Privacy Policy

Hello, KSS user! This Privacy Policy is where we explain what information is collected when you’re using KSTORMSTUDIO.COM, how it is collected, how we use that information, where we store it, and how we protect it. We will also explain your rights in relation to the information.

WHO WE ARE

We are K-STORM-STUDIO LTD., a company registered in UK (we will further call ourselves “KSS”).

WHAT THIS PRIVACY POLICY GOVERNS

This Privacy Policy applies to KSTORMSTUDIO.COM, your KSS user account, any games or videos or other content which you purchase, access or use via KSTORMSTUDIO.COM, the ‘KSS Wallet’, KSS payment methods, the KSS web forums, KSS customer and technical support and any other services we provide to you (we’ll just call all this “KSS services” for short).

Specifically, this Privacy Policy governs personal information and non-personal information which we collect from you when you’re using KSS services. (“Personal information” means information which, on its own or in combination with other information, can be used to identify you).

We respect your right to privacy and will only process personal information in accordance with applicable data protection legislation in the UK, EU, the USA (including the Children’s Online Privacy Protection Act) and elsewhere.

KSS works with trusted partners, developers and publishers, payment providers, customer service software providers and others (“Trusted Partners”) – more on them later in this Policy.

PROTECTING CHILDREN

We recognise we have a special obligation to protect personal information obtained from children. We do not and will not knowingly collect personal information from any child under the age of 16. If for any reason we decide to collect personal information of children between 13 and 16 we will ask for their parent or guardian consent. If you are a parent or guardian’s and are concerned about the transfer of personal information about your child, please contact us.

INFORMATION WE COLLECT

When you register a KSS account with us, you will need to provide us: (a) your username; (b) your email address; and (c) a password (which is encrypted so that we don’t have access to it). This information is necessary for us to provide you with a KSS account requested by you. In your KSS account settings you can also set your date of birth, avatar, your geographical location and many others. This information will be protected by your KSS account password. You are responsible for keeping it safe – please don’t share it with anyone.

When you use KSS services we may also collect the following information (how we use it is described later in this document):

We may also collect additional information when you use other KSS services (see opposite).

• (a) Technical details about devices which you use to access KSS services, including: Internet and/or network connection (including your IP address); mobile device identifiers; your operating system, browser type or other software; your hardware details; or other technical details provided by your web browser. This is technical data about our users and their actions and patterns, which does not provide personal information;
• (b) Details of your use of KSS services including, but not limited to: metrics information about when and how you use KSS services (such as what game(s) you are playing, what asset you’re downloading or uploading, your current status, your interactions with others); order status; order ID; traffic data; your geographical location; your purchase history; game library; emails received; and links accessed; your preferences and choices such as subscriptions, preferred language and currency; your friend lists on KSS; your communication via chat, game reviews, published posts on forum and other KSS services;
• (c) Other information required in order to help you with any queries/support you may need assistance with via the KSS forums or customer support, including communications with you;
• (d) limited payment processing information, including as applicable your credit card number, name and email address (on a hashed/anonymised basis as applicable), payment methods, payment engine and transaction type; fraud risk score;
• (e) if you use Facebook Connect or Google Connect we may also collect limited information through Facebook Connect and/or Google Connect such as your Facebook ID, avatar, e-mail and friend list;
• (f) if you purchase content via a third party platform which uses our KSS Direct to Account API, the platform may share data with us such as your platform ID, order details or your IP address;
• (g) any other information which you supply us via our services;

A quick word about bug reports and crash logs: KSS software will generate bug or crash reports regarding KSS services – these reports will not mention your personal information. You can decide whether to submit these reports to KSS automatically. If you manually submit bug or crash reports to us, or if we contact you asking for feedback regarding crash or bug reports, then we may store them alongside your personal information.

If KSS services crash, we might ask you to send us crash logs/bug reports.

A quick word about payment details (if/when you use them in KSS services): this is a matter for the relevant payment method/platform/processor. We process only limited payment processing information on a hashed/anonymised basis as applicable. If you make any purchases within KSS services, then we are notified by the payment processor once a transaction takes place and of course we make sure you receive your purchased item, but we will not receive any of your actual payment details.

HOW WE COLLECT INFORMATION FROM YOU

We may collect, process and use information about you in the following ways (either directly or via our Trusted Partners as explained above): (a) information you give us via KSS services; (b) information given when you contact us or report a problem with KSS services; (c) through our API which allows third party platforms to sell content which is activated by KSS (“KSS Direct to Account API”); (d) we may also ask you to complete surveys that we use for research purposes, although you don’t have to respond to them. We may collect this information via KSS services or trusted third parties connected with us for optional things like surveys or polls.

We will collect the information ourselves or via third parties when it comes to optional things like surveys, KSS Connect or authentication services like Facebook Connect.

5.2 Facebook Connect and/or Google Connect. When you register for KSS services via Facebook Connect (of course, it’s optional), Facebook will provide us with certain information about you such as your Facebook ID, avatar, e-mail, gender, location and friend list. Data is gathered strictly in accordance with the social network(s)’ terms and conditions, so check your privacy settings on Facebook. The same rules will be applied in case you register for KSS services via Google Connect.

COOKIES

We also collect information about you via cookies. You can find out more about this in our Cookie Policy here. The Cookie Policy and Cookie Declaration are a part of this Privacy Policy.

WHY DO WE USE YOUR DATA?

When we process information about you, we do so as necessary to provide KSS services you use, meet our legal obligations (f.ex. tax, accounting) or to fulfill the so-called “legitimate interests” of KSS or other reasons described in the “How we use your data” section. To clarify, by legitimate interests we mean lawful purposes that could be reasonably expected (like informing you about games we distribute and making sure our marketing is relevant for you, protecting the security of our websites and systems, conducting anti-cheat analysis and anti-fraud checks). When we rely on the legitimate interest, we consider and balance any potential impact on you and your rights. For other purposes we will ask for your consent and you will be entitled to withdraw this consent any time, with no impact on the validity of the processing before your consent has been withdrawn.

HOW WE HANDLE YOUR INFORMATION

All information you provide to us is stored on our secure servers or those of our Trusted Partners. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage.

All information you provide to us is stored either on our secure servers or those of our Trusted Partners.

How long are we going to keep your data? We will retain your personal information only for as long as we will be required in order to fulfil the purposes outlined in this Privacy Policy. In certain special cases, a longer retention period might be required by law e.g. tax, accounting purposes or other legal requirements and obligations. As soon as we will no longer require your personal data to provide our services for other purposes mentioned above, we will promptly delete or anonymize it. In particular:

• (a) we will keep information that is associated with your KSS account for the duration of your agreement for the access to KSS services (i.e. until you close your KSS account). If you choose to close your KSS account, limited data that we collect about you may still be retained for tax, legal and accounting purposes;
• (b) if you don’t have a KSS account and contact us we will retain correspondence with you as long as necessary to help you out and then for the period necessary for legal or accountability purposes;
• (c) information that you post on our public forums and your game reviews will be retained until you decide that it should be removed as well. We don’t want to interfere with your posts and expressions without your permission.

HOW DO WE USE YOUR INFORMATION

We will use the above information in the following ways:

• (a) to carry out our obligations arising from any contracts between you and us, like providing access to your KSS account, providing you with the games, assets and technical support and in general allowing to use KSS services and its functionalities when you choose to do so f. ex. your KSS user profile, chat, forum or cloud saving;
• (b) to ensure that KSS services are presented in the most effective manner for you and for your computer or other device from which you access KSS services;
• (c) to provide you with information, products or services that you request from us and which we feel may interest you – in particular, we may send you newsletters or emails about KSS services, special and occasional offers like a welcome offer or provide you with ads, offers and product recommendations on the basis of your purchases or activity on our and third party websites and services.
• (d) to activate content on your KSS account through our Direct to Account API;
• (e) to evaluate the effectiveness of our marketing actions and improve the quality of our marketing;
• (f) to notify you about changes to KSS services and our legal documents;
• (g) to improve or modify KSS services, f.ex. based on which games, assets or contents you like, how you play them, reported problems, your suggestions or satisfaction surveys;
• (h) to improve or modify KSS services, for example based on which games you like more and how you play them;
• (i) to calculate conversion rates and other elements of KSTORMSTUDIO.COM performance;
• (j) in connection with the services of our Trusted Partners, such as payment processors, located in and outside the UK, but only to the extent necessary to provide those services;
• (k) to provide you with optional functionalities such as KSS Connect or authentication via Facebook account or Google account;
• (l) to create a universal user’s profile based on information about your use of KSS services and other platforms (we’ll rely on data made available when you merge your KSS account with your account on other platforms) in order to make our Services even more interesting for you;
• (m) to protect you from an unauthorized use of your account and against fraud;
• (n) for tax, legal and accounting purposes;
• (o) for the accountability purposes as defined by EK legislation (GDPR); and

Non-personal data. We might process some aggregated and general non-personal data on user behaviour (e.g. sales per region, number of support tickets) and share it with Trusted Partners who work with us to provide KSS services to you (for example, with games or assets developers/publishers selling games and assets on KSTORMSTUDIO.COM or with payment providers) in order to support, improve or amend KSS services or to help them to improve their products, which you have bought. We may also share non-personal information with data analysis services to help us run KSTORMSTUDIO.COM. Fear not, as mentioned above, everything’s anonymised, so you cannot be identified.

DATA SHARINGS

Other Users

Some elements of your personal information and some information about your use of KSS services are accessible to other KSS users. For example: other users of KSS services will be able to see your username and avatar (if you choose to have one). We may also display other information derived from your activity on KSS services. We do this to help KSS users to find gamers with similar tastes and to build the KSS user community. You can manage the privacy settings of your KSS user profile in your KSS account.

Some information about you will be visible on KSTORMSTUDIO.COM as a part of your KSS user profile..

How you use your information. Please remember that any communications you have via KSS services (e.g. via private messages, chat or the KSS forums) may reveal your screen name, other details about you and the content of any communications by you with other users. Also, any information and content you share publicly using KSS services (e.g. on our forums or your KSS user profile) will be accessible to KSS users and others. Consider carefully with whom you share your information and avoid sharing contact or private information about yourself.

Our Trusted Partners

In general, we do not disclose information about you to third parties without your consent. We may share your data only with the following categories of third parties who were engaged by us to help deliver our services and functionalities to you (they are formally called “Data Processors”). When we provide your information to these Trusted Partners, their use and disclosure of it is subject to limitations in our agreements with them:

• Customer support partners that provide us with software and support ticket system to help us managing your customer support requests;
• Advertising and advertising measurement partners to facilitate targeting, delivery and measurement of online advertising on third-party services (such as Google Adwords) or that provide us with email delivery tools (such as GetResponse);
• Third party vendors that provide us with analytical tools for KSTORMSTUDIO.COM;
• Third party vendors that provide us with error tracking and crash reporting tools;
• Third party platforms that may sell content which is activated by KSS using our Direct to Account API;
• Third party network providers to optimize delivery of KSS content you requested (we share only your IP address and the identification of KSS content you wish to access);
• Data storage partners: we may store some of your information using third-party data storage services, e.g. for cloud saves, we may use Google services to run surveys on KSTORMSTUDIO.COM;
• Our professional advisors dealing f.ex. with legal, tax, audit or accounting matters.

In general, we don’t share information about you with third parties. There are exceptions like our Trusted Partners that help us do our thing. They usually help us with things like data analytics, processing payments, internal tools or running a variety of marketing activities.

During the payment process, we may also share information about you with the following categories of third parties who handle it independently as the so-called data controllers:

• payment-providers for payment processing purposes;
• banks and financial institutions to obtain payment;
• anti-fraud service providers;

Some forms on this site require the use of Google’s reCAPTCHA service before they can be submitted. This plugin checks if you are a person in order to prevent certain website functions from being (ab)used by spam bots (particularly comments). Use of the reCAPTCHA service is subject to the Google Privacy Policy and Terms of Use.

Your information may be processed, stored and transferred outside your country of residence and beyond the United Kingdom, such as Europe, the United States, Canada or Brazil. Privacy laws in these countries may not offer the same level of protection as in your country. But whenever we’re sharing your personal information outside the UK, we will do so on the basis of the UK standard contractual clauses and/or other lawful measures to transfer your data and establish adequate protection of your personal information

THIRD PARTY INFORMATION COLLECTION AND EXTERNAL SERVICES

KSS services may, from time to time, contain links to and from the websites or services of third parties (e.g. to games and assets developers whose games, assets and/or contents are on KSS). In addition, third parties (e.g. games developers/publishers) may also collect personally identifiable information (e.g. your email address or name) if you want to access additional game services, but they can collect any such information only after you have been informed of it and consented to it. This may include saving information to your KSS profile in relation to their games (such as, for example, saving game progress). Our Privacy Policy does not extend to these external sites or companies, so please refer directly to their privacy policies.

OTHER STUFF

Please be aware that we are subject to various laws and we may be required to release personal information to comply with law enforcement or other legal requirements.

In the unlikely event of a reorganisation or merger of KSS or KSS accounts we may transfer personally identifiable information to an involved third party who will protect this to at least the same level as we do in this Privacy Policy.

YOUR RIGHTS

You have the right to object to the processing of your personal data in certain situations f.ex. for marketing purposes at any time. You can do so by contacting us, here or by changing your email settings within your KSS account. Also email communications from KSS to you will contain an opt-out/unsubscribe option.

Know your rights! These include the right to know how your personal information is being used, access to the data itself, the right to alter it, transfer, restrict how we use it, or just have it all deleted.

You may have additional privacy rights (see opposite).

If you have any concerns about your privacy please contact us first. If however you feel we have not dealt with your concern you can report this to your local data protection authority.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy if we think it’s necessary for legal reasons or to reflect changes in KSS services. If so, we will make the changed Privacy Policy available online and (if you have a KSS account). We will also update the “Last Updated” date.

USER AGREEMENT

We’d also like to remind you that our User Agreement has more information about how we operate KSS services and it has a number of sections which apply to this Privacy Policy too. You can read it at User Agreement.