505GAMES collects your personal information when you register with us for our products, use the 505GAMES websites, videogames, mobile applications, online store or other services (“Services”), including when you buy our products, or otherwise contact us. Generally, personal information is collected when (a) you use a Service, (b) you create an Account, (c) you make a purchase within our Services, (d) you create user generated content, (e) you watch advertisements within our Services, (f) you sign up to a newsletter, (g) you contact 505Games customer service and during technical support sessions, (h) you enter into a contest or sweepstake, (i) you chat with other users of the Services, (j) you wish to participate in a beta or otherwise download a patch or a demo and (k) you share or otherwise contribute to our social media channels and other community websites.
We use this personal information to: provide you the products or Services you have requested; create your user profile; to send you information about our products or Services and your registration; when you agree, to send you marketing information and to respond to your correspondence;
Whatever the activity may be, we will only collect personal information to the extent deemed reasonably necessary to fulfil your requests and our legitimate business objectives
[This version was last updated on 10 May 2018 and historic versions can be obtained by contacting us.
- Full name of legal entity: 505 Games S.P.A.
- Name or title of Privacy Compliance Officer: Dario Treves
- Email address: firstname.lastname@example.org
- Postal address: Via Tortona, 37 20144 Milan (Italy)
- TYPES OF INFORMATION COLLECTEDIn order to better provide you with our numerous services, we collect two types of information about our users: Personally Identifiable Information ( “PII”) and Non-Personally Identifiable Information (“Non-PII”). Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our site.PII means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It refers to information that lets us know the specifics of who you are.
- Information you provide to usWhen you engage in certain activities on the 505Games.com, such as registering for a membership, ordering a product or service, submitting content and/or posting content in discussion forums or other public areas, entering a contest or sweepstakes, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities; however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other PII (“Identity Data”). When ordering products or services on the site, you may be asked to provide a credit card number (“Financial Data”). Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
- Information we collect about youWe gather certain information about you based upon where you visit on our site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and/or your Internet Protocol (“IP”) address (“Technical Data”).A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
- PURPOSE FOR WHICH WE PROCESS PIIWe will only process your PII, in accordance with applicable law, for the following purposes:
- creating and maintaining your Customer account, if you become our registered Customer – Identity Data;
- offering our goods and providing our services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker. This may also include, where legally permitted, processing data related to your location – Identity Data;
- handling and fulfilling your orders, if you request goods or services from us. This may also include processing of information that we receive from third parties, for example, address data to verify your correct address – Identity Data and Financial Data;
- obtaining payment from you, if you purchase any of our goods and/or services – Identity Data and Financial Data;
- enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions, as may be required, in order to fulfil your orders – Identity Data and Financial Data;
- resolving any returns, refunds or disputes, if you lawfully exercise your rights or if you wish to dispute any part of our offering – Identity Data and Financial Data;
- sending you administrative communications and notices – Identity Data;
- sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you – Identity Data;
- serving personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our sites, and other data obtained through the use of “cookies” placed on your devices. Please see our Cookie Statement below – Identity Data;
- ensuring the security of your account and our business, preventing or detecting fraud or abuses of our site, for example, by requesting verification information in order to reset your account password – Identity Data and Technical Data;
- developing and improving our products and services, enhance the operation of our site and statistically analyse site use, for example, by reviewing visits to our site and its various subpages, demand for specific goods and services and User comments– Identity Data and Technical Data;
- to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law– Identity Data, Financial Data and Technical Data;
- your request for content, goods or services necessitating steps including processing of your PII to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract; and
- legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights. We will rely on this legal ground in relation to the processing set out in paragraphs above, in which we have a legitimate interest; and
- compliance with a legal obligation to which we are subject, such as, for example, the processing for the purposes set out above.
- COLLECTION METHODSWe use different methods to collect data from and about you including through:Direct Interactions: We collect PII about you when you voluntarily provide it to us. You provide certain PII (mostly Identity Data) to us when you (a) register for our services and register your e-mail address with us; (b) enter sweepstakes or contests sponsored by us or one of our partners; (c) sign up for special offers from selected third parties; (d) send e-mail messages, submit forms, or transmit other information by telephone or letter; or (e) submit your credit card or other payment information when ordering and purchasing products and services on our site. We may also collect information from you at other points on our site that state that such information is being collected.Automated Technologies or Interactions: In addition, we may also collect certain other Technical Data (some of which is Non-PII). This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our site, and to gather demographic information.Third Parties or Publicly available sources: Our third-party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our site.In addition of identity Data we may collect demographic information such as your age, gender, favourite styles of gaming and the device you own or plan to buy.
- RELEASE OF INFORMATIONWe do not sell, trade, or rent your PII to others. We do provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third parties. We and our service partners use your PII to operate our sites and to deliver their services. Where we wish to disclose or are compelled to disclose your PII to third parties this will only take place in accordance with applicable laws and for the purposes listed above. These scenarios include disclosure:
- to our subsidiaries, branches or associated offices;
- to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our data centre provider for the safe keeping of your PII, webhosting provider through which your PII may be collected, identity verification partners in order to verify your identity against public databases, logistics partners for delivery of products you have ordered, bank to process you credit card information where you have purchased something from us;
- to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;
- subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by clicking here;
- to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- to analytics and search engine providers (including Google Analytics and FB Tracing pixel) that assist us in the improvement and optimisation of the Site. Your PII is generally shared in a form that does not directly identify you;
- third party analytics providers that assist us in establishing trends amongst our users based on the information you provide to us and generating associated content (for example, news articles and/or social media posts);
- to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your PII will be permanently transferred to a successor company;
- to public authorities where we are required by law to do so; and
- to any other third party where you have provided your consent.
- With vendors, consultants, and/or other service providers (“Service Providers”) who are engaged by or working with us in connection with the operation of the Services and/or the promotion of 505Games products and who need access to such information to carry out their work;
- With other Users of the Services as described herein; and
- With promotional partners to send you coupons, promotions, rewards, awards and advertisements you request.
- INTERNATIONAL TRANSFER OF PIIWe may transfer your PII to:
- third parties in countries outside the country in which it was originally collected; and
- within the 505 Games Group (which may also involve a transfer to a country outside the country in which it was originally collected),
- transfers to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
- for transfers to the US, if the entity is part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
- RETENTION OF PIIYour PII will be retained until your last use or purchase of our services or goods and normally for a period of five years thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your PII that is no longer required for the purposes set out in this Policy. The retention of your PII will be subject to periodic review.We may keep an anonymised form of your PII, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
- DATA SUBJECT RIGHTSData protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their PII. Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their PII is not being processed in accordance with applicable law.Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their PII. If you would like to make a SAR i.e. a request for copies of the PII we hold about you, you may do so by writing to the Privacy Compliance Officer whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee.Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete PII.Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your PII at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your PII is essential.Right to object to processing. You may, as permitted by applicable law, request that we stop processing your PII.Right to erasure. You may request that we erase your PII and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your PII, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.Right to data portability. In certain circumstances, you may request that we transfer your pII TO YOU OR TO A THIRD PARTY in a structured, commonly used and machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your pii in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your PII. However, you do have the right to contact the relevant supervisory authority directly.
- UPDATING AND CORRECTING INFORMATIONWe believe you should have the ability to access and edit the PII that you have provided to us. You may change any of your PII in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this site. You may also access and correct your personal information and privacy preferences by writing us using the contact details above.Please include your name, address, and/or e-mail address when you contact us.We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed (see above).
- USER CHOICES ON COLLECTION AND USE OF INFORMATIONWe strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.We may, from time to time, send you e-mails regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only 505 Games (or agents working on behalf of 505 Games and under confidentiality agreements) will send you these direct mailings and only if you indicated that you have not opted out of receiving such marketing and, in relation to marketing from our partners, only if you have expressly opted-in to receiving marketing communications from third parties.If you do not want to receive such mailings, simply tell us when you give us your personal information. Or, at any time, you can easily edit your account information by logging into the site or by contacting us at any time to no longer receive such offers and mailings.You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our site may not work properly.
- SECURITY OF INFORMATIONAt our site, you can be assured that your PII is secure, consistent with current industry standards. The importance of security for all PII associated with our users is of utmost concern to us. Your PII is protected in several ways. Access by you to your PII is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your PII resides on a secure server that only selected 505 Games personnel and contractors have access to via password. We encrypt your PII and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.As described above, in order to most efficiently serve you, credit card transactions and order fulfilment are handled by established third-party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
- COOKIESWhen you use our site we will store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a Web site stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our site. The cookies make your use of the site easier, make the site run more smoothly, and help us to maintain a secure site. You are always free to decline our cookies if your browser permits, but some parts of our site may not work properly in that case.We may use an outside ad serving company to display banner advertisements on our site. As part of their service, they will place a separate cookie on your computer. We will not provide any third-party ad server with any information about your purchases. As described above, we and our third-party ad server will collect and use information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to a particular ad. Other advertisers may also place banner ads on our site in the same manner as above, but we will not disclose any PII to them.
- YOUR CALIFORNIA PRIVACY RIGHTSIf you are a California resident, California Civil Code Section 1798.83 provides you with the right to receive: a) information identifying any third party company(ies) to whom 505 Games may have disclosed, within the past year, personal information pertaining to you and your family for that company’s direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request via the Contact link at the bottom of the 505 Games site pages.Moreover, if you are a California resident, California law provides that you be given the opportunity to opt out of our sharing your personal information with third parties that would use such personal information for their own direct marketing. Absent such an opt-out, we may share your information with other affiliates of 505 Games, to provide you with information about their products, services or promotions that we think may be of interest to you. Accordingly, per California law, we provide a way for you to opt out if you do not want us to share your information in this manner.California residents can also opt out of our sharing your information as described above by contacting Customer Service, Monday – Friday 9:00 AM – 5:00 p.m. (PST) at the following toll-free number: (818) 540-3000, and requesting that you would like to opt out from receiving all marketing communications from 505 Games and/or any of its affiliates. If you have already received communications from us, it will expedite the opt-out process if you are prepared to provide us with the exact name, and e-mail and/or postal mail addresses under which you have been receiving communications from us. Please note that it may take us up to 30 days to fully process your opt-out request.
- fax at +39 02 4130399
- email at, email@example.com
- post at 505 Games S.p.A. Via Tortona 37 20144 Milan (Italy)
- GUIDELINES FOR CHILDRENBy accessing the Web Site and/or Service(s), you affirm that you are more than 18 years old, are an emancipated minor, or have the consent of your parents or legal guardian and, therefore, are fully capable and competent to abide by and enter into the agreements and obligations set forth in these Terms of Services.Unless stated specifically to the contrary on the applicable 505Games site, 505Games’s Services are not intended for children under 13 (“Child” or “Children”) and 505Games will not request any PII from Children. Therefore, 505Games restricts access to certain Services on age grounds. In certain jurisdictions, for certain Services and functions, 505Games may allow a Child to register for certain Services with parental approval.When Children are permitted to register for a Service with parental approval, we will take additional steps to protect the Children’s privacy, including:Notifying parents about our information practices with regard to Children, including the types of PII we may collect from Children, the uses to which we may put that information, and whether and with whom we may share that informationIn accordance with applicable law, obtaining consent from parents for the collection and use of PII from their ChildrenLimiting our collection of PII from Children to no more than is reasonably necessary to participate in an online activityGiving parents access or the ability to request access to PII we have collected from their Children and the ability to request that PII be changed or deletedMore specifically, when a Child registers, (s)he must supply the e-mail address, and/or other contact information of a parent or legal guardian who will be contacted by 505Games to ask him/her to confirm, refuse to modify his/her Child’s registration. The parent/legal guardian may be asked to provide additional documentation or perform additional actions as part of the approval process as consistent with applicable law. 505Games reserves the right to refuse access to the Service pending confirmation and activation by his/her parent or guardian. 505Games reserves the right to ask for written proof of parental consent for any User or potential User of the services suspected to be a Child. Parental consent applies exclusively to the specific service for which it has been granted.Certain Services are specifically designed for Children and enable Children to create their own free accounts for which 505Games collects their username or other identifier, password, date of birth (or age), photo, video, voice recording, country, zip code or other geo-locational information, and parent or guardian’s e-mail address and/or other parent or guardian contact information. Such Services sometimes offer the possibility of paying for a subscription or certain game functions which enable Children to participate in more activities on the Services by making a payment. The subscription services may also allow parents or guardians to manage their Child’s account and create their own player accounts.Certain Services enable Children to create personalized avatars which they can use in numerous activities in the services, including mini-games and virtual worlds. Children may also use other functions of the Services such as “Recommend to a friend” to invite a friend to find out about the Services. The “Recommend to a friend” functions enable Children to send their friends a single message inviting them to visit the related service. 505Games will collect the first name and e-mail address of your Child (or, failing that, the e-mail address of the parent or guardian) and the e-mail address of his/her friend for the sole purpose of sending a single message. This information is neither stored nor used for any other purpose and we do not reveal your child’s e-mail address to the recipient.Parents may delete their Child’s account or change their Child’s privacy settings at any time by sending an e-mail to the Privacy Compliace Officer, who is identified above in section 1. The deletion request will be processed within thirty (30) days of the date of which we receive it.In all cases, use of the Services by Children must take place under the responsibility of their parents or legal guardians and any use of the Services is assumed to have been validated by them. AS FAR AS IS PERMITTED BY APPLICABLE LEGISLATION, 505GAMES DECLINES ANY RESPONSIBILITY REGARDING ANY ACTIVITIES WHICH MAY BE CONDUCTED BY CHILDREN WITHOUT THE PERMISSION OF THEIR PARENTS OR LEGAL GUARDIANS.IF YOU ARE A PARENT OR LEGAL GUARDIAN AND YOU GIVE YOUR PERMISSION FOR YOUR CHILD TO REGISTER FOR ONE OR OTHER OF THE SERVICES, YOU THEREBY AGREE TO THE TERMS RELATING TO USE OF THE SERVICES BY YOUR CHILD.