Last updated March 22, 2023
This privacy notice
for Brightdawn Entertainment, SIA (
- Download
and use
our game ( The Art of War: Card Game) , or any other application of ours that links to this privacy notice
- Engage with
us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy
notice will help you understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services. If you still have any questions or
concerns, please contact us at info@brightdawn.eu
.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice,
but you can find out more details about any of these topics by clicking the link following
each key point or by using our table of
contents below to find the section you are looking
for.
What
personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with
Brightdawn Entertainment, SIA
Do we
process any sensitive personal information?
Do we
receive any information from third parties?
How do
we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent. We process your
information only when we have a valid legal reason to do so. Learn more about how we process your information.
In
what situations and with which
categories of
How do
we keep your information safe? We have
What
are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. Learn more
about your privacy
rights.
How do
you exercise your rights? The easiest way to exercise your rights is by info@brightdawn.eu
Want to learn
more about what Brightdawn Entertainment, SIA
TABLE OF CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you disclose to
us
In
Short: We collect personal
information that you provide to
us.
We collect
personal information that you voluntarily provide to us when you
Personal Information Provided by You. The
personal information that we collect depends on the context of your interactions with us and the
Services, the choices you make, and the products and features you use. The personal information
we collect may include the following:
-
email addresses
-
usernames
-
contact or authentication data
Sensitive Information.
Payment
Data. We may collect data necessary to process your payment if you make purchases,
such as your payment instrument number, and the security code associated with your payment
instrument. All payment data is stored byValve
,
Apple Inc.
and
Epic
Games
.
You
may
find
their
privacy
notice
link(s)
here:
https://store.steampowered.com/privacy_agreement/
,
https://www.apple.com/legal/privacy/
and
https://www.epicgames.com/site/en-US/privacypolicy
.
Social
Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, Twitter, or other social media
account. If you choose to register in this way, we will collect the information described in the
section called
HOW DO WE HANDLE YOUR SOCIAL
LOGINS?
Application Data. If you use our application(s), we also
may collect the following information if you choose to provide us with access or permission:
- Device Data. We automatically collect
device information (such as your device ID, model, and manufacturer), operating
system, version information and system configuration information, device and application
identification numbers, browser type and version, and Internet Protocol (IP) address (or proxy server). If
you are using our application(s), we may also collect information about the phone
network associated with your device, your device’s operating system or
platform, the type of device you use, your device’s unique device ID, and
information about the features of our application(s) you accessed.
This information is primarily needed to maintain the
security and operation of our application(s), for troubleshooting, and for our internal
analytics and reporting purposes.
All
personal information that you provide to us must be true, complete, and accurate,
and you must notify us of any changes to such personal
information.
Information
automatically collected
In
Short: Some
information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically
when you visit our
Services.
We
automatically collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language preferences,
referring URLs, device name, country, location, information about how and when you
use our Services, and other technical information. This information is primarily
needed to maintain the security and operation of our Services, and for our internal
analytics and reporting purposes.
The
information we collect includes:
- Log and Usage Data. Log and usage data is
service-related, diagnostic, usage, and performance information our servers
automatically collect when you access or use our Services and which we record in
log files. Depending on how you interact with us, this log data may include your
IP address, device information, browser type, and settings and information about
your activity in the Services (such as the
date/time stamps associated with your usage, pages and files viewed, searches,
and other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called
"crash dumps" ), and hardware settings).
- Device Data. We collect device data such
as information about your computer, phone, tablet, or other device you use to
access the Services. Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet service
provider and/or mobile carrier, operating system, and system configuration
information.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In
Short: We process your information to
provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply
with law. We may also process your information for other
purposes with your
consent.
We process your personal information for a
variety of reasons, depending on how you interact with our Services,
including:
We
will
use
and
retain
the
collected
personal
information
as
needed
to
provide
the
Services
or
for:
More
information
about
our
data
collection
and
sharing
practices
can
be
found
in
this
privacy
notice
- To
request feedback. We
may process your information when
necessary to request feedback and to
contact you about your use of our
Services.
- To
send you marketing and
promotional
communications. We may
process the personal information you
send to us for our marketing
purposes, if this is in accordance
with your marketing preferences. You
can opt out of our marketing emails
at any time. For more information,
see
"
- To
deliver targeted advertising to
you. We may process
your information to develop and
display
personalized
- To
protect our
Services. We
may process your information
as part of our efforts to
keep our Services safe and
secure, including fraud
monitoring and
prevention.
-
To
identify
usage
trends.
We may process
information
about how you
use our Services
to better
understand how
they are being
used so we can
improve
them.
-
To
save
or
protect
an
individual's
vital
interest.
We
may
process
your
information
when
necessary
to
save
or
protect
an
individual’s
vital
interest,
such
as
to
prevent
harm.
-
Authentication and Authorization .To link the game profile to the account of a specific person, as well as to prevent fraud and access violation.
3.
WHAT
LEGAL
BASES
DO
WE
RELY
ON
TO
PROCESS
YOUR
INFORMATION?
In
Short: We
only
process
your
personal
information
when
we
believe
it
is
necessary
and
we
have
a
valid
legal
reason
(i.e.
,
legal
basis)
to
do
so
under
applicable
law,
like
with
your
consent,
to
comply
with
laws,
to
provide
you
with
services
to
enter
into
or
fulfill
our
contractual
obligations,
to
protect
your
rights,
or
to
fulfill
our
legitimate
business
interests.
If
you
are
located
in
the
EU
or
UK,
this
section
applies
to
you.
The
General
Data
Protection
Regulation
(GDPR)
and UK
GDPR
require
us to
explain
the
valid
legal
bases we
rely on
in order
to
process
your
personal
information.
As such,
we may
rely on
the
following
legal
bases to
process
your
personal
information:
-
Consent. We
may
process
your
information
if
you
have
given
us
permission
(i.e.
-
Performance
of
a
Contract.
We
may
process
your
personal
information
when
we
believe
it
is
necessary
to
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
-
Send
users
information
about
special
offers
and
discounts
on
our
products
and
services
-
Develop
and
display
-
-
Diagnose
problems
and/or
prevent
fraudulent
activities
-
Understand
how
our
users
use
our
products
and
services
so
we
can
improve
user
experience
-
Legal
Obligations.
We
may
process
your
information
where
we
believe
it
is
necessary
for
compliance
with
our
legal
obligations,
such
as
to
cooperate
with
a
law
enforcement
body
or
regulatory
agency,
exercise
or
defend
our
legal
rights,
or
disclose
your
information
as
evidence
in
litigation
in
which
we
are
involved.
-
Vital
Interests.
We
may
process
your
information
where
we
believe
it
is
necessary
to
protect
your
vital
interests
or
the
vital
interests
of
a
third
party,
such
as
situations
involving
potential
threats
to
the
safety
of
any
person.
If
you
are
located
in
Canada,
this
section
applies
to
you.
We
may
process
your
information
if
you
have
given
us
specific
permission
(i.e.
,
express
consent)
to
use
your
personal
information
for
a
specific
purpose,
or
in
situations
where
your
permission
can
be
inferred
(i.e.
,
implied
consent).
You
can withdraw
your
consent at
any
time.
In
some
exceptional
cases,
we
may
be
legally
permitted
under
applicable
law
to
process
your
information
without
your
consent,
including,
for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
-
For
investigations
and
fraud
detection
and
prevention
-
For
business
transactions
provided
certain
conditions
are
met
-
If
it
is
contained
in
a
witness
statement
and
the
collection
is
necessary
to
assess,
process,
or
settle
an
insurance
claim
-
For
identifying
injured,
ill,
or
deceased
persons
and
communicating
with
next
of
kin
-
If
we
have
reasonable
grounds
to
believe
an
individual
has
been,
is,
or
may
be
victim
of
financial
abuse
-
If
it
is
reasonable
to
expect
collection
and
use
with
consent
would
compromise
the
availability
or
the
accuracy
of
the
information
and
the
collection
is
reasonable
for
purposes
related
to
investigating
a
breach
of
an
agreement
or
a
contravention
of
the
laws
of
Canada
or
a
province
-
If
disclosure
is
required
to
comply
with
a
subpoena,
warrant,
court
order,
or
rules
of
the
court
relating
to
the
production
of
records
-
If
it
was
produced
by
an
individual
in
the
course
of
their
employment,
business,
or
profession
and
the
collection
is
consistent
with
the
purposes
for
which
the
information
was
produced
-
If
the
collection
is
solely
for
journalistic,
artistic,
or
literary
purposes
-
If
the
information
is
publicly
available
and
is
specified
by
the
regulations
In
Short: We
may
share
information
in
specific
situations
described
in
this
section
and/or
with
the
following
categories
of
third
parties.
Vendors,
Consultants,
and
Other
Third-Party
Service
Providers.
We
may
share
your
data
with
third-party
vendors,
service
providers,
contractors,
or
agents
(
"third
parties"
)
who
perform
services
for
us
or
on
our
behalf
and
require
access
to
such
information
to
do
that
work.
We
have
contracts
in
place
with
our
third
parties,
which
are
designed
to
help
safeguard
your
personal
information.
This
means
that
they
cannot
do
anything
with
your
personal
information
unless
we
have
instructed
them
to
do
it.
They
will
also
not
share
your
personal
information
with
any
organization
apart
from
us.
They
also
commit
to
protect
the
data
they
hold
on
our
behalf
and
to
retain
it
for
the
period
we
instruct.
The
categories
of
third
parties
we
may
share
personal
information
with
are
as
follows:
-
Performance Monitoring Tools
-
Data Storage Service Providers
-
Data Analytics Services
-
Cloud Computing Services
We
also
may
need
to
share
your
personal
information
in
the
following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
-
Offer
Wall. Our
application(s)
may
display
a
third-party
hosted
5.
WHAT
IS
OUR
STANCE
ON
THIRD-PARTY
WEBSITES?
In
Short: We
are
not
responsible
for
the
safety
of
any
information
that
you
share
with
third
parties
that
we
may
link
to
or
who
advertise
on
our
Services,
but
are
not
affiliated
with,
our
Services.
The
Services
,
including
our
offer
wall,
may
link
to
third-party
websites,
online
services,
or
mobile
applications
and/or
contain
advertisements
from
third
parties
that
are
not
affiliated
with
us
and
which
may
link
to
other
websites,
services,
or
applications.
Accordingly,
we
do
not
make
any
guarantee
regarding
any
such
third
parties,
and
we
will
not
be
liable
for
any
loss
or
damage
caused
by
the
use
of
such
third-party
websites,
services,
or
applications.
The
inclusion
of
a
link
towards
a
third-party
website,
service,
or
application
does
not
imply
an
endorsement
by
us.
We
cannot
guarantee
the
safety
and
privacy
of
data
you
provide
to
any
third
parties.
Any
data
collected
by
third
parties
is
not
covered
by
this
privacy
notice.
We
are
not
responsible
for
the
content
or
privacy
and
security
practices
and
policies
of
any
third
parties,
including
other
websites,
services,
or
applications
that
may
be
linked
to
or
from
the
Services.
You
should
review
the
policies
of
such
third
parties
and
contact
them
directly
to
respond
to
your
questions.
In
Short: If
you
choose
to
register
or
log
in
to
our
Services
using
a
social
media
account,
we
may
have
access
to
certain
information
about
you.
Our
Services
offer
you
the
ability
to
register
and
log
in
using
your
third-party
social
media
account
details
(like
your
Facebook
or
Twitter
logins).
Where
you
choose
to
do
this,
we
will
receive
certain
profile
information
about
you
from
your
social
media
provider.
The
profile
information
we
receive
may
vary
depending
on
the
social
media
provider
concerned,
but
will
often
include
your
name,
email
address,
friends
list,
and
profile
picture,
as
well
as
other
information
you
choose
to
make
public
on
such
a
social
media
platform.
We
will
use
the
information
we
receive
only
for
the
purposes
that
are
described
in
this
privacy
notice
or
that
are
otherwise
made
clear
to
you
on
the
relevant
Services.
Please
note
that
we
do
not
control,
and
are
not
responsible
for,
other
uses
of
your
personal
information
by
your
third-party
social
media
provider.
We
recommend
that
you
review
their
privacy
notice
to
understand
how
they
collect,
use,
and
share
your
personal
information,
and
how
you
can
set
your
privacy
preferences
on
their
sites
and
apps.
7.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
In
Short: We
keep
your
information
for
as
long
as
necessary
to
fulfill
the
purposes
outlined
in
this
privacy
notice
unless
otherwise
required
by
law.
We
will
only
keep
your
personal
information
for
as
long
as
it
is
necessary
for
the
purposes
set
out
in
this
privacy
notice,
unless
a
longer
retention
period
is
required
or
permitted
by
law
(such
as
tax,
accounting,
or
other
legal
requirements).
When
we
have
no
ongoing
legitimate
business
need
to
process
your
personal
information,
we
will
either
delete
or
anonymize
such
information,
or,
if
this
is
not
possible
(for
example,
because
your
personal
information
has
been
stored
in
backup
archives),
then
we
will
securely
store
your
personal
information
and
isolate
it
from
any
further
processing
until
deletion
is
possible.
8.
HOW
DO
WE
KEEP
YOUR
INFORMATION
SAFE?
In
Short: We
aim
to
protect
your
personal
information
through
a
system
of
organizational
and
technical
security
measures.
We
have
implemented
appropriate
and
reasonable
technical
and
organizational
security
measures
designed
to
protect
the
security
of
any
personal
information
we
process.
However,
despite
our
safeguards
and
efforts
to
secure
your
information,
no
electronic
transmission
over
the
Internet
or
information
storage
technology
can
be
guaranteed
to
be
100%
secure,
so
we
cannot
promise
or
guarantee
that
hackers,
cybercriminals,
or
other
unauthorized
third
parties
will
not
be
able
to
defeat
our
security
and
improperly
collect,
access,
steal,
or
modify
your
information.
Although
we
will
do
our
best
to
protect
your
personal
information,
transmission
of
personal
information
to
and
from
our
Services
is
at
your
own
risk.
You
should
only
access
the
Services
within
a
secure
environment.
9.
DO
WE
COLLECT
INFORMATION
FROM
MINORS?
In
Short: We
do
not
knowingly
collect
data
from
or
market
to
children
under
18
years
of
age
.
We
do
not
knowingly
solicit
data
from
or
market
to
children
under
18
years
of
age.
By
using
the
Services,
you
represent
that
you
are
at
least
18
or
that
you
are
the
parent
or
guardian
of
such
a
minor
and
consent
to
such
minor
dependent’s
use
of
the
Services.
If
we
learn
that
personal
information
from
users
less
than
18
years
of
age
has
been
collected,
we
will
deactivate
the
account
and
take
reasonable
measures
to
promptly
delete
such
data
from
our
records.
If
you
become
aware
of
any
data
we
may
have
collected
from
children
under
age
18,
please
contact
us
at
info@brightdawn.eu
.
10.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:
In
some
regions,
such
as
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
and
Canada
,
you
have
rights
that
allow
you
greater
access
to
and
control
over
your
personal
information.
You
may
review,
change,
or
terminate
your
account
at
any
time.
In
some
regions
(like
the
EEA,
UK,
and
Canada
),
you
have
certain
rights
under
applicable
data
protection
laws.
These
may
include
the
right
(i)
to
request
access
and
obtain
a
copy
of
your
personal
information,
(ii)
to
request
rectification
or
erasure;
(iii)
to
restrict
the
processing
of
your
personal
information;
and
(iv)
if
applicable,
to
data
portability.
In
certain
circumstances,
you
may
also
have
the
right
to
object
to
the
processing
of
your
personal
information.
You
can
make
such
a
request
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below.
We
will
consider
and
act
upon
any
request
in
accordance
with
applicable
data
protection
laws.
If
you
are
located
in
the
EEA
or
UK
and
you
believe
we
are
unlawfully
processing
your
personal
information,
you
also
have
the
right
to
complain
to
your
Member
State
data
protection
authority
or UK
data
protection
authority.
If
you
are
located
in
Switzerland,
you
may
contact
the
Federal
Data
Protection
and
Information
Commissioner.
Withdrawing
your
consent:
If
we
are
relying
on
your
consent
to
process
your
personal
information,
which
may
be
express
and/or
implied
consent
depending
on
the
applicable
law,
you
have
the
right
to
withdraw
your
consent
at
any
time.
You
can
withdraw
your
consent
at
any
time
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below
.
However,
please
note
that
this
will
not
affect
the
lawfulness
of
the
processing
before
its
withdrawal
nor,
when
applicable
law
allows,
will
it
affect
the
processing
of
your
personal
information
conducted
in
reliance
on
lawful
processing
grounds
other
than
consent.
Opting
out
of
marketing
and
promotional
communications: You
can
unsubscribe
from
our
marketing
and
promotional
communications
at
any
time
by
clicking
on
the
unsubscribe
link
in
the
emails
that
we
send,
or
by
contacting
us
using
the
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below.
You
will
then
be
removed
from
the
marketing
lists.
However,
we
may
still
communicate
with
you
—
for
example,
to
send
you
service-related
messages
that
are
necessary
for
the
administration
and
use
of
your
account,
to
respond
to
service
requests,
or
for
other
non-marketing
purposes.
If
you
have
questions
or
comments
about
your
privacy
rights,
you
may
email
us
at
info@brightdawn.eu
.
11.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
Most
web
browsers
and
some
mobile
operating
systems
and
mobile
applications
include
a
Do-Not-Track
(
"DNT"
)
feature
or
setting
you
can
activate
to
signal
your
privacy
preference
not
to
have
data
about
your
online
browsing
activities
monitored
and
collected.
At
this
stage
no
uniform
technology
standard
for
recognizing
and
implementing
DNT
signals
has
been
finalized
.
As
such,
we
do
not
currently
respond
to
DNT
browser
signals
or
any
other
mechanism
that
automatically
communicates
your
choice
not
to
be
tracked
online.
If
a
standard
for
online
tracking
is
adopted
that
we
must
follow
in
the
future,
we
will
inform
you
about
that
practice
in
a
revised
version
of
this
privacy
notice.
12.
DO
CALIFORNIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short: Yes,
if
you
are
a
resident
of
California,
you
are
granted
specific
rights
regarding
access
to
your
personal
information.
California
Civil
Code
Section
1798.83,
also
known
as
the
"Shine
The
Light"
law,
permits
our
users
who
are
California
residents
to
request
and
obtain
from
us,
once
a
year
and
free
of
charge,
information
about
categories
of
personal
information
(if
any)
we
disclosed
to
third
parties
for
direct
marketing
purposes
and
the
names
and
addresses
of
all
third
parties
with
which
we
shared
personal
information
in
the
immediately
preceding
calendar
year.
If
you
are
a
California
resident
and
would
like
to
make
such
a
request,
please
submit
your
request
in
writing
to
us
using
the
contact
information
provided
below.
If
you
are
under
18
years
of
age,
reside
in
California,
and
have
a
registered
account
with
Services,
you
have
the
right
to
request
removal
of
unwanted
data
that
you
publicly
post
on
the
Services.
To
request
removal
of
such
data,
please
contact
us
using
the
contact
information
provided
below
and
include
the
email
address
associated
with
your
account
and
a
statement
that
you
reside
in
California.
We
will
make
sure
the
data
is
not
publicly
displayed
on
the
Services,
but
please
be
aware
that
the
data
may
not
be
completely
or
comprehensively
removed
from
all
our
systems
(e.g.
,
backups,
etc.).
CCPA
Privacy
Notice
The
California
Code
of
Regulations
defines
a
"resident"
as:
(1)
every
individual
who
is
in
the
State
of
California
for
other
than
a
temporary
or
transitory
purpose
and
(2)
every
individual
who
is
domiciled
in
the
State
of
California
who
is
outside
the
State
of
California
for
a
temporary
or
transitory
purpose
All
other
individuals
are
defined
as
"non-residents."
If
this
definition
of
"resident"
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
information.
What
categories
of
personal
information
do
we
collect?
We
have
collected
the
following
categories
of
personal
information
in
the
past
twelve
(12)
months:
| Category | Examples | Collected |
|
A.
Identifiers
|
Contact
details,
such
as
real
name,
alias,
postal
address,
telephone
or
mobile
contact
number,
unique
personal
identifier,
online
identifier,
Internet
Protocol
address,
email
address,
and
account
name
|
|
|
B.
Personal
information
categories
listed
in
the
California
Customer
Records
statute
|
Name,
contact
information,
education,
employment,
employment
history,
and
financial
information
|
|
|
C.
Protected
classification
characteristics
under
California
or
federal
law
|
Gender
and
date
of
birth
|
|
|
D.
Commercial
information
|
Transaction
information,
purchase
history,
financial
details,
and
payment
information
|
|
|
E.
Biometric
information
|
Fingerprints
and
voiceprints
|
|
|
F.
Internet
or
other
similar
network
activity
|
Browsing
history,
search
history,
online
|
|
|
G.
Geolocation
data
|
Device
location
|
|
|
H.
Audio,
electronic,
visual,
thermal,
olfactory,
or
similar
information
|
Images
and
audio,
video
or
call
recordings
created
in
connection
with
our
business
activities
|
|
|
I.
Professional
or
employment-related
information
|
Business
contact
details
in
order
to
provide
you
our
Services
at
a
business
level
or
job
title,
work
history,
and
professional
qualifications
if
you
apply
for
a
job
with
us
|
|
|
J.
Education
Information
|
Student
records
and
directory
information
|
|
|
K.
Inferences
drawn
from
other
personal
information
|
Inferences
drawn
from
any
of
the
collected
personal
information
listed
above
to
create
a
profile
or
summary
about,
for
example,
an
individual’s
preferences
and
characteristics
|
|
| L. Sensitive Personal Information |
|
|
-
Category
A
-
As long as the user has an account with us
We
may
also
collect
other
personal
information
outside
of
these
categories
through
instances
where
you
interact
with
us
in
person,
online,
or
by
phone
or
mail
in
the
context
of:
-
Receiving
help
through
our
customer
support
channels;
-
Participation
in
customer
surveys
or
contests;
and
-
Facilitation
in
the
delivery
of
our
Services
and
to
respond
to
your
inquiries.
How
do
we
use
and
share
your
personal
information?