Privacy Policy


Hello, Cefirus user! This Privacy Policy is where we explain what information is collected when you’re using Cefirus.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. If you have any queries you can contact us at contact@cefirus.com. Here we go…
1. WHO WE ARE

We are Cefirus S.L., a company incorporated in Spain (we will further call ourselves “Cefirus”).

You can contact us via email at contact@cefirus.com .
2. WHAT THIS PRIVACY POLICY GOVERNS

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

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

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

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

2.5 For personal information contained in this Privacy Policy which is used by Cefirus, Cefirus is the data controller under EU data protection legislation.
3. PROTECTING CHILDREN

3.1 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 at contact@cefirus.com
4. INFORMATION WE COLLECT

4.1 When you register a Cefirus 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 Cefirus account requested by you. In your Cefirus account settings you can also set your date of birth, avatar, and your geographical location. This information will be protected by your Cefirus account password. You are responsible for keeping it safe - please don't share it with anyone.

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

(a) Technical details about devices which you use to access Cefirus 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 Cefirus services including, but not limited to: metrics information about when and how you use Cefirus services (such as product downloads, 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 Cefirus; your communication via chat, game reviews, published posts on forum and other Cefirus services;
(c) Other information required in order to help you with any queries/support you may need assistance with via the Cefirus 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 we may also collect limited information through Facebook Connect such as your Facebook ID, avatar, e-mail and friend list;
(f) any other information which you supply us via our services;

4.6 A quick word about payment details (if/when you use them in Cefirus 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 Cefirus 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.
5. HOW WE COLLECT INFORMATION FROM YOU

5.1 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 Cefirus services;
(b) information given when you contact us or report a problem with Cefirus services;
(c) through our API which allows third party platforms to sell content which is activated by Cefirus (“Cefirus 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 Cefirus services or trusted third parties connected with us for optional things like surveys or polls.

5.2 Facebook Connect. When you register for Cefirus 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.
6. COOKIES

We also collect information about you via cookies. You can find out more about this in our Cookie Policy here. You can also manage your consents in our Cookie Declaration which you can find in the footnote of our website. The Cookie Policy and Cookie Declaration are a part of this Privacy Policy.
7. WHY DO WE USE YOUR DATA? (LEGAL GROUNDS FOR DATA PROCESSING)

7.1. When we process information about you, we do so as necessary to provide Cefirus services you use (i.e. to perform agreement between us), meet our legal obligations (f.ex. tax, accounting) or to fulfill the so-called “legitimate interests” of Cefirus 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.

7.2. When we transfer your data outside of the European Economic Area, we do so on the basis of a variety of legal mechanisms, as described in “Trusted Partners”.
8. HOW WE HANDLE YOUR INFORMATION

8.1 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.

8.2 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 Cefirus account for the duration of your agreement for the access to Cefirus services (i.e. until you close your Cefirus account). If you choose to close your Cefirus 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 Cefirus 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.
9. HOW DO WE USE YOUR INFORMATION

9.1 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 Cefirus account, providing you with the games and technical support and in general allowing to use Cefirus services and its functionalities when you choose to do so f. ex. your Cefirus user profile, chat or forum;
(b) to ensure that Cefirus services are presented in the most effective manner for you and for your computer or other device from which you access Cefirus 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 Cefirus 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 (of course, it’s optional)
(d) to activate content on your Cefirus 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 Cefirus services and our legal documents;
(g) to improve or modify Cefirus services, f.ex. based on which games you like, reported problems, your suggestions or satisfaction surveys;
(h) to improve or modify Cefirus services, for example based on which games you like more;
(i) to calculate conversion rates and other elements of Cefirus.com performance;
(j) in connection with the services of our Trusted Partners, such as payment processors, located in and outside the EU, but only to the extent necessary to provide those services;
(k) to provide you with optional functionalities such as Cefirus Connect or authentication via Facebook account;
(l) to create a universal user’s profile based on information about your use of Cefirus services and other platforms (we’ll rely on data made available when you merge your Cefirus 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 EU legislation (GDPR);

9.2. Whenever we’re personalizing or targeting our marketing communications, offers and adverts, we may profile your personal information. However, we do not make automated decisions (f.ex. via algorithms) that could affect your legal situation. If you decide that you no longer want to receive personalized offers, product recommendations from us, or no advertising news at all, you can object to this at any time. You can also choose whether to receive marketing communication from us, including personalized and targeted marketing emails by managing subscriptions on your Cefirus Account Subscription page, following the link "unsubscribe" attached to our marketing emails or just contacting us directly at contact@cefirus.com .

9.3 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 Cefirus services to you (for example, with games developers/publishers selling games on Cefirus.com or with payment providers) in order to support, improve or amend Cefirus 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 Cefirus.com. Fear not, as mentioned above, everything’s anonymised, so you cannot be identified.
10. DATA SHARINGS

Other Users

10.1 Some elements of your personal information and some information about your use of Cefirus services are accessible to other Cefirus users. For example: other users of Cefirus 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 Cefirus services. We do this to help Cefirus users to find other users with similar tastes and to build the Cefirus user community. You can manage the privacy settings of your Cefirus user profile in your Cefirus account.

10.2 How you use your information. Please remember that any communications you have via Cefirus services (e.g. via private messages, chat or the Cefirus 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 Cefirus services (e.g. on our forums or your Cefirus user profile) will be accessible to Cefirus users and others. Consider carefully with whom you share your information and avoid sharing contact or private information about yourself.

Our Trusted Partners

10.3. 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 (like Zendesk Inc.);
  • 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);
  • Cefirus’s subsidiaries and affiliates;
  • Third party vendors that provide us with analytical tools for Cefirus.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 Cefirus using our Direct to Account API (more details of which can be found in our User Agreement);
  • Third party network providers to optimize delivery of Cefirus content you requested (we share only your IP address and the identification of Cefirus content you wish to access);
  • Data storage partners: we may store some of your information using third-party data storage services, we may use Google services to run surveys on Cefirus.com;
  • Our professional advisors dealing f.ex. with legal, tax, audit or accounting matters.


10.4 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;

10.5 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.

10.6 Your information may be processed, stored and transferred outside your country of residence and beyond the European Economic Area (EEA) and Switzerland, such as the United States, Canada or Brazil. Privacy laws in these countries may not offer the same level of protection as in your country or in the EEA. But whenever we’re sharing your personal information outside the EEA and Switzerland, we will do so on the basis of the EU standard contractual clauses and/or other lawful measures to transfer your data and establish adequate protection of your personal information.
11. THIRD PARTY INFORMATION COLLECTION AND EXTERNAL SERVICES

11.1 Cefirus services may, from time to time, contain links to and from the websites or services of third parties (e.g. to games developers whose games are on Cefirus). 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 Cefirus profile in relation to their games. Our Privacy Policy does not extend to these external sites or companies, so please refer directly to their privacy policies.

11.2 Cefirus services may also offer you easy and optional access to Cefirus-approved Trusted Partners’ services, e.g. the websites and games provided by our development team. In order to do this, we will need to share some of your personal information (e.g. your email address) with them, as long as you agree to it. This personal information will be protected under our Trusted Partner’s privacy policy.
12. OTHER STUFF

12.1 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.

12.2 In the unlikely event of a reorganisation or merger of Cefirus or Cefirus 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.
13. YOUR RIGHTS

13.1 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 at contact@cefirus.com or by changing your email settings within your Cefirus account. Also email communications from Cefirus to you will contain an opt-out/unsubscribe option.

13.2 Depending on where you live, you may have additional privacy rights. For example, under EU laws you have the following additional rights:

to access information we hold about you;
to request that we delete your personal information from our system;
to ask us to rectify/correct your personal information if appropriate.
to ask us to restrict processing of your data
to transmit your data to another entity;
to lodge a complaint with a data protection authority.

You can exercise these rights by contacting us at contact@cefirus.com.

13.3 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 or the Agencia Española de Protección de Datos ("AEDP") in Spain.
14. CHANGES TO THIS PRIVACY POLICY

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

15.1 We'd also like to remind you that our User Agreement has more information about how we operate Cefirus services and it has a number of sections which apply to this Privacy Policy too. You can read it at User Agreement.
Last updated: 2021-11-02

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