Privacy Policy

COVEN SAS, a French company with SIRET no 90157781700017 respects the privacy rights of its users and is committed to being transparent with how we use personal information in connection to our products and services such as websites or when playing our games. The following is intended to inform users about how we gather, use and store information derived from your usage of our products and services. Please note that by playing and/or accessing our games, constitute the acceptance of this Privacy Policy. If you do not accept the terms of this Privacy Policy, please do not play and/or access the game.

What Information We Collect From You

Our products may collect the following information from you while you are using them:

which operating system you are using to run our products;
the brand and model number of your CPU and GPU;
the performance (frame rate, CPU/GPU load) of our products on your computer or gameplay device;
the amount of time you spend using our products;
which country you are located in;
whether you have installed or uninstalled our products;
any in-app purchases you have made, where applicable.

Where applicable, access and playing of certain basic Game versions, experience of certain basic content and games features may not require registering of an account with applicable platform/service providers that are providing the Game etc. to you. However, in order to access and play the complete Game, access certain premium game functions, levels, content and features you must register an account with the platform/service providers that are providing the Game etc. to you. You must then create an account with the platform/service providers’ platforms that hosts the Game to access such premium game functions, levels, content and features etc. To create an account you are required to provide certain mandatory information such as your name, your email address, account login etc. which is mandatory in order to be able to establish an account. Coven and/or the platform/service providers (i.e. Apple App Store, Google Play, PlayStation (PSVR), Xbox etc.) collects financial information on the terms and conditions set out in this Privacy Policy and/or the platform/service providers’ own Privacy Policies, which can be found on the respective platforms. Further you may, but may not be required to, provide certain voluntary information such as date of birth, screen name, your personal profile in the Game, interests in and use of various games, products and services, and any other personal or preference information.

COVEN may also collect and process other information when you interact with the Game online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifier such as a device identifier of any of your computer(s) or device(s) that are used to access the Game. Such information will be collected and processed irrespective of whether you only access the Game or if you actually play the Game. Coven may also collect and process certain information when you as a user with a user account interact with the Game such as the information in your personal profile, the relationships you form in the Game, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit information through various channels.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Logfiles

Log files are files that log actions that have occurred on a website, app or platform. Coven may collect data in the form of log files and may use such log files to gather statistics about End Users user habits and to assess overall Game activity, including how many “hits”; a particular web page etc. is getting and other navigational data. These entries are generated anonymously, and enable Coven and/or platforms to track interest in specific promotions, features, troubleshoot technical concerns, and provide End Users with content that may be of interest to them. Log files are used internally only, and are not associated with any particular user, computer, or browser.

Web beacons

Coven webservices (such as this website) or Games may use a variety of technical methods for tracking purposes, including “Web beacons” etc. Web beacons are small pieces of data that are embedded in images on the pages of the webservices or Game. We may also use these technical methods to analyze the traffic patterns in the Game such as the frequency with which End Users accesses various parts of the Game etc. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. The information from use of these technical methods may be collected in a form that is personally identifiable.

What This Information Collected For

We use your information solely for our own internal purposes. This is primarily for the improvement, maintenance and evaluation of our products and services. In accordance with applicable laws, this information may include:

Age identification for data protection purposes, for example to determine the legal requirements for processing of Personal Data. We request that anyone under the age of 18 not send any Personal Data about themselves over the Internet unless sent under the supervision of their parent or guardian. We do not knowingly collect Personal Data from children under 13 years old in the Game. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or played the Game and provided personally identifiable information to us, please contact us at contact@wearecoven.com or the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information. This in compliance with Article 6(1)(c) of the GDPR.
for support and troubleshooting reasons;
send support and administrative messages
provide news and information about the Game and/or about our games and products;
monitor the end users playing of the Game and activities in the Game;
provide adults with advertising in accordance with given consent and/or permissible laws;

Protecting and Storing Personal Information

In cases where we store your personal information, we will implement all reasonable security measures to ensure that it is stored safely and confidentially. Every possible effort will be made to prevent the loss, manipulation or leakage of all customers’ personal information.

With respect to processing of Personal Data Coven is Data Controller. Coven shall

(i) Not keep the Personal Data for longer than is necessary for the purposes of performing the Agreement unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules;

(ii) Store, process and use the Personal Data for the sole purpose of performing the Agreement;

and (iii) Ensure that their employees and employees of their affiliates and subcontractors involved in the performance of the Agreement comply with the provisions of this agreement

(iv) Implement all reasonable technical and organizational measures to protect your Personal Data against any accidental or unlawful destruction, accidental loss, unauthorized alteration, communication or access,

(v) Where applicable report to you, upon its occurrence, any unauthorized access, disclosure, use, modification or destruction of your Personal Data,

(vi) Refrain from exporting or transferring your Personal Data to any Third Country, and from collecting, using or Processing Personal Data within any Third Country, unless prior to the transfer we have ensured that an adequate level of protection of the Personal Data has been implemented in accordance with the terms and conditions stated in section 9 of this Agreement (International Data Transfers). Personal Data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with us has ended.

Providing Personal Information To Third Parties

Personal information which we collect will not be provided to third parties without your consent, unless:

it is required by the law, or is necessary for cooperation with local or international legal enforcement authorities;
it is necessary in order to prevent an emergency, prevent harm to others, or to protect our rights and policies.

We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.

Additionally, we may share information about you with certain third parties based on the legal basis in Articles 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR as follows:

Third Party Agents and Contractors

We may share information about you with third party agents and contractors in order to provide the Game to you, for ongoing development, for analytical purposes etc. We will only provide information to such third party agents and contractors for their performances of their specific assignments for us and consistent with this Privacy Policy, and for no other purposes and provided that such third party agents and contractors have ensured an adequate level of protection of the Personal Data in accordance with all Applicable Data Protection Legislation and/or though agreements with us.

Social networks

Where the Game and related services are accessed and/or provided through social networks.

Third parties

When required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity.

Courts, law enforcement agencies, legal authorities etc.

When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of Coven, the Game, end users etc.

Other end users

In order to provide certain Game features.

Advertising networks

For advertising purposes. We may share your advertising ID with advertising partners in order to serving behavioral advertisements to you within the Game if you have given consent in accordance with Article 6(1)(a) of the GDPR.

Where applicable certain third parties’ use of Personal Data will not be covered by this Privacy Policy. In such instances you must review such third parties’ privacy policies.

Deletion of Personal Information

If we receive a request from you to obtain disclosure, correct, terminate the use of, or delete your personal information, we will, by appropriate methods, verify that the request was made by you and then respond as soon as possible, unless it is appropriate to reject such request by law or business circumstances.

Information from Children

Our products and services are intended for users aged 13 and older. Accordingly, we will not knowingly collect or use any personal information from children that we know to be under the age of 13. In addition, we will delete any information in our possession that we discover originates from a child under the age of 13.

If you believe that your child’s personal information was mistakenly collected through our services, please contact us immediately and we will work with you to remove such information if necessary.

Security

Coven has taken reasonable steps to ensure that the personally identifiable information it collects is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the Personal Data collected from our Game’s End Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with the Game, that we store on our systems or that is stored on our service providers’ systems.

Please note that Coven may provide links to other games and websites that are operated and hosted by third parties who may have their own information collection practices. Those other games and websites are governed by their own privacy policies, which may be substantially different from Coven’ policies. Visitors to other games and websites are encouraged to review the privacy policies and information collection practices of those websites.

Any improper collection or misuse of User Created Content or information provided in the Game is a violation of the Terms of Use and should be reported to Coven at contact@weareoven.com

International Data Transfers

We may transfer and share your information to third parties (including service providers operating on our behalf) which may be located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. Where your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur based on the following safeguards: i) If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework (“Privacy Shield”) (see Privacy Shield at www.privacyshield.gov), or ii) If we have entered into EU Commission approved standard contractual clauses with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.

Your Choices and Controls

You have the following rights regarding your Personal Data:

The right to request access

In accordance to Chapter III, Article 15 of the GDPR a Data Subject may request access to processed Personal Data. This includes confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

the purposes of the processing;
the categories of Personal Data concerned;
the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the Personal Data are not collected from you, any available information as to the source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

You shall be provided a copy of the Personal Data undergoing processing. For any further copies requested, we may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others. Please note that the access may be restricted due to intellectual property rights or trade secrets.

The right to object

You have the right to object to the Personal Data processing on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Article 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your Personal Data for direct marketing purposes at any time. We will cease the processing of your Personal Data for this purpose after the objection. Please note that if you exercise this right, your user license to use the Game and related services will cease automatically.

Right of correction and erasure

You have the right to have inaccurate Personal Data rectified, in accordance with Article 16 of the GDPR.

You have the right to have your Personal Data erased where one of the following grounds applies, see Article 17 of the GDPR:

The Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
if you have withdrawn your consent and there are no other legal grounds for the processing,
if you have objected to the processing and there are no overriding legitimate grounds for the processing,
the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law,
the Personal Data have been unlawfully processed or
the Personal Data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

The right to restriction

You have the right to obtain restriction of processing in certain circumstances, in accordance with Article 18 of the GDPR. If you have the right to restriction, we will only process your Personal Data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

The right to withdraw consent

If we have asked for your consent to our processing of your Personal Data, you have the right to withdraw your consent at any time, in accordance with Article 7 of the GDPR. You may at any time opt out of and/or unsubscribe from emails from Coven and our service providers, or withdraw consent to Personal Data storage, either via the unsubscribe link included in the emails, or by emailing contact@wearecoven.com. If you withdraw your consent, we will cease processing of the Personal Data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your right to play the Game and related services will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability

You have the right to receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hinderance if the processing is based on consent or contract performance, sin accordance with Article 20 of the GDPR.

Changing or Removing Account Information

Access and control over most Personal Data in the Game is readily available through the profile editing tools on your account with the applicable platform/service provider that you are accessing the game through. End Users may modify or delete any or all of their profile information at any time by logging into their accounts. Information will be updated as soon as possible. End Users who wish to deactivate their Game account may do so in their accounts with the applicable platform/service provider that you are accessing the game through. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other End Users or visitors of the Game. You cannot however remove communications made in any communication features in the Game, which might have been shared with other End Users (for example sending personal messages to another End Users).

If you wish to invoke any of the rights described above, you may contact us at any time by emailing us at contact@wearecoven.com. We will process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Changes To The Privacy Policy

This policy is current as of its last revision date. However, please note that this policy may be amended from time to time to reflect changes and additions to the privacy policy. Please check back for the most current version before relying on any of the provisions in this privacy policy.

Coven will notify you of material changes by posting them on applicable game/app stores, and/or on the websites etc. You are encouraged to check back and review this Privacy Policy from time to time so that you will always know what information is collected how it is used and to whom it is disclosed. Your continued use of our services and playing of the Game subject to this Privacy Policy will signify your acceptance of Privacy Policy changes.

License

By purchasing or using any one of our products, you agree not to:

commercially exploit our products for financial gain without our permission;
distribute, lease, license, sell, rent or otherwise transfer our products to others without our permission;
make copies of our products;
make our products available on a network for usage or download by others;
reverse engineer, decompile, alter, disassemble or prepare derivative works based on our products;
cheat, or utilize any unauthorized programs in connection with any online features of our products;
violate any terms, policies, licenses, or code of conduct for any online features;
hold us liable for any damages whatsoever resulting from the possession, usage or malfunction of our products.

Warranty

Although we make every effort to ensure the products we provide are error-free and compatible with third-party hardware and software required to use them, we make no warranty against any interference with your enjoyment of our products, be that because of bugs, compatibility or stability problems.

Copyrights

We reserve all rights over the conceptual, visual and auditory contents of our products. No part of our products may be reproduced or copied (with or without alterations) without our permission.

Contact

If you have any questions, concerns or complaints regarding our Privacy Policy, please contact Coven via

COVEN, 14 rue du Moulin Joly 75011 Paris

Email: contact’at’wearecoven’dot’com