PRIVACY POLICY

STORM WARFARE is an online game that offers users the chance to play, purchase, collect, and showcase digital blockchain collectibles (collectively referred to as the "game"). The application is proprietary to JANUS INTERAKTIF STUDYO YAZILIM A.S. ("Company," "we," or "us" etc.). This privacy policy (this "Policy") outlines how we collect and process personal information about you when you visit our website at https://www.stormwarfare.com, sign up for or use/play GAME, or otherwise engage in business or contact us.

At every phase of data collection, utilization, and disclosure, we employ physical, electronic, administrative, and procedural safeguards to safeguard the personal data entrusted to us. However, it's important to note that no transmission of personal data over the internet can be guaranteed to be completely secure. Despite our best efforts, we cannot assure or warrant the security of any information you transmit to us or from our online services. Therefore, we bear no responsibility or liability for the security of information transmitted via the internet.

This Policy outlines how we collect, use, disclose, process, and manage your personal data. It applies to all personal data belonging to individuals that are in our possession or under our control.

By accepting this Policy, you are familiarized yourself with this Policy, understood and are agreeing with the terms and practices described in this Policy (including new versions of this Privacy Policy when and as they come into effect), and the Terms, which govern this Policy and contains all disclaimers of warranties and limitation of liabilities. If you do not agree to this Policy, please do not further access or use the Platform and the Services.

HOW WE COLLECT INFORMATION

We collect personal information concerning you from certain sources to provide the Services and manage our Platform. We also obtain information from you and from Third Parties as detailed below;

Collection Sources: We gather personal information from various sources to provide Services and manage our Platform, including direct interactions with you and data obtained from third parties.
User Interactions: Information is collected when you engage with our Platform or Services, such as visiting our website, playing our game, making purchases, registering an account, subscribing to newsletters, participating in contests, surveys, or contacting us.
Third-Party Service Providers: We utilize third-party service providers to perform certain Services on our behalf, ensuring they comply with applicable laws and regulations and use personal information solely for designated purposes.
Third-Party Analytics and Advertising: Third-party tools are employed to analyze Platform usage and optimize Services effectiveness. These tools may utilize technologies like cookies and web beacons to collect and store information, often combining it with data from other sources.
Third-Party Social Media Integration: Personal information may be collected from social media platforms and networks used in connection with our Platform, subject to their privacy policies. Data obtained may personalize content and synchronize online progression across devices.
Cookies and Automatic Collection: Information about online activities on the Platform and connected devices may be collected over time. This typically involves automatic collection methods such as cookies, web beacons, and website log files. These methods are detailed in our Cookie Policy section.

TYPES OF INFORMATION WE COLLECT

Personal Information that We Collect from You

While using our Platform or Service, you may provide us with certain personally identifiable information that can be used to contact or identify you. Personally, identifiable information may include, but is not limited to;

Personal Information: This may include your name, gender, contact details, social media profile information,
Email Address: We may collect your email address for communication purposes.
Digital Assets Information: Details regarding digital assets held by you may be collected.
Digital Wallet Details: Particulars of digital wallet addresses, including transactions performed by said digital wallet addresses, and public cryptographic keys related to digital wallet addresses on distributed ledger networks or similar information, may be recorded.
User Interaction Information: Information about your use of our services and website, including specific user interactions such as utilized features, visited areas, clicks, and time spent on the website, may be logged.
Account Credentials: Usernames, passwords, third-party account credentials (e.g., Apple login credentials, Google login credentials), Internet Protocol (IP) address, and geographical location may be collected.
Technical Information: Browser type and version, operating system, internet service provider, referrers (websites from which you reach our website), mobile device ID, location of access, or other similar technical data may be gathered.
Behavior and Diagnostic Data: Data regarding pages visited (including sub-pages), time and date of visit, time spent on each page, and other diagnostic data may be recorded.
Personal Opinions: Any personal opinions made known to us, such as feedback or responses to surveys, may also be collected.

HOW WE USE PERSONAL INFORMATION

We use the information that we collect/obtain to conduct our business and to provide you with the best possible Services and experiences. We rely upon several legal grounds to ensure that our use of the information we collect/obtain is compliant with the applicable laws. We use the information to facilitate the business relationships we have with you, to comply with legal obligations, and to pursue our legitimate business interests. These activities may include, but are not limited to, the following:

Developing and providing products or services, including registering your account for processing registration and delivering agreed-upon services (including game-related services).
Providing services related to trading and/or holding of digital assets, both fungible and non-fungible.
Targeted advertising to deliver relevant advertisements and offers, as well as measuring their effectiveness.
Conducting digital marketing and advertising campaigns, including promotional communications and paid advertisements, while measuring campaign effectiveness.
Offering various products and/or services, whether digital or otherwise, whether provided through an external service provider or otherwise.
Managing contests, prize draws, and tournaments, including processing entries and potentially awarding prizes or rewards.
Addressing, investigating, or responding to feedback, queries, complaints, claims, or disputes related to the services.
Compliance with applicable laws, regulations, rules, directives, orders, instructions, and requests from local or foreign authorities, including regulatory, governmental, tax, and law enforcement authorities.
Facilitating evaluation of any proposed transaction by any actual or proposed assignee, transferee, participant, or sub-participant of our rights or obligations.
Enforcement of obligations owed to us, protection of our rights or property, and protection against legal liability.

HOW WE SHARE INFORMATION

We may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To a buyer or other successor in the event of a merger, reorganization, dissolution, or other transfer or sale of some or all of Company’s assets.
To fulfill the purposes for which you provide it.
With your consent.

We may share your personal information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; (v) protect our rights, property or safety, our Users, and the public; or (vi) fulfill our obligations arising of or in connection with the contracts with Users.

We share personal information with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, data analysis, information technology, and related infrastructure. These Service Providers may need to access personal information to perform their services. We authorize such Service Providers to use or disclose personal information only as necessary to perform Services on our behalf or comply with legal requirements. We require such Service Providers to contractually commit to protect the security and confidentiality of personal information they process on our behalf. Our Service Providers are predominantly located in the European Union and the United States of America.

We may disclose information in the aggregate form to Third Parties in cases such as to help with auditing interactions and transactions with you, addressing security, fixing errors, helping us with advertising or marketing, maintaining accounts, helping with our internal research, verifying service quality or safety, and performing any of the other actions or activities allowed under this Policy.

We may share personal information with Third Parties we work with for our purposes, though in general, we do not share personal information about you with Third Parties for Third-Party marketing or advertising purposes. For information about the choices you have about the online advertising practices described in this section, please see the “Exercising Your DPA Privacy Rights”, " Exercising Your GDPR Privacy Rights" and “Exercising Your California Privacy Rights“ sections below.

Third Parties are prohibited from using personal information for any other purpose and are contractually required to comply with all applicable laws and requirements.

We will encourage Third Parties we collaborate with to adopt and post transparent privacy policies. However, the use of your personal information by Third Parties is governed by their privacy policies and is not under our control. You acknowledge that we are not responsible for the violations caused by Third Parties.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share personal information with third parties for the purpose of facilitating and completing the transaction.

We share personal information when it is necessary: (i) to comply with applicable laws; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety, and property of the Company, you, or others; and (iv) to respond requests of the courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your jurisdiction.

BRITISH VIRGIN ISLANDS PRIVACY INFORMATION

You should know that your personal data may be transferred from your home country to third parties. If you are a BVI resident, this could imply that we also transfer data to countries that do not offer an adequate level of protection for your personal data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to get a copy of the safeguards that we have put in place. Our contact details are at the end of this Policy.

Your Rights Under the DPA

We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights properly.

You have the right under this Privacy Policy to:

Right of Access: You have the right to obtain confirmation from us as to whether Personal Data concerning you is processed, and, where that is the case, you have the right to request and get access to such Personal Data.

You have the right to obtain information on following;

Whether your Personal Data is processed by us or on behalf of us
A description of your Personal Data in a form
The purposes of the processing of Personal Data
The Personal Data recipients or group of recipients
Where the Personal Data is transferred to if it is transferred outside of the British Virgin Islands
How do we ensure the integrity and confidentiality of the Personal Data

Right to Rectification: You have the right to request rectification by us of inaccurate Personal Data and you have the right to provide additional Personal Data to complete any incomplete Personal Data as required by the Company

Right to Prevent Processing for The Purpose of Direct Marketing: You have the right to require that processing of Personal Data for the purpose of direct marketing ceases or does not begin.

Right to Complain: You have the right to complain to the Information Commissioner regarding alleged contraventions of the Act.

Right to Bring Civil Proceedings: You have the right to bring civil proceedings to the British Virgin Island High Court for damage or distress caused by contravention of the Act.

Exercising Your DPA Rights

You may exercise your rights on written request by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If your request is valid, we will provide information within 30 days. You have the right to file a complaint with the Information Commissioner.

EUROPEAN UNION PRIVACY INFORMATION

You should also know that your personal data may be transferred from your home country to third parties. If you are an EU resident, this could imply that we also transfer data to countries that do not offer an adequate level of protection for your personal data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to get a copy of the safeguards that we have put in place. Our contact details are at the end of this Policy.

Your Rights and Choices Under the GDPR

We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights properly.

You have the right under this Privacy Policy, and by law, if you are within the EU, to:

Right to Erasure (“Right to be Forgotten”): In certain cases, you have the right to request from us the erasure of your Personal Data. For the avoidance of any doubt, we may not be able to grant this right to you in certain cases, due to our obligations to fulfill certain legal requirements.

Right to Restriction of Processing: You have the right to request from us a restriction of processing, for a certain period and/or for certain situations.

Right to Data Portability: You have the right to receive your Personal Data from us in a structured format and you have the right to (let) transmit such Personal Data to another controller.

Right to Object: In certain cases, you have the right to object to the processing of your Personal Data including regard to profiling. You have the right to object to the further processing of your Personal Data in so far as such data has been collected for direct marketing purposes.

Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.

Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our processing of your Personal Data.

Right to Compensation of Damages: In case we breach applicable legislation on the processing of your Personal Data, you have the right to claim damages from us for any damages such breach may cause to you.

Exercising Your GDPR Privacy Rights

You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If You make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (the “EEA”), please contact your local data protection authority in the EEA.

CALIFORNIA PRIVACY INFORMATION

The following section sets forth privacy information relevant to residents of California, including your California Privacy Rights and Choices.

Your Rights and Choices Under California Privacy Law

Under this Policy, and by law, if you are a resident of California, you have the following rights:

Right to Notice: You must be properly notified of which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
The Right to Access / Request: The CCPA permits you to request and obtain from the Company information regarding disclosure of your Personal Information that has been collected in the past 12 (twelve) months by the Company or its subsidiaries to a third party for the third party's direct marketing purposes.
The Right to Say No to the Sale of Personal Data (Do not Sell): You have the right to ask the Company not to sell your Personal Information to third parties. You can submit such a request by visiting our Platform and contacting us through the channels, features, and functionalities provided on the Platform and this Policy.
The Right to Know about Your Personal Data: You have the right to request and obtain from the Company information regarding the disclosure of the following:

The categories of Personal Information collected
The sources from which the Personal Information was collected
The business or commercial purpose for collecting or Selling the Personal Information
Categories of Third Parties with whom we share Personal Information
The specific pieces of Personal Information we collected about you

The Right to Delete Personal Data: You also have the right to request the deletion of your Personal Information that has been collected in the past 12 (twelve) months.
The Right Not to be Discriminated against: You have the right not to be discriminated against for exercising any of your rights as a consumer, including the following:

Denying providing Services to you
Charging different prices or rates for Services, including the use of discounts or other benefits, or imposing penalties
Providing a different level or quality of Services to you
Suggesting that you will receive a different price or rate for products or Services or a different level or quality of products or Services.

Exercising Your California Privacy Rights

In order to exercise any of your rights under the CCPA, as a California resident, you can contact us through channels, features, and functionalities (i.e., email address, phone number, interactive customer support chat, contact form) provided on the Platform.

Once we receive your request, we will validate the information that you provide and send a message to the email address you provide in the request, asking you to verify that it is your email address. Please follow the instructions in that email to verify your email address. We will begin processing your request once you verify your email address.

The Company will disclose and deliver the required information free of charge within 45 (forty-five) days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Please note that if you do not include necessary information concerning you in your requests, we may ask you to verify your identity before responding to such requests.

Do Not Sell My Personal Information

We may continue to collect and share personal information about you with Third Parties as described in our Policy if that sharing is not a "sale" of personal information, such as to continue to provide Services to you.

We do not provide personal information about you to Third Parties in exchange for money. We do share personal information with Third Parties that we work with, including to help us market or advertise our Platform and Services to you and mostly with regard to your prior consent. When this information is in a format that directly identifies you by name, it is generally not shared with any Third Parties for Third-Party marketing or advertising purposes. You can find more detail about our practices in our Policy, set forth under the "Marketing and Advertising Activities" section.

Even though we do not provide personal information to these Third Parties in exchange for money, the CCPA may characterize our providing the following categories of information we share with Third Parties that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our Platform and Services to you, as "sales" of personal information; (i) Device and browsing information and other internet activity information; (ii) purchase or other commercial information; and (iii) identifiers.

The Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA.

If you wish to opt-out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below;

You can opt-out of Selling your personal information to the extent prescribed under the CCPA, by adjusting settings using each Device and browser you use with this Platform.

The opt-out will place a cookie on your Device that is unique to the browser you use to opt-out. If you change browsers or delete the cookies saved by your browser, you will need to opt-out again.

Please note that any opt-out is specific to the browser you use. You may need to opt-out on every browser that you use.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some Third-Party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain the removal of content or information they have publicly posted.

We do not knowingly process the personal information of California residents under the age of 18. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us.

YOUR COMMUNICATIONS CHOICES

You may receive marketing and advertising communications about the Company, the Platform, the Services, and our games if you provide clear consent. To receive marketing and advertising communications from the Company, you can sign up on our newsletter, contact us, or give your clear consent in the applicable areas. We provide our Users with the opportunity to "opt out" of receiving marketing and advertising communications. We provide you with the following options if you prefer to "opt out" of receiving information or materials that we think may be of interest to you:

At all times, you have the option of "opting out" of receiving marketing and advertising emails from the sender only by clicking the "unsubscribe" link in any of the marketing and advertising emails you receive. In addition, if you have an online account, you may change your email preferences regarding email from us by logging into your account.
In all cases, you may email us at privacy@janusinteractive.co.uk

SECURITY

We are making reasonable efforts to provide you with an appropriate level of security at the risk associated with the processing of your personal information. We take organizational, physical, technical, and administrative measures to safeguard your personal information against unauthorized access, destruction, loss, alteration, or abuse. Your personal information may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have a reason to believe that your interaction with us is no longer secure (for example, if you think your account is compromised), please contact us immediately.

Taking into account the nature, scope, context, and purpose of the processing, we have taken the following technical and organizational measures including without limitation to:

Access to our database and user accounts by hird-Party Service Providers is protected with access control.
Access to the database is limited, not all staff in our organization have full access.
Data sent from our games is encrypted in transit where technically possible. We do not actively monitor the security of our databases and need to rely on our processors to notify us of any data breaches.
RETENTION

Your personal information may be retained for as long as is reasonably necessary to perform the purposes listed under the "How We Use Information" section. For example, if you register an online account with us, we will store any personal information associated with your account for as long as you remain a User or we believe we may be in a position to provide Services to you. If you make a purchase, we will store any personal information associated with that purchase as long as required to fulfill the order, remember your preferences for future interactions, or be able to provide you with Services as well as to be able to fulfill our legal obligations.

We also retain personal information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners, and where data retention is mandated by the payment methods that we support, or by the applicable laws.

The servers and databases in which information may be stored may be located outside the country from which you accessed the Services and, in a country, where the data protection and other laws may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial processes in the countries in which we operate.

Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable laws.

COOKIE POLICY

Cookies are small text files stored in a Device’s web browser memory. They help website providers with things like understanding how people use a website, remembering a user’s login details, and storing website preferences. This article explains how we use cookies and other similar technologies to help us ensure that our Services function properly, prevents fraud and other harm, and analyze and improve the Services in accordance with our Policy.

How We Use Cookies

Cookies play an important role in helping us provide personal, effective, and safe Services. We use cookies on our Website. We change the cookies periodically as we improve or add to our Services, but we generally use cookies for the following purposes:

To Operate Our Website: Some cookies are essential to the operation of our Website and Services. We use those cookies in several different ways, including:

Authentication
Security
Functional
Preferences/Features/Services

To Analyze and Improve Our Services: Cookies help us understand how to make our Website and Services work better for you. Cookies tell us how people reach our Website, and they give us insights into improvements or enhancements we need to make to our Website and Services.

For Better Advertising: Cookies can help us provide more effective advertising on our Website. For example, we might use a cookie to help to prevent you from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.

How We Use Other Technologies

Third-Party Analytics: We use Google Analytics which uses cookies and similar technologies, to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information regarding the use of other sites, apps, and online resources. You can learn about Google’s practices on its website. Please refer to the table below for more on how we use Third-Party analytics.

How to Manage Cookies

Your web browser may allow you to change your cookie preferences, including deleting and disabling cookies. Please consult the “help” section of your web browser to understand your options, but please note that if you choose to disable the cookies, some features of our Website or Services may not operate as intended.

INTERNATIONAL DATA TRANSFERS

We are a global business. Personal information may be stored and processed in any country where we have operations or where we engage Service Providers. We may transfer personal information that we maintain about you to recipients in countries other than the country in which the persons’ information was originally collected. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.

USE BY MINORS

Our Platform is not intended for children under 18 (eighteen) years of age. No one under the age 18 may provide any personal information to or on the Platform. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Platform or on or through any of its features/register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of this Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we find out we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at info@janusinteractive.co.uk

UPDATES TO THIS POLICY AND NOTIFICATIONS

We may change this Policy from time to time to reflect new services, changes in our personal information processing practices, or applicable laws. The “Last Updated Date” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Platform. If we change our practices in a way that requires revising this Policy in a material way, we will provide appropriate notice to you. We may provide you with disclosures and alerts regarding the Policy or personal information collected by posting them on our Platform and, if you are a User, by contacting you through your email address.

LINKS TO OTHER WEBSITES

The Services or Platform may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.

JURISDICTION

The Company focuses on multinational compliance regulations including but not limited to United States Privacy Law and, the GDPR to make sure privacy is a “go-to” rather than a thing to be worried about. You have the right to request further information on our personal information processing activities based on your country's jurisdiction.

We welcome you to reach out if you have any questions or concerns regarding our privacy practices or to request a copy of this Policy in another format. Please feel free to contact us via;
Email: info@janusinteractive.co.uk