Privacy Policy

Last Updated: 01/11/2024

Enixion SAS (“we,” “us,” or “our”) values your privacy and is committed to protecting the personal information of our users. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of your personal data when you use our website (https://enixion.net) and our mobile games (“our games”). By using our services, you agree to the terms and conditions set forth in this policy.

1. Scope and Consent

This Privacy Policy applies to all users accessing our services globally, including those from the European Economic Area (EEA), the United States, China, Japan, and South Korea. By using our website and mobile games, you explicitly consent to our data practices as described herein. If you do not agree with this policy, please refrain from using our services.

This Privacy Policy has been structured to ensure compliance with various privacy laws, including but not limited to the General Data Protection Regulation (GDPR) of the European Union, the California Consumer Privacy Act (CCPA), the Personal Information Protection Law (PIPL) of China, and other applicable data protection laws.

2. Types of Data Collected

We collect various types of data to enhance user experience, improve functionality, ensure security, and support game analytics. The data collected may include the following categories:

Basic Information Collected Automatically

  • Anonymous Online Identifier: A unique identifier for tracking purposes, used without revealing personal information.
  • App Download Confirmation: Information verifying that you have downloaded our app.
  • Device Information: Details on the type of device used, including model and operating system, to optimize performance across devices.
  • Geographical Region: General location information to tailor content and improve service quality.
  • Time Zone: Your time zone to provide region-specific features and improve in-game experience.

Additional User Data Collected

  • Email Address: Collected if provided for customer support purposes.
  • Game Account Information (UID): A unique identifier specific to each player to track progress and link accounts.
  • Advertising ID: Used to facilitate data collection for targeted advertisements and user insights, as permitted by applicable laws.
  • Device Model and Operating System: Information about device type to support functionality and resolve technical issues.
  • Build Version: Data on the specific app version in use to assist in troubleshooting and providing support.
  • Application Language Settings: Your language preferences within the app to enhance personalization.
  • Nickname: The nickname chosen within the game, which is used to personalize the user experience.

Cookies and Tracking Technologies: Our website may use cookies and similar tracking technologies to enhance the user experience, remember preferences, and perform anonymous statistical analysis. Cookies are also used to deliver personalized content and advertisements across other websites and platforms. For more information, please refer to the cookie section below.

3. Purpose of Data Collection and Legal Basis for Processing

We process your personal data in strict compliance with applicable privacy laws and solely for the following purposes:

  • Performance of Contract: To create and maintain user accounts, enable access to our games, and respond to user inquiries.
  • Legitimate Interests: To enhance user experience, personalize in-game content, conduct analytics, and ensure system security and integrity.
  • Consent: For targeted advertising and direct marketing, where required by law. Consent may be withdrawn at any time by contacting us or adjusting your settings.

In-Game Advertising

In-game advertising is managed through LevelPlay by Unity (ironSource), which delivers targeted advertisements based on user interactions. This may involve the collection and processing of device identifiers, location data, and other data points, as outlined in the privacy policies of these third-party services. Users have the right to control advertising preferences through their device or platform settings.

ironSource uses the following mediation networks for ad delivery, and we encourage our users to review their respective privacy policies:

4. Data Sharing and Disclosure to Third Parties

We do not sell, lease, or disclose personal data to third parties without user consent, except as described below:

Service Providers

We may share your data with trusted service providers who assist in delivering core functionalities of our services:

  • Microsoft Azure: Used exclusively to collect session-related data, which does not include any personally identifiable information (PII). Personal data is managed only by providers who have obtained the user’s explicit consent, such as Unity Player Authentication, Google Play Games or Apple Game Center.
  • Google Analytics and Unity Cloud Analytics: Employed for anonymized tracking of user engagement to improve our services.
  • LevelPlay by Unity (ironSource): Manages in-app advertising and mediation, delivering targeted ads in compliance with user preferences.
  • Payment Processors (Google Play and Apple): Process payments and manage in-app purchases, adhering to industry-standard security protocols.

All third-party service providers are required to comply with applicable data protection laws, and we ensure contractual safeguards to protect user data.

5. Data Storage and Security Measures

User data is stored securely on Unity Cloud and Microsoft Azure servers located within and outside the European Economic Area (EEA). We employ industry-standard security measures, including encryption, access control, and network firewalls, to protect personal data from unauthorized access, alteration, and disclosure.

For payment transactions, data security is managed by Google Play and Apple, which handle all payment processing in compliance with the Payment Card Industry Data Security Standard (PCI-DSS). We do not store payment information on our servers.

6. Retention and Use Period

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Data retention practices include:

  • User Data: Retained for the duration of the user’s active account with Enixion.
  • Transaction Data: Certain information related to in-app purchases is retained to comply with accounting and legal obligations.
  • Deletion Requests: Upon user request for deletion, we will either delete or anonymize non-essential data unless retention is legally mandated.

Data collected specifically for inquiries will be automatically disposed of after one year following the resolution and closure of the inquiry.

7. User Rights (EU/EEA)

If you are located in the EEA, you have specific rights under the General Data Protection Regulation (GDPR), including:

  • Right to Access: You can request information regarding the personal data we hold about you.
  • Right to Rectification: You have the right to request corrections to your data if it is inaccurate or incomplete.
  • Right to Erasure: You may request deletion of your personal data, subject to certain legal restrictions.
  • Right to Restrict Processing: Under specific circumstances, you may request that we limit the processing of your personal data.
  • Right to Data Portability: You can request a copy of your personal data in a structured, machine-readable format.

To exercise these rights, please contact us at [email protected] with proof of identity. We will respond to your request in compliance with GDPR requirements.

8. Additional Rights for Users Outside the EU/EEA

United States (CCPA and Other Applicable Laws)

Residents of California, as well as those in other U.S. states with specific privacy regulations, have rights under applicable state and federal privacy laws. These rights include:

  • Right to Access: You have the right to request a copy of the personal information we hold about you, including information on how we use it and share it with third parties.
  • Right to Deletion: You may request the deletion of personal information that we have collected about you, subject to certain exceptions (e.g., if the information is necessary to complete a transaction, comply with legal obligations, or protect against fraudulent activity).
  • Right to Opt-Out of Sale of Personal Data: Although we do not sell personal data, California residents have the right to opt out of the sale of their personal information. We respect this right and comply with CCPA transparency requirements.

Other federal and state laws may apply to specific data collection, processing, and sharing practices, and we strive to maintain compliance with applicable U.S. privacy regulations.

For any requests or questions related to your privacy rights under U.S. laws, please contact us at privacy@enixion.com.

China (PIPL)

Under the Personal Information Protection Law (PIPL) of China, users in China have the following rights regarding their personal information:

  • Right to Access: You have the right to request information about the personal data we hold about you and how it is being used.
  • Right to Correction: You may request the correction of inaccurate or incomplete personal information.
  • Right to Deletion: You have the right to request the deletion of personal data, especially when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent.
  • Right to Restrict or Object to Processing: Under certain conditions, you can request the restriction or objection to the processing of your personal data.
  • Right to Withdraw Consent: You may withdraw consent at any time for the processing of your data, without affecting the legality of processing based on consent before its withdrawal.

Data transfers outside China are subject to strict regulatory standards, and we ensure compliance by adopting appropriate safeguards such as Standard Contractual Clauses (SCCs) or other mechanisms approved by Chinese authorities.

For requests related to your data rights under PIPL, please contact privacy@enixion.com.

Japan (APPI)

We comply with Japan’s Act on the Protection of Personal Information (APPI), which grants Japanese users the following rights:

  • Right to Access: You have the right to request access to your personal data and obtain details on its use and disclosure.
  • Right to Correction or Deletion: You may request corrections if your personal information is inaccurate, or request deletion when the data is no longer necessary for its original purpose.
  • Right to Limit Processing: Under certain conditions, users may restrict or limit the processing of their personal data.
  • Right to Withdraw Consent: Japanese users may withdraw consent at any time for processing activities that were based on consent, which will apply moving forward without retroactive effect.

Data transfers outside Japan are conducted in compliance with APPI, ensuring that appropriate protections, such as data transfer agreements, are in place.

To exercise your rights under APPI, please contact us at privacy@enixion.com.

South Korea (PIPA)

In accordance with South Korea’s Personal Information Protection Act (PIPA), users in South Korea are entitled to the following rights:

  • Right to Access: Users can request access to their personal information and information about how it is used.
  • Right to Correction and Deletion: You may request corrections to any inaccurate data and deletion of data that is no longer necessary for the purposes for which it was collected.
  • Right to Restrict Processing: In certain cases, you can request the restriction of processing of your personal information.
  • Right to Withdraw Consent: Users have the right to withdraw consent for data processing at any time, which will affect future processing activities but not data processing carried out prior to withdrawal.

All data transfers outside of South Korea are conducted with appropriate safeguards to ensure compliance with PIPA, including data protection agreements with third parties.

For questions or to exercise your rights under PIPA, please reach out to us at privacy@enixion.com.

9. Children’s Privacy

Our games are not intended for users under the age of 13. We do not knowingly collect personal data from children below this age threshold. In compliance with regional regulations, we apply the following standards for users within the European Union, the United States, and certain Asian countries.

European Union (GDPR)

Under the General Data Protection Regulation (GDPR), we are committed to protecting the privacy of minors. According to Article 8 of the GDPR, we do not process personal data from users under 16 without verifiable parental consent, unless the applicable Member State provides for a lower age threshold (but not below 13). If we learn that personal data from a user below the required age has been collected without parental consent, we will take immediate steps to delete this data in compliance with GDPR regulations.

United States (COPPA)

In the United States, we comply with the Children’s Online Privacy Protection Act (COPPA), which restricts the collection of personal data from children under the age of 13. If we discover that we have inadvertently collected personal data from a child under 13, we will delete this information promptly to meet COPPA requirements.

Asia (Local Regulations)

For users in China, Japan, South Korea, and other Asian countries, we follow the specific local regulations regarding data protection for minors. If we collect data from users in these countries, we ensure compliance with the Personal Information Protection Law (PIPL) in China, the Act on the Protection of Personal Information (APPI) in Japan, and the Personal Information Protection Act (PIPA) in South Korea, among others. These laws restrict data collection from minors and may require parental consent for users under 13 or as locally mandated. If we identify any such data collected without appropriate consent, it will be promptly deleted.

10. International Data Transfers

User data may be transferred and stored on servers located outside the EEA. Where we transfer data internationally, we ensure adequate safeguards, such as the Standard Contractual Clauses (SCCs), to comply with EU data protection laws.

For users outside the EU, data transfers are conducted in compliance with the applicable privacy laws of each country or region.

11. Cookies and Tracking Technologies

Our website utilizes cookies to enhance user experience, track session information, and provide relevant advertising. By using our website, you consent to our use of cookies as described herein.

You may manage cookie preferences through your browser settings. For more information on cookies, including how to disable them, please refer to our Cookie Policy.

12. Privacy Policy Updates

We reserve the right to modify this Privacy Policy at any time. Material changes will be posted on this page, with the “Last Updated” date reflecting the most recent modification. Continued use of our services following these changes constitutes your acceptance of the updated policy.

13. Contact Information

For inquiries regarding this Privacy Policy, data practices, or to exercise your rights, please contact:

Email: [email protected]

External Links for Related Policies: