PRIVACY POLICY

Here at eRepublik Labs we care about your privacy and we respect your privacy rights.

By using the eRepublik Service (as defined below), you permit the collection and use of your personal information as outlined below and you signify your agreement to this Privacy Policy. If you do not agree with these terms, you should not use the eRepublik Service.


1 ABOUT OUR PRIVACY POLICY

eRepublik Labs Limited of The Unit 4, Block A, Broomfield Business Park, Malahide, Co Dublin, K36 RF83, Ireland, registration no. 462101, VAT No. IE - 9693023K (“eRepublik Labs”,“we”,“us” and “our”) provides and operates the Age of Lords Game, including the http://www.ageoflords.com webpage and the Game, available for iOS and Android Apss, all their sections (the “Game”) as well as the in-game profiles and any other areas of the Game not listed here, that will or may be created in the future (the “eRepublik Service”). The eRepublik Service is administered by ERPK LABS SRL of 39-41 Nicolae Filipescu street, 6th floor, 2nd District, Bucharest, Postal Code 020961, Romania, registered with the Romanian Trade Register under No. J40/6415/2009, having the Sole Registration No. 25622297, on our behalf.

2 HOW WE COLLECT INFORMATION

3 USES MADE OF THE INFORMATION

4 DISCLOSURE OF YOUR INFORMATION TO OTHER PEOPLE

5 SECURITY AND CONTROL OF YOUR PERSONAL DATA

6. Legal basis for the processing of personal information

Insofar as we obtain the consent of the data subject for the processing of personal information, Art. 6 para. 1 lit. a GDPR serves as the legal basis.

If the processing of personal information required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to steps at the request of the data subject prior to entering into a contract.

Insofar as the processing of personal information is processing is necessary for compliance with a legal obligation to which we are subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that processing of personal information is necessary in order to protect the vital interests of the data subject or of another natural person, Art. 6 para 1 lit. d GDPR serves as the legal basis.

In the event that processing of personal information is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, Art. 6 para 1 lit. e GDPR serves as the legal basis.

If processing of personal information is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal information, in particular where the data subject is a child, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

7. Links to third party websites

8. Retention of personal information

The personal information will be deleted or access will be restricted as soon as the purpose of storage ceases to apply. The data will also be deleted or access will be restricted if a storage period expires, unless there is a need for further storage of the personal information for the conclusion or fulfilment of a contract.

9. Registration to the eRepublik Service via Facebook or other App Stores (Apple App Store, Google Play Store)

In order to use some of our eRepublik Service, you may register by providing personal information via Facebook, the Apple App Store and the Google Play Store. The data will not be passed on to third parties.

The legal basis for the processing of personal information in the course of the registration is a contractual relation according to Art. 6 para. 1 lit. b GDPR.

10. Rights of the data subject

If your personal information is processed, you have the following rights vis-à-vis us. To invoke those rights, please send an email to privacy@erepubliklabs.com, specifying the type of request.

a) Right of access

You have the right to obtain from us a confirmation as to whether or not personal information concerning you are being processed, and, where that is the case, access to the personal data and the following information:

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.

b) Right of rectification

You have the right to obtain from us within undue delay the rectification of inaccurate or incomplete personal information. Taking into account the purposes of the processing, you shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement.

c) Right to erasure (‘right to be forgotten’)

You shall have the right to obtain from us the erasure of personal information concerning without undue delay and we shall have the obligation to erase personal information without undue delay where one of the following grounds applies:

Where we have made the personal information public and is obliged pursuant to the above to erase the personal information, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The right to erasure shall not apply to the extent that processing is necessary:

d) Right to restriction of processing

You shall have the right to obtain from us the restriction of processing where one of the following applies:

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

If you have obtained restriction of processing pursuant to the above, you shall be informed by us before the restriction of processing is lifted.

e) Right to data portability

You have the right to receive the personal information, which 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 hindrance from the controller to which the personal information have been provided, where:

The right shall not adversely affect the rights and freedoms of others.

In exercising your right to data portability you shall have the right to have the personal information transmitted directly from one controller to another, where technically feasible.

The exercise of this right shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

f) Notification regarding rectification or erasure of personal data or restriction of processing

We shall communicate any rectification or erasure of personal data or restriction of processing carried to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if the you request it.

g) Right to object

You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning him or her which is based on Art. 6 para. 1 lit e) or lit. f). We shall no longer process the personal information unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Where personal information is processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, the personal information shall no longer be processed for such purposes.

At the latest at the time of the first communication with you, the right referred to above shall be explicitly brought to your attention shall be presented clearly and separately from any other information.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise his or her right to object by automated means using technical specifications.

h) Automated individual decision-making

The you shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you

This shall not apply if the decision:

TWe shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of us, to express his or her point of view and to contest the decision.

Decisions shall not be based on special categories of personal data unless Art. 9 para.2 lit. a) or lit g) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

i) Right of complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the European Member State where you reside, work or suspect of infringement, if you believe that the processing of personal information concerning you is not in compliance with GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

11. IP addresses and cookies

12. Access to information and updating, verifying and deleting personal data

13. Changes to our Privacy Policy

14. User feedback and complaints, external data protection officer

Dr. Christian Rauda

Certified specialist for information technology law

GRAEF Rechtsanwälte

Jungfrauenthal 8

20149 Hamburg

Germany

www.graef.eu

privacy@erepubliklabs.com