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Conspiracy TD
Privacy Policy

This Privacy Policy (“Policy”) describes how we collect, use, and share Personal Data about you during and after relationship with us when you play Conspiracy TD (“our Game”) and/or visit our website at www.conspiracytd.com.

In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Serbia`s Data Protection Law on 9 November 2018 (published in the Official Gazette of the Republic of Serbia, no. 87/2018) (“DP Law”), the European General Data Protection Regulation ("GDPR"), and only as described in this Privacy Policy.

Responsible Party and Controller
Conspiracy TD
Aleksandar Vascic Sole Proprietor
Novi Becej, Serbia

E-mail: conspiracytd@gmail.com

Data Subject Rights
In connection with our processing of your data, you have the following rights:

• Right to information
• Right to have inaccurate or incomplete Personal Data corrected
• Right to erasure
• The right to restrict processing
• Right to object to the processing
• Right to data portability
• Right to revoke consent
• Right to complain

Please direct all requests for information, requests for information or objections to data processing to us using conspiracytd@gmail.com

Relevant legal basis
In accordance with the DP Law and the GDPR, we inform you of the legal basis for our data processing. If the legal basis is not stated below, the following applies:

• the legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR,
• the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is Art. 6(1)(b) GDPR,
• the legal basis for processing in order to fulfil our legal obligations is Art. 6(1)(c) GDPR, and
• the legal basis for processing in order to protect our legitimate interests is Art. 6(1)(f) GDPR.

Automated Decision Making
Automated decision making is not used at Conspiracy TD.

Processing of special categories of data
No special categories of data are processed at Conspiracy TD.

Supervisory Authority
The competent data protection authority in Serbia is:
Commissioner for Information of Public Importance and Personal Data Protection (CIPIPDP),
15, Bulevar kralja Aleksandra str, Belgrade 11120
www.poverenik.rs

If you believe that the processing of your data is not lawful. You have the right to make a complaint at any time. We would, however, appreciate the chance to deal with your concerns before you approach the CIPIPDP, or any other Supervisory Authority, so please contact us in the first instance.
Hosting
To provide our website, we use the services of SuperHosting d.o.o. who process the below-mentioned data and all data to be processed in connection with the operation of this website on our behalf. The legal basis for the data processing is our legitimate interest in providing our web site in accordance with Art. 6 (1) f) GDPR.

Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your enquiry: Name, contact details -if provided by you- and your message. The legal basis of the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations in accordance with Art. 6 (1) b) GDPR and/or our legitimate interest in processing your enquiry in accordance with Art. 6 (1) f) GDPR.

When playing Conspiracy TD
We collect information about you when you play our game. This data may be required to enter into a contractual relationship with you or to perform a contract with you (such as to provide Service at your request), and failure to provide any data may result in our inability to play our game.

a) Data collected directly from you
You may provide us with the following Personal and Non-Personal Data:

• SteamID64(*), steamID, steam profile name, purchase history,
• device information, and records of the issues you experience to provide customer service,
• Player in-game nickname, scores, progress, settings, general player UI and in game interactions, player to player interactions(chat), playtimes
• hardware specifications like GPU and CPU type and used/free RAM memory with occasional performance logs(current frames per second and average frames per second for specific period)

b) Data collected automatically
We automatically collect the following Personal and Non-Personal Data:

• Device information (including but not limited to, IP address, device ID, device model, network type, OS version, time zone settings, battery status, screen resolution, etc.),
• Device event information, including crash reports and system activity details (e.g., whether you encountered an error using our services or lost internet access, etc.)

c) Information collected from third parties
We collect certain information from your Steam account as permitted by the terms of the Steam platform and your privacy settings on Steam.

When you play our Game, we or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security, authentication, or age verification purposes. We also may use other anti-cheat and age verification technology with our services.

d) Unreal Engine
Our Game is built using the game development platform Unreal (operated by Epic Games, 620 Crossroads Blvd., Cary, NC 27518, USA). This uses software modules and libraries that come from Epic Games itself or third parties and become an inherent part of our Game (called a game engine). During the execution of the Game, Personal Data may be processed by Epic Games itself, including device identification numbers (so-called UDID - unique device identifiers, IP address). Data such as the device type, country of app installation, advertising ID, sensor markings (e.g., from the pressure or acceleration sensor), game identification number (app ID) and the checksum of the transmitted data are also processed. You can find more information about data processing in Epic Games`Privacy Policy.

e) Your Use of the Steam Client and Websites
Our Game is offered on Steamoffered by Valve Corporation PO. Box 1688 Bellevue, WA 98009. We have no influence or control over how Valve Corporation processes your Personal Data. You can find more information about data processing in Steam`s Privacy Policy.

How we use your Personal Data
We use the collected Personal Data for a variety of purposes, primarily, to provide the Game and the website and to improve the quality of the game and website. This may include:

• Operating and providing the games and website,
• Providing customer service by collecting and responding to inquiries,
• Providing advertising information and other information on marketing and promotions,
• Solving technical problems and improving the quality of the game,
• Identification of individual players to provide the game,
• Technical protection against usage of unauthorized programs,
• Prevent, detect, identify, investigate, and respond to cheaters and potential or actual claims, liabilities, prohibited behavior, and criminal activity, and

Data Security
We secure your data through appropriate technical and organizational measures against loss, destruction, access, modification, or distribution of your data by unauthorized persons. However, and despite regular checks, complete protection against all dangers is not possible.

Passing on of data
Your Personal Data will only be passed on to third parties,
• if you have given your express consent to this;
• if the disclosure is necessary for the fulfillment of contractual obligations;
• if we are legally obligated to disclose the data;
• if the disclosure of the data is in the public interest;
• if the disclosure of the data is necessary for the protection of our legitimate interests or the legitimate interests of a third party, unless your interests in the protection of your data override these interests.

Third Party Recipients
In order to be able to provide our Game and website, we may have to pass on your Personal Data to third party recipients. Third party recipients may be our suppliers, service partners and our trading partners as described in this policy or for the enforcement of a lawful order issued for example by a court, the police, or a regulatory authority. If your Personal Data is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Data. For certain countries we process the data in certain regions (as set out in more detail below).

Duration of storage of Personal Data
Your data will be stored by us for as long as it is needed for the respective purposes underlying the processing and for 12 months beyond that point. After that, we only store data insofar as we are legally obligated to do so, e.g., due to statutory retention obligations.

Personal Data of children
We do not knowingly collect, use or share any information about children under the age of 16 without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.

Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Site. You will be deemed to have accepted such amendments by continuing to use the Service, so please review it frequently.

Validity and questions
This privacy and cookie policy is valid as of Wednesday, 14 February 2024. It is the current and valid version of our privacy policy. However, we point out that from time to time due to actual or legal changes a revision to this privacy and cookie policy may be necessary. If you have any data protection questions, please feel free to contact us using the details provided above.