
If you wish to review, access, amend or correct your Personal Data, you may do so in your account on our server. If you wish you remove your Personal Data, please contact our Data Protection Officer identified below. We may decline requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, or are extremely impractical. We may also decline requests in part when it is necessary for us to maintain such data to prevent harmful and negative impacts to our games and our user community, such as fraud, hacking or breach of our Terms of Service and Licensing Agreement.
Data Protection Contact
Our Data Protection Officer (DPO) and data protection representatives can be contacted directly here:
To exercise your GDPR rights of access (to request a copy of the information we hold about you), rectification (to correct data we hold about you that is inaccurate or incomplete), or portability (to have the data we hold about you transferred to another organization), please contact our DPO.
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