Welcome to Target City, our simple story based first-person shooter game. At Target City, we respect your privacy and are committed to being transparent about what data we collect when you play our Game and how it is used.
GENERAL INFORMATION
a) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data.
b) What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
c) What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Serbia’s Data Protection Act, Law no. 87/2018) (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).
d) Who is responsible for data processing?
The responsible party for data processing is Target City (“Target City”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, you can reach us via email using support@thetargetcity.com.
e) What are the legal bases of processing?
We only process your Personal Data if we at least one of the following applies:
● you have given your consent,
● the data is necessary for the fulfillment of a contract / pre-contractual measures,
● the data is necessary for the fulfillment of a legal obligation or
● the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We may collect and process the following Personal Data about you:
a) Data that you give us:
This is information about you that you give to us when creating a user account (email and password) and the data you provide to us voluntarily for example when you request support or tell us about an issue with our game (your name, email address, player name, data you provide to us in relation to your request), your unique product user id (PUID) when you play our game. In terms of in-game communications we collect but not further process or monitor the communications related to your session.
b) Data that our and other systems collect about you:
If you download our game and install it, the game may learns but we do not further process or monitor certain details about your computer or device (such as IP address, which may be used to infer general location at a city or country level, unique device IDs, processing capabilities, manufacturer and model, language and other regional settings, and screen resolution and similar settings).
Likewise if you use the P2P network feature to host and/or create a game for others to join, the game learns but we do not further process or monitor details about the network and software you’re using (such as browser type and version, operating system name and version, ISP, and your preference settings).
Our game requires the use of the Epic Online Service (EOS) Subsystem provided by Epic Games, Inc. Doing so EOS may collect certain technical data and provided that Epic has disclosed the collection of technical data accurately in their Developer Agreements and Service Addendum for Standard Services we are not aware of any processing of Personal Data through the Use of Epic’s services. Equally, we have no possibility to influence the data Epic collects.
c) Other information:
We may also collect some Aggregated Data such as statistical or demographic data for any purpose including improving our game. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.
HOW WILL WE USE YOUR PERSONAL DATA?
We may collect, store and use your Personal Data for the following purposes including to :
● operate and improve our Game;
● create game accounts and allow users to play our Game;
● understand you and your preferences to enhance your experience and enjoyment using our Game;
● respond to your comments and questions and provide customer support service;
● enable you to communicate with other users.
We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances we may also be required by law to disclose or otherwise process your Personal Data.
DATA SHARING
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
a) Internal
If necessary, we transfer your Personal Data within Plachter Realty. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.
b) External bodies
Personal Data is transferred to our service providers in the following instances:
● in the context of fulfilling our contract with you,
● to communicate with you,
● to provide our Game, and
● to state authorities and institutions as far as this is required or necessary.
c) International transfers
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
WHERE AND HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Typically all Game related data is stored locally on your device. Certain data however is stored with us (including your contact and support requests). We will delete your Personal Data when we no longer need such Personal Data, for instance where:
● it is no longer necessary for us to retain your Personal Data to fulfill the purposes for which we had collected it;
● we believe that your Personal Data that we hold is inaccurate; or
● in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.
●
Sometimes, however there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.
DATA SECURITY
We use SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.
YOUR RIGHTS AND PRIVILEGES
a) Privacy rights
You can exercise the following rights:
● The right to access;
● The right to rectification;
● The right to erasure;
● The right to restrict processing;
● The right to object to processing;
● The right to data portability;
b) Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.
c) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
d) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
e) What we do not do
● We do not request Personal Data from minors and children;
● We do not process special category data without obtaining prior specific consent;
● We do not use Automated decision-making including profiling; and
● We do not sell your Personal Data.
HOW DO WE MAKE CHANGES TO THIS POLICY?
We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our Game. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.
EFFECTIVE DATE
Friday, 14th of June, 2024