Version 1.0
Dix 2012 Ltd. (Dix) respects the privacy rights of its users and recognises the importance of protecting their personal data. This Digital Product Privacy Policy (the „Privacy Policy”) provides information relating to the collection, processing, use and privacy of information you submit through the Digital Product.
Dix is the controller within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 -„GDPR”).
Words and expressions in this Privacy Policy have the same meaning as in the End User License Agreement for the Digital Product.
1 What Information We Collect and Process
1.1 Information about Your Person
In order to use the Digital Product you may need to provide the country you wish your user experience to be set to. The provision of this information is necessary to provide you with the country-specific content of the Digital Product.
1.2 Information about the Device You Use
To enable the connection of the device on which you use your Digital Product to Dix servers, we may collect and process technical information related to your device, such as MAC address, IP address, serial number or other alphanumeric codes assigned to your device.
We may also collect and process information about the settings of the device you use to optimise your experience, such as country settings, language settings, parental control settings and wireless access point information of the device; we may also collect screen resolution and other display preferences of the device that you use.
1.3 Information Related to Your Transactions
If you use the Digital Product to make any transactions, we collect and process information about these transactions, such as the registration of licences, purchase of items, use of items, payments and other related activities.
1.4 Information Related to Your Use of the Digital Product
To enable you to enjoy all features of your Digital Product, we process the data related to your activities, such as the nickname, appearance and profile of the character representing you in the Digital Product, alphanumeric codes assigned to your Digital Product, friends and favourites that you registered, other users you played with, User-Generated Content that you uploaded, posted or otherwise made available via the Digital Product, your online presence information, and other data specific to the features of the Digital Product that you use.
We may also collect your activity history data such as which features of the Digital Product you used, at what times you played, your level, score and in-game location, as well as crash reports.
1.5 Linking to Other Networks
Dix does not allow you to link your Digital Product to another account offered by a third party.
1.6 Cookies and Similar Technologies
The Digital Product may use cookies and other similar technologies. Cookies are small files downloaded to your device. Cookies help us to ensure the safety and smooth functionality of our services (security cookies and session cookies).
The security and session cookies that we employ are necessary to provide you with the services you have requested. For example, we employ cookies that enable us to maintain your online session.
2 How Information Is Used – Purposes of Processing
2.1 Providing the Service
We collect and further process the information in order to:
- Set up the connection of your device with Dix servers,
- Enable your use of the Digital Product; and to
- Process requests that you make via the Digital Product.
If you use the Digital Product for making transactions, we process the information about the transactions you make to the extent necessary to process your orders, to provide you with the transaction history and to meet our financial and legal obligations.
The legal basis for the processing referred to in this Section 2.1 is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).
2.2 Fraud Prevention and Prevention of Other Illegal Activities
We may process the collected information relating to the use of the Digital Product to prevent fraud, potentially illegal or offensive activities or to enforce our rights or the rights of other users.
The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the prevention of fraudulent and illegal activities, the protection of our systems and networks, of our services and of our users and the enforcement of our legitimate rights and rights of our users.
You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.
2.3 Usage Information
„Usage Information” as referred to in this Section 2.4 includes all information submitted through the Digital Product as well as all information collected and processed when using the Digital Product.
2.3.1 Provision of the service
We process the Usage Information for the provision of the service of the Digital Product described in Section 2.1. The legal basis for the processing referred to in this Section 2.4.1 is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).
2.3.2 Product and Service Improvement
We process the Usage Information to perform analytics and statistics of the usage of the Digital Product in order to improve and optimise the Digital Product and our products, our services and performance of our products and services.
The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the improvement and optimization of the Digital Product and of our products and performances which is to the benefit of the users.
You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time opt out in the „Sharing Usage Data” settings of your Digital Product.
2.4 Linking to Other Networks
The legal basis for the processing in the cases explained in Section 1.5 is Art. 6 para. 1 (a) GDPR.
2.5 Cookies and Similar Technologies
The legal basis for using security and session cookies as explained in Section 1.6 above is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).
3 User Communications
When you send an email or other communication to Dix, we use those communications in order to process your inquiries and respond to your requests.
The legal basis for this processing is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).
4 Who Has Access to Your Information
Dix does not share your information with third party.
5 Storage Time
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or – where the applicable law provides for longer storage and retention periods – for the storage and retention period required by law. After that your personal data will be deleted.
In particular:
- If you withdraw a consent on which a processing of your personal data is based, we will delete your personal data without undue delay to the extent that the collection and processing of the personal data was based on the withdrawn consent.
- If you exercise a right to object to the processing of your personal data, we will delete your personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
6 Your rights under GDPR
In particular, but without limitation, you may have the following rights under applicable European data protection law:
- Right of access: You have the right to obtain confirmation from us as to whether or not we process personal data from you and you also have the right to at any time obtain access to our personal data stored by us. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy. You can also access the information you provided in the settings of your Digital Product.
- Right to rectification of your personal data: If we process your personal data, we shall endeavour to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which your personal data was collected. If your personal data is inaccurate or incomplete, you have the right to obtain the rectification of such data. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy. You can also change the information you provided in the settings of your Digital Product.
- Right to erasure of your personal data or right to restriction of processing: You may have the right to obtain the erasure of your personal data or the restriction of processing of your personal data. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.
- Right to withdraw your consent: If you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.
- Right to data portability: You may have the right to receive the personal data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.
- Right to object: You may have the right to object to the processing of your personal data as further specified in this Privacy Policy.
- Right to lodge a complaint with supervisory authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union. You may contact the Hesse Data Protection Supervisor.
7 Dix’s European Representative and Contact
If you have any questions about this Privacy Policy and Dix’s data processing activities or if you want to exercise any of your rights under GDPR, please contact:
Dix 2012 Ltd, 2330 Dunaharaszti, Somogyváry Gyula u. 54/B, +36305522193, dix@dix.hu.
8 Dix’s Data Protection Officer:
Dix 2012 Ltd, 2330 Dunaharaszti, Somogyváry Gyula u. 54/B, +36305522193, dix@dix.hu.