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Privacy Policy 

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Last updated: 04 12 2023

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EERUS.CAP, and its subsidiaries which comprise the EERUS.CAP group of companies, “we”, “us” or “our”), is a developer, publisher and distributor of interactive entertainment. This Privacy Policy explains the data practices for the products, services and websites provided by the Entities. Please read this Privacy Policy carefully, and keep in mind that our practices and the data we collect may differ depending on how you use the Services. The Services are also subject to all other terms and policies included in our Services. This Privacy Policy supplements the privacy statements provided with your software product and by your platform manufacturer.

This Privacy Policy does not apply to personal data collected from candidates. Please review our Candidate Privacy Policy here.

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As part of its activities, EERUS.CAP collects and processes Personal Data to identify its stakeholders (customers, suppliers, service providers, independent lawyers, employees, commercial partners, etc.). As an organization that processes Personal Data, EERUS.CAP recognizes the need to control its collection, conservation, use and destruction in order to comply with Law No. 2013-450 of June 19, 2013 relating to to the Protection of Personal Data in Côte d'Ivoire and the General Data Protection Regulation (EU Regulation 2016/679). As such, a Personal Data Protection Correspondent / Data Protection Officer (DPO) has been appointed, to ensure EERUS.CAP’s compliance with the applicable regulations.

Through this Personal Data Confidentiality Charter (the “Charter”), EERUS.CAP undertakes to implement technical and organizational measures to guarantee the fair, transparent, lawful and adequate processing of Personal Data. This Charter reflects all of the commitments made by EERUS.CAP in terms of Personal Data Protection

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Notice when collecting personal data: Please see the Categories of data collected and How we use personal data and our legal bases sections for an overview of what data we collect, and why, and the Rights section to data for information on how to exercise your privacy rights, including opting out of the sale or sharing of your personal data.

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Categories of data collected


The type of data we collect depends on how you use the Services. In general, we collect the following information:

Identifiers/Contact Information: Name, username, gamertag, postal and email address, phone number, unique identifiers, mobile device identifier, platform identifier, game service identifier, advertising identifier (IDFA, Android identifier ) and IP address

Protected characteristics : Age and gender

Commercial information : purchase and usage history and preferences, including game information

Billing information : Payment information (credit/debit card information) and shipping address

Internet/Electronic Activity : Web/app browsing and gaming information related to the Services; information about your online interaction(s) with the Services or our advertisements; and information about the games and platforms you use, and other information about installed applications.

Device and Usage Data : Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with it the Services (e.g. content viewed, pages visited, clicks, scrolls)

Inferences from your profile : Inferences made from your information and web activity to help create a personalized profile so that we can identify goods and services that may be of interest to you

Audio/Visual Information : Photos, images and account avatars, audio information via chat features, game recordings and video footage (for example, when you participate in the play test)

Sensitive Information : Precise location information (if you allow the Services to collect your location), account identifiers (username and password), and content of communications through chat features.

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How we use information and our legal bases


We use the information we collect within EERUS.CAP as follows, in accordance with various legal bases:

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Business Purposes: To provide the Services and support, fulfill orders and requests, improve the Services and our business, develop new products and services, improve your experience on the Services, protect the safety of our users, employees, facilities and Services and develop internal marketing and demographic studies

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Business purposes: Market and advertise our products and services and those of our business partners, send you promotional resources and administer promotional activities or events

We also use your information as permitted by law.


Sources of the data we collect

 

How we obtain information depends on how you use the Services. For example, we collect data:

  • that you entrust to us directly, for example when you create an account, sign up for marketing or contact us

  • about games you play (automatically) from third-party platforms, for example when you play our games or access our Services with third-party accounts automatically, including through cookies and similar tracking technologies

  • from third parties, such as advertising networks, business partners, third-party information providers and others

 

When we share data


As detailed below, we share your data with:

  • vendors who provide support and other services for us

  • members of the EERUS.CAP group

  • advertising service providers and partners

  • other third parties (e.g., for collaboration, legal and security purposes, in connection with the sale or transfer of a business or asset, and for other purposes with your authorization)

  • other users, for example when you participate in open communities or events, or information posted on leaderboards

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In the past 12 months, EERUS.CAP has sold or shared unique identifiers, IP address, and Internet/electronic activity and inferences from your profile with third-party advertising providers to enable us to provide you with personalized advertisements to you and others like you. We do not sell or share personal data about individuals when we know they are under 18 without their consent (or that of their parents depending on their age).


Public display


If you share personal information, post an image or video, or provide other content in public forums such as a message board, chat room, comments box, or profile page, Other people may view, collect and use this information. If your username or identifier contains your name, your name will be publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of these public forums may be able to identify you, use the information to send you messages or copy images, videos or content that you have shared. There is no expectation of privacy or confidentiality on these public forums. Please do not share your personal data in public forums or in your username or handle. You are responsible for any information or content that you publicly post using our Services. 

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Data rights


Depending on your location, you may have certain rights over your personal data, including the right to:

  • Request access to your personal data or a copy thereof

  • Request deletion of your personal data

  • Request rectification or modification of your personal data

  • Be informed about the personal data we collect or process about you, the sources of the personal data and the third parties with whom the information has been shared or sold and for what purposes

  • Withdraw your consent, if processing is based on consent

  • Opt-out of the sale or sharing of your personal data (including targeted advertising)

  • Sign up/unsubscribe from financial incentives

  • Limit the use and disclosure of your sensitive personal data


Manage your account, communications and data


We provide you with several options for managing your Service account, the communications you receive from us, and how we use your information. This includes your Service account settings, email unsubscribe and deletion tools, and opting out of interest-based advertising.

You can find more information on managing your specific account and communications here.


Data retention


We will retain your information for as long as necessary to provide you with the Services, fulfill our legal obligations, or exercise, defend or establish our rights.


Minors’ Privacy


Generally speaking, we direct our Services towards an Adult audience and we do not knowingly collect personal data from persons under the age of 18 (or older, if applicable law provides different protections). If we learn that a child has provided personal information without a parent's permission, we will promptly delete that information. We encourage parents to ask their children never to give their real names, addresses or telephone numbers, without permission, when using the Internet.

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Data security


We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity and confidentiality of the data we collect about you. These security measures are designed to protect against accidental or unlawful destruction, loss, misuse, alteration and unauthorized disclosure or access to the data under our control. However, no system can be 100% secure and we cannot guarantee our security measures.

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International transfers


We and our suppliers and partners may process, transfer and store data about you in connection with the Services in the United States and other countries that may not have privacy laws equivalent to those of the country where you reside. We take steps to apply appropriate safeguards when we transfer this data.

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Loyalty


EERUS.CAP undertakes to inform the Data Subjects of the conditions under which their Personal Data is processed and communicates at least the information necessary for the processing of the data collected.

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Transparency


EERUS.CAP undertakes to inform Data Subjects of the conditions under which their Personal Data is collected.

Quality

EERUS.CAP undertakes to respect the principle of accuracy and data minimization by collecting only the information strictly necessary for the achievement of the purposes.

The duration of the conversation

EERUS.CAP undertakes to retain Personal Data only for the period necessary to achieve the specified purposes and to comply with legal requirements.

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Communication

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EERUC.CAP ensures that it has an authorization policy in place to guarantee that only authorized persons have access to Personal Data. Subcontractors are subject to compliance with the commitments made by EERUS.CAP in terms of Personal Data Protection.
 

 

Internet network

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EERUS .CAP will not be responsible in the event of a malfunction of the Internet network preventing access to the site or proper navigation on it. EERUSC.CAP cannot in particular be held responsible for possible external malicious acts, errors of direction or redirection, lack of availability of information and/or the presence of viruses on the site.

Connection to this site implies knowledge and acceptance of the characteristics and limits of the Internet, the absence of protection of certain data against possible misappropriation or piracy and the risks of contamination by possible viruses.

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Intellectual property

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All rights of reproduction, representation and communication to the public are reserved, including for downloadable documents and visual, photographic, iconographic, audiovisual or other representations.

No license, nor any right other than that of consulting the site and playing and the games offered, is granted to anyone with regard to intellectual property rules.

The reproduction of all or part of the website on any medium by any process is strictly prohibited without express written authorization from EERUS.CAP.

The EERUS.CAP brands as well as the logos appearing on the site are registered trademarks. Failure to comply with the above constitutes an infringement and exposes the possible infringer to civil and/or criminal prosecution.



Other EERUS.CAP Terms, Third Party Terms and Links to Other Sites


Use of our services and products may be subject to other terms and representations that we or platform manufacturers and other partners provide, including: (i) the terms that accompany your purchase; (ii) the conditions applicable to the Online Services; (iii) other terms and representations made available to you by us or third parties. We are not responsible for the practices on third party sites that may be linked to the Services.


Contact us


If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer. You can also contact us or our Data Protection Officer by post at the addresses below. Please indicate your location in your message. You may also have the right to lodge a complaint with a privacy authority. You can also contact us by email at eeruscap@gmail.com .

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For the purposes of privacy laws, the controller of your personal data is EERUS.CAP. Depending on the Services, our labels and divisions may be considered data controllers, either with EERUS.CAP or alone. The information and contact details of the controller and representative are indicated here. References to EERUS.CAP in this Privacy Policy should be construed as references to the relevant EERUS.CAP entity identified as the controller of personal data for the particular Services you use.

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Privacy Policy Changes


We reserve the right to make changes to this Privacy Policy. Please check for these changes from time to time. If we modify this Privacy Policy in a material manner, we will notify you and, if applicable, provide you with additional choices regarding such modification. To the extent permitted by applicable law, your continued use of the Services means you accept these changes.

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