MindArk PE Aktiebolag (publ) (”we” or “MindArk”) cares about your privacy. Therefore, we always strive to protect your personal data in the best possible way and to comply with all applicable laws and regulations for the protection of personal data. Personal data is defined as any information relating to an identified or identifiable natural person; it can be information about your name, address etc., but can also be your avatar’s name and activities in Entropia Universe.
This policy applies to all Entropia Universe users and potential users. Here, we inform you about how we collect and process your personal data when you are an Entropia Universe user and when you subscribe to our newsletter.
You will find more detailed information about our data processing procedures below. Below we provide information about the legal basis, storage period, purpose of processing, and how you can influence our processing of your personal data.
Table of contents
- Who is responsible for your personal data? Questions or queries?
- From whom or where do we collect your personal data?
- How and on what legal basis do we process your personal data?
- For how long will we store your personal data?
- Are you required to provide the personal data?
- Who can gain access to your personal data?
- Where is your personal data stored/transferred to?
- How can you influence our processing of your personal data?
Who is responsible for your personal data? Questions or queries?
MindArk PE Aktiebolag (publ), Swedish company registration number 556640-4769, located at Masthamnsgatan 5, 413 27 Gothenburg, Sweden and with the email address email@example.com is responsible for the processing of your personal data (the controller).
If you have any questions regarding our processing of your personal data, you may contact us via the Support Section of the Entropia Universe website, or via any of the contact details stated above. If you wish to mail us, please send a letter to the address stated above, to the attention of Entropia Support.
From whom or where do we collect your personal data?
We collect the majority of the personal data that we process about you from you, including when you use Entropia Universe. We also collect information about browser cookies, your IP address and/or MAC address associated with your device.
In addition, we also process some personal data about you that we have collected from other Entropia Universe users if they share information about you with us, either directly by addressing us or indirectly by mentioning you in chats within Entropia Universe.
How and on what legal basis do we process your personal data?
Our aim is to be as transparent as possible regarding our processing of your personal data. Therefore, we provide detailed information about how we process your personal data below. Here you can read about why we process your personal data (the purposes of processing), what personal data we process and our legal basis for processing your personal data.
To enable you to create an Entropia Universe account
When you create an Entropia Universe account, you will submit information relating to your log-in name, your email address, and your password. We will process this information to create an Entropia Universe account for you and thereafter process your email address to send a verification to your email address.
If you do not download the Entropia Universe client to your device after an Entropia Universe account has been created, we process information about your email address in order to send you an email reminder to download the client.
Our legal basis for the processing described above is to administer and fulfill our obligations towards you as an Entropia Universe user, i.e. to be able to enter into our contract and for the performance of our contract with you.
To provide Entropia Universe to you as a user
If you log in and participate in Entropia Universe, we will process all information associated with your Entropia Universe account (see above), information regarding your IP address, MAC address as well as information about your game progress and in-game behavior in Entropia Universe. This is, for example, information about how your avatar interacts in Entropia Universe, what competitions and challenges you participate in, information about the equipment associated with your avatar, information relating to your PED Card balance, information about in-game transactions and settings you have chosen as well as information about your device such as hardware, related drivers and your IP address, in order to be able to technically provide the game to you. We will also process personal data about you in logs from within Entropia Universe that you are either part of or referred to.
If you forget your Entropia Universe account password, we will, upon your request, send an email to the email address that you have registered for your Entropia Universe account.
All of our processing of your personal data as described above is for the purpose of administering and fulfilling our obligations to you as an Entropia Universe user, i.e. the legal basis that it is necessary for the performance of our contract with you.
To administer exchanges of PED and items for your avatar and to handle deposits and withdrawals of funds
In order to handle any exchanges of PED and/or items for your avatar from the Entropia Universe webshop and to handle deposits or withdrawals of funds relevant payment information is transferred to and handled by our payment providers. In some cases, the payment providers themselves are the personal data controllers and will in such case provide information about their processing to you separately; this is the case for example when making a bank transfer to us.
For these purposes we will process information about your Entropia Universe account (see above), age, country of residence, address, date of birth and information about your debit/credit card or bank account details. Which personal data is processed depends on the payment method you choose. Your credit card details or other payment information is handled and stored according to industry standards, either by us, and/or by our payment processors.
We process your personal data for the purposes of administering and fulfilling our obligations to you when you make a purchase and/or deposit or withdrawal of funds, i.e. the legal basis that it is necessary for the performance of our contract with you. We also process some information when handling deposits or withdrawals in order to comply with applicable laws and regulations (see below).
To communicate with you, for example regarding support cases
To answer your questions and otherwise communicate with you as an Entropia Universe user, for example via our support channels, mobile apps, chat, social media or email, we will process information about your name, email address and any other information that you share with us when communicating.
Our legal basis for processing is our legitimate interest in helping you with the matter regarding which you have contacted us. You can read more about our balance of interests test below.
To publish any user testimonials that you’ve written
We may ask you to write a user testimonial and thereafter publish your user testimonial if you agree to let us publish it. For this purpose, we process your name and other information that you share in your user testimonial.
We may contact you with a request for a user testimonial and publish such user testimonials based on our legitimate interest in being able to request user testimonials from our users, and to share such testimonials that you have chosen to write. You can read more about our balance of interests test below.
Our legal basis for the processing is our legitimate interest in ensuring that your use of Entropia Universe complies with applicable rules and policies. You can read more about our balance of interests test below.
To send information, newsletters and marketing to you
We will send different types of information, newsletters and marketing to you as an Entropia Universe user, as detailed below.
- If you have permitted us to send you newsletters we will periodically send you emails with information about Entropia Universe that we believe is relevant for you and other Entropia Universe users. This may include information regarding upcoming events or competitions and information about technical issues. We may also send more personalized emails to you based on personal data that we have collected about you, for instance, your date of birth, or your activity within Entropia Universe. For example, an email may be sent when you have been inactive for an extended period. You only receive information, newsletters and/or marketing if you have given us your consent to do so. If you withdraw your consent we will stop sending you such information. For further information, see below.
To protect us against fraud or attempted fraud
We process your personal data in order to prevent and handle fraud or fraud attempts, for example credit card fraud.
- To make deposits and withdrawals we can take measures to verify your identity. Which specific measures we take depends on the money transfer method, as well as your deposit level. If we need to verify your identity we process your name, address, and bank information regarding your bank statements. If possible we will also send a verification code for verified cards to allow you to confirm your identity. To increase your deposit limit even further or for other money transfer methods we may request a verified copy of your passport or government-issued ID. Furthermore, we process personal data in logs in order to verify the source of funds , including information from security checks and whether you have completed the required information or not.
- For this purpose, we also process personal data that is relevant for us to identify a potential fraud attempt or an actual fraud. The personal data processed can include information about how you use Entropia Universe (including logs), suspicious behavior, insults or abuse directed at other users in chat, and your Entropia Universe account. To verify you as a legitimate user for the purpose of protecting us against economic fraud we may process information about whether you are located in the same country as your IP, your birth certificate and/or a verified copy of your passport and your MAC address.
Our legal basis for processing is our legitimate interest in protecting other users and ourselves against fraud and fraud attempts. You can read more about our balance of interests test below.
To handle complaints and/or legal disputes
In order to handle any complaints and/or legal disputes regarding your use of Entropia Universe or any transactions you have made, we process your name, email address, phone number and any other personal data which is relevant within the framework of the complaint and/or legal dispute. This may include information about your behavior within Entropia Universe, information about any transactions and so on.
Our processing for this purpose is our legitimate interest in processing information about you in order to establish, exercise or defend us against legal claims. You can read more about our balance of interests test below.
To comply with applicable laws and regulations
We process your personal data in order to comply with applicable laws and regulations. For example, we process your personal data for this purpose in accordance with the following:
- To comply with applicable accounting, bookkeeping, tax and VAT laws and regulations we process your name, address, country, your PED transactions, deposits, withdrawals and payment information (see above for information regarding our processing for handling withdrawals).
- To comply with applicable anti-money laundering legislation when we are obliged to do so. If you make withdrawals over a certain limit this includes processing of a verified copy of your passport or government-issued ID to verify your identity if you make a deposit and/or withdrawal of funds, and process information in logs in order to verify the source of the money. For this purpose, we also process information about whether you are located in the same country as your IP address indicates.
- Depending on where you live, it might be possible for you to purchase loot boxes. If that is the case and you purchase loot boxes, we will process your IP address, bank account number, which country you are located in and your avatar status in order to comply with applicable legislation.
To improve Entropia Universe
We process your personal data, namely information about your hardware and software configuration, as well as information about your game progress and in-game behavior in order to improve Entropia Universe and your gaming experience. For example, we optimize Entropia Universe based on information about how you and other users interact and move when playing.
If the Entropia Universe client crashes when you use it, we process the information that you experienced a crash, what happened during the crash and information from your device, but not information about what you did before the crash or information about other software running at the same time. This means that we process information about your account name, graphics card, drivers, sound card, MAC address, operating system, total system memory (RAM) and how much memory is available, position in Entropia Universe (X, Y or Z sector and server), how long Entropia Universe had been running before the crash, and in some cases other relevant information such as the textures your client was loading when the crash happened. We will also automatically take a screenshot showing the exact state of what the client was showing at the moment the client crashed.
Our legal basis for processing information to improve Entropia Universe and your gaming experience and for processing information about the crash is our legitimate interest in improving Entropia Universe in order to offer a better user experience for you and other Entropia Universe users. You can read more about our balance of interests test below. Note that you can choose whether to automatically send information regarding crashes in your client settings.
To create statistics
In order to be able to compile statistics about Entropia Universe we process personal data, for example regarding your gender, in order to know how many males and females that use Entropia Universe, how many users have participated in a specific event, how much activity occurred during an event, and what the most popular content was. We may also compile statistics about the age category users of Entropia Universe represent, and may process information about your date of birth. The statistical compilation will be aggregated so that your personal data will only be processed for the initial part of the compilation. If we send statistical information to our business partners, we always anonymize such information, i.e. they will not receive personal data about you in the statistics they receive from us.
Our legal basis for processing is our legitimate interest in creating statistics. You can read more about our balance of interests test below.
To provide personalized marketing to you and to market Entropia Universe to potential new users
If you were referred to Entropia Universe by a third-party marketing campaign a number combination will be created especially for you and we will make a note on your account to know which campaign you clicked before creating an account on Entropia Universe, as well as which number combination that is collected by you. We may receive such information from a third-party that provides and manages such marketing services.
Thereafter we may provide your number combination to a third party which shows personalized marketing to potential users of Entropia Universe similar to you in digital channels, social media and/or third-party websites. We store the number combination for this purpose for as long as you have an account on Entropia Universe, unless you have objected to such processing before.
Our legal basis for processing is our legitimate interest in providing relevant marketing to you as a potential customer and to other customers based on information that we or third-parties have collected about you (so called profiling). You can read more about our balance of interests test below.
Balance of interests tests when processing data based on “legitimate interests”
For how long will we store your personal data?
MindArk will only store your personal data for as long as the processing is necessary for the purpose that it is being processed. As a general rule, we will only store your personal data for as long as you have an Entropia Universe account. We will stop processing your personal data when you unregister your account or ask us to delete certain data (provided that the data cannot be stored by us thereafter in accordance with applicable data protection legislation, see further information below). Please note that your Entropia Universe account and all related personal data will be deleted if you have been inactive for a consecutive period of one year (excluding any personal data that needs to be stored for a longer period, as described below).
We will continuously erase the personal data in the following cases:
- When we compile statistics about our users where only aggregated data is used; and
- Personal data that may be stored in unstructured material, for example questions asked via email, will continuously be erased in accordance with our retention policy, unless we need to keep the email for a longer period due to the purpose for which it is processed.
In the following cases, we will store your personal data for a longer or shorter period than what is stated above:
- If we have published your user testimonial, it will be published until you withdraw your consent to the processing by notifying us;
- We will store necessary personal data, such as information about your payment and any personal data that is relevant to process when you use loot boxes, in order to comply with Swedish accounting and bookkeeping acts and regulations for seven years from when the fiscal year that the payment refers to ended;
- We will store necessary personal data, such as chat and activity logs, for the purpose of reviewing the personal data to determine if an intended withdrawal is legitimate, for five to ten years according to applicable anti-money laundry legislation;
- We store your personal data from the date that a complaint and/or legal dispute, including potential complaint or legal dispute, comes to our attention and for as long as it is ongoing. If we decline your claim, we always store the information for one year in case you may choose to have your legal dispute reviewed by a relevant instance; and
- If you have consented to receive our information, newsletters and marketing, we will send such information, newsletters and marketing until you unsubscribe or no longer has an account.
Are you required to provide the personal data?
The substantial parts of our processing of your personal data is necessary for the fulfilment of the contract that we have with you. If you do not provide us with the personal data that we need to process to fulfill that contract, you will not be able to create an Entropia Universe account or use Entropia Universe.
As described above, some processing is also conducted due to legal requirements. If you do not provide us with the personal data which you are obligated to provide us with, for instance if you are making withdrawals over a certain limit and we need a copy of your passport or identity card for identity control purposes, you may not be able to make a deposit or withdrawal of funds.
Who can gain access to your personal data?
As a starting point, only MindArk processes your personal data. We may also share your personal data with our selected partners and suppliers in accordance with the below:
- We share information about your IP address with our supplier that provides us with the service that is used to control whether you are located in the same country that your IP address suggests;
- Depending on the method you use to deposit or withdrawal, we may share information about your credit/debit card number (if you choose to make a deposit by card) or other relevant information with our payment processor or our bank to administer any deposit and/or withdrawal of funds. If you choose a payment solution for which the service provider itself is the personal data controller, you will receive separate information from them regarding such processing;
- To post any user testimonials, we will make your personal data publicly available via our social media and/or website; and
- In order to provide personalized marketing to you and other potential customers we, in some cases, share the number combination that was created when you clicked on a banner with the relevant third party that provides such marketing.
If you want to know more about who we share your personal data with, please feel free to contact us.
Where is your personal data stored/transferred to?
MindArk does not process your personal data outside of the EU/EEA.
How can you influence our processing of your personal data?
Under data protection legislation, depending on the circumstances, you are entitled to a variety of rights regarding our processing of your personal data. We list some of those rights below.
Right to withdraw consent and to object to processing
You have the right to, entirely or partly, withdraw a previously given consent for the processing of your personal data. Your withdrawal will not have an effect on the lawfulness of prior processing based on your consent before its withdrawal.
You also have the right to object to our processing of your personal data that is performed based on our legitimate interests. You always have the right to object to marketing from us, such as newsletters. If you object, we will no longer process the personal data you have objected to us processing, unless we can demonstrate compelling legitimate reasons for the processing that outweigh your interests or if such processing is for the purpose of establishing, exercising or defending legal claims, in which case we may have the right to continue processing the personal data.
Right to information and access
You have the right to obtain confirmation as to whether or not we are processing personal data concerning you. You can gain access to the personal data and obtain a copy of the personal data processed by us.
As an active Entropia Universe user, you can also see information about your inventory, transaction history (deposit/withdrawals) for the last 12 months, bank information, account ID, bank name, bank location, and information regarding your support cases via the 'My Section' on the Entropia Universe website.
Right to rectification
You have the right to rectification of any inaccurate personal data concerning you and to ask us to have incomplete personal data completed. When assessing whether the personal data is incomplete or not, we will take into account the purposes of the processing.
Right to erasure (“the right to be forgotten”) and restriction of processing
Under certain circumstances, you have the right to request erasure of your personal data. One consequence of erasure is that your user account will become deactivated. This is the case where i) the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, ii) you withdraw your consent on which the processing is based and where there is no other legal ground for continuance of the processing, iii) you object to the processing and there are no overriding legitimate grounds for the processing, iv) you object to processing for direct marketing purposes, v) the personal data has been unlawfully processed or vi) the personal data must be erased in compliance with a legal obligation in European Union or EU member state law to which MindArk is subject.
You also have the right to request that MindArk restrict its processing of your personal data. That is the case when i) the accuracy of the personal data is contested by you, for a period enabling the controller to verify the accuracy of the personal data, ii) the processing is unlawful and you oppose the erasure of the personal data and instead request restriction of its use, iii) MindArk no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims or iv) you have objected to processing pending the verification whether the legitimate grounds of MindArk override those of yours.
Right to lodge a complaint to a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular in the EU/EEA member state of your habitual residence, place of work or place of the alleged infringement of the General Data Protection Regulation. You have such a right without prejudice to any other administrative or judicial remedy. In Sweden, the supervisory authority is The Swedish Data Protection Authority.
Right to data portability
You have a right to ask us to transfer some or all of your personal data which you have provided to us in a structured, commonly used and machine-readable format (data portability). This right applies if:
- the processing is based on consent or on a contract between you and us; and
- the processing is carried out by automated means.
In exercising your right to data portability, you have the right to have personal data transmitted directly from MindArk to another controller, where technically feasible.