Privacy Policy

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0 A.D. Empires Ascendant Multiplayer Lobby Privacy Policy

Document Date: 2018-10-16

Personal data processed by Wildfire Games and purposes of processing:

1. Playername

The player is identified by a name that the player chooses at the time of registration.
Having a unique playername is a requirement to gain a rating, to allow players, moderators and developers to identify players they met before, communicate about the game, coordinate matches and enables moderators to enforce the Terms of Use.
The playername serves as a pseudoynm. The identity (natural person) of players is not known to Wildfire Games, except where personally identifiable information (such as the realname) was disclosed on the Lobby Chat, other services of Wildfire Games or elsewhere in the public, or when the IP address is used to bring criminal proceedings.

2. Password

A player is authenticated using a password that the player chooses at the time of registration.
Wildfire Games only receives an encrypted version of the password, so that the password chosen by the user is not revealed to Wildfire Games or others in case of a breach.

3. IP address

When a player hosts a match in the Multiplayer Lobby, the IP address of that player is sent to every player who is online, so that other players can join that game.
Wildfire Games stores players IP addresses and may infer publicly available geolocation and internet service provider data (for example "geolite2") from the IP address in order to:

1. Enforce the Terms of Use where persons create multiple accounts without Wildfire Games permission, in particular after having been banned from the service for violating the Terms of Use. IP addresses will not be saved for longer than three years for this purpose.
2. Make it possible to bring criminal proceedings in case of a cyberattack (EU Court of Justice Press Release No 112/16).

Wildfire Games will not use the IP address logs for any other purpose, in particular not for marketing, not otherwise disclose IP addresses to the public or third parties and erase IP addresses if they are not relevant for the stated purposes anymore.

4. Online presence

Which players are currently connected to the Multiplayer Lobby and which match they joined is shown to all online players.

5. Chat messages

The Multiplayer Lobby features a public chat room that enables players to discuss the game and organize multiplayer matches.
Wildfire Games stores a log of the public chat messages and online presence to meet the following purposes:

1. Moderators may screen chat messages to enforce the Terms of Use.
2. Wildfire Games may address or resolve bug reports, balancing issues or feature proposals indicated by players in the chat room.
3. Wildfire Games may assess trends amongst discussed topics, the growth of the active community and use these indicators as feedback to assess, improve and direct development of the game and the service.

6. Match statistics

Players can gain a rating on the Multiplayer Lobby that reflects their skill at the game.
The rating of all players is published by Wildfire Games and allows players to focus on competitive or balanced matchmaking if they wish to.
During a rated match, players send data relating to the game (such as the number of units trained, resources gathered and the winner of the match) to Wildfire Games, so that Wildfire Games can adapt the players ratings based on these statistics.
Wildfire Games stores match statistics to:

1. Verify the accuracy of the rating score and identify and enforce Terms of Use violations relating to that.
2. Compute and publish community statistics to improve the game and the service, for example to improve the balancing of the game or to make certain aspects of the game more appealing.

Security of processing:

The transmission of personal data is secured using TLS encryption (GDPR 32).
Personal data is protected against unintentional loss in encrypted backups for additional time (GDPR 30.1.g, GDPR 32).

All personal data that Wildfire Games processes is obtained from the user (GDPR 14).
Wildfire Games reserves the right to delete any service data (including personal data) at any time, except where a user has objected to the erasure of his or her personal data for performance of a legal claim.

Legal basis for the processing:

1. The processing is necessary for the performance of the service defined in the terms (GDPR 6.1.b).
2. Wildfire Games has legitimate interests in providing the Multiplayer Lobby, in the development and improvement of 0 A.D. and the Multiplayer Lobby, in enforcing the Terms of Use and in the protection against cyberattacks (GDPR 6.1.f).
3. Wildfire Games does not process any further data for the Multiplayer Lobby and does not ask for consent to process data (GDPR 6.1.a, GDPR 7, GDPR 8, GDPR 13.2.c).

User rights:

1. Contact Wildfire Games, by sending an email to webmaster at wildfiregames dot com (GDPR 13.1.a, GDPR 13.1.b). To exercise any user right, please refer to this contact.
2. Right of access to personal data concerning him or her (GDPR 15).
3. Right to obtain personal data in a machine-readable format (GDPR 20).
4. Right to rectification of inaccurate personal data (GDPR 16).
5. Right to erasure of personal data where it is not relevant to the stated purposes, if the data was processed unlawfully or if the user objects to the processing and has overriding legitimate grounds (GDPR 17).
6. Right to restriction of personal data processing where the accuracy of the data is contested by the user, if the data was processed unlawfully or if the user requires the data for a legal claim (GDPR 18).
7. Right to object to the processing of personal data concerning him or her on grounds relating to their particular situation (GDPR 21).
8. Right to lodge a complaint with a supervisory authority (GDPR 13.2.d, GDPR 77).

Requests that are manifestly unfounded or excessive are not responded to or may be charged (GDPR 12.4, GDPR 12.5).

Wildfire Games obligations:

1. 1. Wildfire Games demonstrates compliance with GDPR (GDPR 5.2 'accountability').
   2. Wildfire Games documents their processing activities appropriately, in particular the categories of processed personal data and security measures to protect it (GDPR 30).
   3. Wildfire Games processes personal data lawfully, fairly and transparently (GDPR 5.1.a, GDPR 12.1).
   4. Wildfire Games informs users of the purposes, legal grounds, legitimate interests and retention periods of personal data processing at the time it is processed, recipients of personal data and where applicable, transfer of personal data to third countries and automated decision-making (GDPR 13.1.c-f, GDPR 13.2.a, GDPR 13.2.e-f, GDPR 15.1, GDPR 15.4).
   5. Wildfire Games does not processes personal data for purposes other than the specified ones (GDPR 5.1.b, 'purpose limitation', GDPR 13.3).
   6. Wildfire Games does not process personal data that is not needed for the specified purposes (GDPR 5.1.c, 'data minimization').
   7. Wildfire Games uses a storage form that does not allow identification of natural persons for longer than necessary (GDPR 5.1.e 'storage limitation').
   8. Wildfire Games secures personal data processing to prevent unauthorised or unlawful processing and accidental loss (GDPR 5.1.f. 'integrity and confidentiality').
   9. Wildfire Games informs users of their right to access, to rectify, to erase personal data and the right to restrict, to withdraw consent to, to object to personal data processing and to complain at a supervisory authority (GDPR 13.2.b, GDPR 13.2.c, GDPR 13.2.d).
2. Wildfire Games facilitates the exercise of user rights where possible (GDPR 12.2), without undue delay (GDPR 12.3).
3. Wildfire Games informs the users that to exercise their rights, users might need to provide additional information to identify the natural person or the data (GDPR 12.6, GDPR 13.2.e).
4. Wildfire Games will not knowingly collect personal data from children under the age of 13 (Children's Online Privacy Protection Act). If you believe Wildfire Games received any personal data from or about a child under 13, please contact Wildfire Games.
5. Where Wildfire Games processes sensitive personal data based on legitimate interests, Wildfire Games considers performing, recording and periodically reviewing Legitimate Interests Assessments and Data Protection Impact Assessments (GDPR 35) to become confident that the individual's interests do not override Wildfire Games legitimate interests, and that Wildfire Games is not using personal data in intrusive ways unless there is a very good reason to.

For further information on Wildfire Games Privacy Policies, visit https://trac.wildfiregames.com/wiki/UserDataProtection