Game Privacy Policy (“Game”)

We are Aonic AB (Publ),  a public limited liability company incorporated in Sweden with its registered office at Västra Trädgårdsgatan 15 111 53 Stockholm, Sweden, and registration number 559335-7527  (“Megabit”, “we” or “us”), and we are a video games publisher.

Where we decide the means or purpose of processing your personal data, we are the “controller."

This notice explains how we process personal data, as a controller, relating to individuals that play Grit and Valor - 1949 (“Game Players”). “You” and “your” shall refer to any Game Player.

We update this notice from time to time, so you should check back in on a regular basis.

Please note that other websites or services mentioned in the Game are not operated by us, and you should refer to the privacy notices on those websites to understand how they process personal data.

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: dataprotection@megabit-publishing.com.

If we can’t resolve your issue, and you:

• are based in the UK, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns;
• are based in Sweden, you can also get in touch with the Swedish Authority for Privacy Protection: imy@imy.se; or

are not based in the above countries, you can submit a complaint to the supervisory authority in your country.

Game Players have the following rights, although these rights may be limited in some circumstances:

• ask us to send a copy of your personal data to you or someone else
• ask us to restrict, stop processing, or delete your personal data
• object to our processing of your personal data
• object to use of your personal data for direct marketing purposes
• ask us to correct inaccuracies in your personal data

If we rely on consent to process personal data, you can withdraw consent by email to the email address below.

GAMEPLAY ANALYTICS

PURPOSE - We process certain information relating to Game Players who are accessing the Game to: (i) understand where they are based and how they play our Game; (ii) improve, test and monitor the quality and delivery of the Game; and (iii) identify and correct any problems in the Game (such as bugs or problems preventing in-Game progression).

CATEGORIES OF PERSONAL DATA – When Game Players play the Game, we directly collect information from them relating to:

• IP address
• Unique installation-specific ID
• User ID
• IDFV
• Their gameplay settings when playing the Game, and how they play the Game.
• Their in-Game achievements and events (including their score, rank and accuracy).
• How long and when they play the Game (including total game time and total session times).
• The geographical location of the device which they are using to play the Game.

LEGAL BASIS – We process this data where we have Game Players’ consent to do so.

RECIPIENTS – Unity Analytics, part of the Unity Gaming Services platform

HOW LONG WE KEEP THIS INFORMATION FOR - This information will be retained for 13 months from the day in which it is collected.

Storage & Transfers

We may disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies). Legal basis: our legal basis for this processing is likely to be: compliance with legal obligation or legitimate interests in: (i) obtaining advice in relation to legal and similar proceedings, (ii) communicating with relevant third parties in relation to legal and similar proceedings; and/or (iii) protecting and defending ourselves from legal and similar proceedings.
• With members of our corporate group, suppliers and subcontractors, as necessary for the purposes (and on the legal basis) set out in this notice.
• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you. Legal basis: our legal basis for this processing is likely to be: our legitimate interests pursued would typically include our interest (and that of our shareholders) in negotiating and concluding the relevant transaction, and our interest (and that of our users) in financing the business and ensuring the development and continuity of the Services.