Random Step S.R.L. is a private company limited by shares incorporated in Romania having a registered office at str. Ing. T. Dragu 21, Bucharest, Romania (“we”/ “us”/ “our”/ “Random Step”). We provide various gaming and other online services (collectively referred to as the “Services”) which Services consist of, but are not limited to the following: any game content, advertisement product or software developed or created by us that you have downloaded or are about to download, any game, content, advertisement product or software that you have embedded on a website or are about to embed, any applications developed / created by us and available through different Platforms and social networking sites (“SNS“), any software running on Random Step’s servers, content, related documentation, information on the Random Step domain, information made available by users to each other through our software or posted publicly on any SNS (together “Platforms”) and any advertising or software placed on those Platforms by third party advertising companies (“Advertising Partners”) or the customers of our Advertising Partners (“Advertising Buyers”).
We provide the Services, online and offline. You provide the equipment (computer, phone, tablet, etc.) and pay any fees to connect to the Internet and app stores, or for data or cellular usage to download and use the Services. You may also need an account with any Platform or social network, if you are using our mobile Services, an account with the company that provides your mobile applications.
We respect your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily.
This Policy sets out important information about your rights in relation to the processing of your personal data, and the basis on which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of this website (www.randomsteps.com) (“our Site” or “the Site”) and/or the Services. This Policy applies to:
- any software provided/used/shared by Random Step or its Advertising Partners, such as games, applications, cookies, advertising identifiers or similar technologies;
- all of our games, whether played online or offline, on mobile devices, PC or on other Platforms such as social networking services;
- our advertising activities and the advertising activities of our Advertising Partners on all Platforms as described below;
- other services that we may provide to you from time to time;
- our site (www.randomsteps.com) and social networking accounts;
- websites and social networking accounts for each and every Service we provide, as stated above.
As set out in the TOS relating to our Services, you must be at least 16 years old to access and/or use our Services. We do not knowingly attempt to solicit or receive information from children.
Under this Policy, and unless we have entered into a different agreement with you, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data you provide to us.
Sharing Your Information With Advertisers
We share Your Data (including but not limited to Gaming Data, Technical Data, Profile Data, Tracking Data and Usage Data (each as described below) with our Advertising Partners who may in turn share Your Data with Advertising Buyers. We also share information about you that we collect by using cookies and other tracking technologies with our Advertising Partners who may in turn share Your Data with Advertising Buyers. These are described further below. Our Advertising Partners and the Advertising Buyers may be located outside of the EEA. As certain of the Services are provided to users free of charge, Random Step uses revenue generated from the sale of advertising space to fund the provision of those Services to its users.
We process your personal data in this way on the basis of our legitimate interests, insofar as it is necessary for us to generate revenue to provide these Services. Without this revenue we would not be able to provide you with these Services.
We have appropriate agreements in place with each of the Advertising Partners to help ensure that personal data is and will always be processed in a lawful, fair, transparent and responsible way. Advertising Partners and Advertising Buyers may, however, also have their own privacy policies.
By accessing or using the Services, you acknowledge we may share Your Data with our Advertising Partners who may in turn share that data with Advertising Buyers wherever they may be located (in accordance with the terms of this Policy) and for the purposes of generating customised advertisements directed at you based on Your Data.
You may object to the processing of your personal data for these purposes at any time. To do so, please contact us at firstname.lastname@example.org.
THE INFORMATION WE COLLECT
We will collect and process the following data about you for the following purposes:
Information you give us.
The information you give us may include:
- Identity Data: your full name and e-mail address. If you use our Services on your mobile device, in addition to your device identifiers, we may also collect the information you provide for: the name you have associated with your device, your telephone number, your country, and your specific geolocation (“Identity Data”).
- Gaming Data: data in respect of your usage of the Services including playing our games or any in-app purchases made by you (“Gaming Data”).
Information we collect about you.
This information may also be provided or can be also used to create your personal profile in connection with our Services. You can choose to log into your profile using your SNS account details. If you do this, for example, you may be able to log in on multiple devices and synchronize progress across those devices. We will receive some of your SNS account information; exactly what information we receive will depend on your settings in your SNS account. We may use this information for the purposes described in this Policy. Once connected in this way, you will also be able to see which of your friends are using our Services and may also allow you to access other functionality in our games and other services, such as inviting friends to play, asking other players for lives and one-to-one messaging. Logging in with your SNS account will not allow us to post anything to your SNS page without your permission.
You can make changes to what data a SNS shares with us, or stop our Services interacting with that SNS by adjusting your settings with that third party provider.
In addition to information you provide about yourself, you may choose to share information about yourself in other content, such as in games. Any action you perform with other players is considered public, and at your own discretion.
We may use information about you that we collect from other sources, including but not limited to newspapers and Internet sources such as blogs, instant messaging services, games and other users of our Services, to supplement your profile in compliance with all applicable laws (the data referred to in the preceding paragraphs shall be referred to as “Profile Data”).
Automatically Collected Information. With regard to each of your visits to our Site we will automatically collect the following information:
- Technical Data: technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and Platform, mobile device model, how often you use the application, the functionality that you use through the Service, including your gameplay choices and other performance data (“Technical Data”); and
- Usage Data/Usage Information: information about your visit and interactions to our website, games, applications or any other Services, including the full Uniform Resource Locators (URL), referring/exit pages, traffic data, location data, weblogs, resources that you access and other communication data, whether this is required for our own billing purposes or otherwise, clickstream to, through and from our site (including date and time), browser type, browser language, browser history, Platform type, landing pages, products you viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to call us (“Usage Data”).
No special categories of personal data.
We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us.
Unless otherwise agreed to in writing by you, Random Step shall not share any Personal Data with Advertising Partners or Advertising Buyers (i) that contains any Special Categories of Personal Data; and/or (ii) that contains Personal Data relating to children under 16 years old.
COOKIES, AD IDENTIFIERS AND TRACKING TECHNOLOGIES
What are cookies and why we use them.
“Cookies” are small text files which are stored by your browser on your computer and are normally used to gather statistical information and to analyse trends of use or access to a website.
Cookies may be used to save your personal preferences so you do not have to re-enter them each time you access the Site.
The Services may send or use “cookies”, “ad identifiers”, “browser cache”, “web beacons”, “pixels”, “mobile SDKs” or similar (tracking) technologies (“Tracking Technologies”) as may evolve or be developed by us or our Advertising Partners or by Advertising Buyers from time to time to your computer or mobile devices when you access our Services, view content through a Random Step game or application or use an SNS.
These Tracking Technologies collect certain data including but not limited to, internet protocol addresses, precise location data and similar unique ID’s including cookie IDs and device ID’s and by using our Services or clicking on advertisements you will activate these Tracking Technologies. They may for example be used to help us, Advertising Partners or Advertising Buyers to recognise your computer and to ensure that your account is accessed by the person that inputs the correct username and password for that account.
We and Advertising Partners and Advertising Buyers who advertise on our Services use these Tracking Technologies to display targeted advertisements, advertisements more likely to be relevant to you, to improve the quality of Services, make recommendations, make the Services easier to use for our users and for general advertising activities and to allow our payment partners to process your payment instructions.
You acknowledge that: (i) in connection with the Services, Random Step, its Advertising Partners and the Advertising Buyers may collect or otherwise process personal data (including but not limited to, internet protocol addresses, precise location data and similar unique IDs such as cookie IDs and device IDs) about or related to you; and (ii) Random Step, its Advertising Partners and Advertising Buyers use Tracking Technologies in order to collect your personal data.
You acknowledge that: (i) Random Step, its Advertising Partners and Advertising Buyers may collect, Process and share Personal Data via the Services and those of the Advertising Partners and the Advertising Buyers for the purposes contemplated by these Terms; and (ii) acknowledge that Random Step, Advertising Partners and Advertising Buyers will deploy Tracking Technologies in order to collect Personal Data in connection with the performance of the Services (“Tracking Data”).
Advertising (or ad) identifiers are non-permanent, non-personal device identifiers for different Platforms and SNSs. These technologies allow the collection of technical data, such as IP address, your device’s model, operating system and screen size, the other applications installed on your device, domain names, and information about how you use our Services.
You can choose to adjust your preferences on the matter, by preventing your device’s ad identifier being used for interest based advertising, or resetting your device’s ad identifier through the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings. You can also disable cookies through your web or phone browser settings.
If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services – for which we cannot be held responsible and it does not mean you will no longer receive advertising, it only means the advertising you do see will be less relevant to your interests.
WHAT WE DO WITH YOUR INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interest (or those of a third party (including but not limited to our Advertising Partners)) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where it is necessary for our legitimate interest in order to fund the provision of the Services to you we will share Your Data with our Advertising Partners who in turn may share Your Data with their Advertising Buyers.
We have set out below, in table format, a description of the ways we plan to use your personal data and the legal basis we rely only to do so. We have also identified our legitimate interests where appropriate:
|Purpose/Activity||Type of data||Legal basis for processing|
|To share Your Data with our Advertising Partners who may in turn share it with Advertising Buyers.||
||Necessary for our legitimate interests (to finance the provision of the Services by selling advertising opportunities to our Advertising Partners to fund the provision of the Services).|
|To respond to your queries and to provide you with the information you request from us in relation to our products or Services.||
|To determine whether you are in compliance with our TOS, software, games, applications or any other Services and to impose sanctions where necessary.||
|For the purpose of compiling statistics in an anonymised manner.||
|To manage any in-app purchases.||
|To provide you with information, products or services we offer that are similar to those that you have already purchased or enquired about||
||Necessary for our legitimate interests (to develop our products or Services and grow our business) unless you have opted out of receiving such information.|
|Where you have given us your consent to do so, to provide you with information about other services we feel may interest you.||
|To ensure that content is presented in the most effective manner for you and for your computer or device and to allow you to access our Services and to participate in interactive features of our Services, when you choose to do so.||
||Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).|
|To administer and protect our business, our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.||
||Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure)|
|To use data analytics to improve or optimise our Site, marketing, customer relationships and experiences.||
||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).|
|To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you including making suggestions and recommendations to you and other users about goods or services that may interest you or them.||
||Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business and to inform our marketing strategy).|
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.
Be advised that if you send messages or publically post material containing personal information, that public information may be collected and used by third parties. Random Step does not assume any liability for the misuse of such public information by third parties.
How long we keep your information.
You can terminate your account at any time, which will remove your profile and other personal information from view.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, we may hold personal data as needed for our accounting or tax compliance purposes for a period of 6 years. For more information about our data retention policies please contact us at firstname.lastname@example.org.
DISCLOSURE OF YOUR INFORMATION
We do not sell your personal information to third parties for marketing purposes. We will share Your Data with our Advertising Partners and they may share it with Advertising Buyers. We may disclose information to other third parties if you consent to us doing so as well as in the following circumstances:
You agree that we have the right to share your personal information with the following recipients or categories of recipients:
- Any department or authorised person within our company or any member company within our group, which means any subsidiary or holding company within the meaning of sections 7 and 8 of the Companies Act 2014.
- Selected third parties including:
- Advertising Partners (who may share your personal information with Advertising Buyers), business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in relation to the Services;
- analytics and search engine providers that assist us in the improvement and optimisation of our Site;
- credit reference agencies for the purpose of assessing your credit score to the extent this is a condition of us entering into a contract with you.
We will disclose your personal information to third party recipients:
- in order to create and build our games, to generate revenue from our Advertising Partners to fund the provision of the Services.
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of our business or assets.
- if Random Step or substantially all of its assets are acquired by a third party, or if there is a corporate restructuring, or a change of control of Random Step, in which case personal data held by it about its customers will be one of the transferred assets. Any third party to which Random Step transfers or sells its assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Policy.
- if we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR or other agreements.
- to protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organisations for the maintenance and security of the Site and Services.
- Random Step may disclose information about you to its partners (including Advertising Partners) in order to provide the Services, resolve service problems and correct errors in the Services, to communicate with you about the Services, to provide you with advertising and promotional information in connection with the Services, and to enhance your experience on the Services. Our Advertising Partners may share this information with Advertising Buyers.
- Random Step, certain of its partners, and each of their contractors and employees, may view and/or process the information that you transmit to the Services or that it is collected by us to provide the Services and otherwise perform the tasks set forth in this Policy.
As a game developer using different softwares and online applications to create and advertise games, we recommend that you consistently check privacy policies of Random Step and third parties in order that you can be confident that Random Step and its partners are committed to GDPR compliance and to understand an operator’s practices (e.g. for Unity software, please check https://unity3d.com/legal/privacy-policy).
Third-Party Advertising Companies
We use Advertising Partners to serve ads for our Services, on any Platform that we use. These Advertising Partners sell advertising to Advertisement Buyers. Our system and the third-party advertising technology uses information derived from usage information set out above, cookies and ad identifiers, your visits to our Services, from our software, games applications that you view and the SNS you use, to target advertising within our site, games or SNS or others (“Usage Information”). In addition, Advertising Partners and Advertising Buyers may use other third-party advertising technology to target advertising on our site and other sites. In the course of advertisements being served to you, a unique third-party cookie or cookies, ad identifiers or similar technologies may be placed on your computer or mobile device. Similarly, such third-party advertising companies may provide us with pixel tags (also called “clear gifs” or “beacons”) to help manage and optimize our/their advertising. Beacons enable us/them to recognise a browser’s cookie when a browser visits the site on which the beacon is located, and to learn which banner ads bring users to a given site.
Our Services will provide Your Data to third-party advertising companies. For example, if an advertiser asks us to show an advertisement to users with certain characteristics (for example, women aged 18-24) or a segment of that group (for example, women aged 18-24 who have viewed certain categories of content) and you respond to that advertisement, the third-party advertising company may conclude that you have the characteristics of the audience that they are trying to reach.
The use of or provision of the Services may require the transfer of your Personal Data located in the EEA or Switzerland to countries outside the EEA or Switzerland (as applicable) and by availing of the Services you expressly consent to the transfer of Your Data outside of the EEA or Switzerland (as applicable). Random Step will ensure an appropriate mechanism that is recognised by applicable EU Data Protection Law is implemented to allow for the data transfer. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.
You acknowledge and agree that Random Step shall discharge its obligations to provide adequate protection for any EEA Personal Data by ensuring any recipient has self-certified its compliance with the Privacy Shield Framework and by using such, recipient agrees to protect EEA Personal Data in accordance with the requirements of the Privacy Shield Principles.
“Privacy Shield” means the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework self-certification program operated by the U.S. Department of Commerce and approved by the European Commission pursuant to Decision C(2016)4176 of 12 July 2016 and by the Swiss Federal Council on January 11, 2017, respectively.
“Privacy Shield Principles” means the Privacy Shield Framework Principles (as supplemented by the Supplemental Principles) contained in Annex II to the European Commission Decision C(2016)4176 of July 12, 2016 (as may be amended, superseded or replaced).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.
For more information about this and the safeguards in place relating to the transfer, please contact us by email at email@example.com.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We encrypt data transmissions and we have reasonable measures in place to protect the physical security of records we store on our premises. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR PERSONAL DATA AND YOUR RIGHTS
Accessing your Personal Data.
You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to firstname.lastname@example.org. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. We will endeavour to respond to you within one month.
There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Right of Restriction.
You may restrict us from processing your personal data in any of the following circumstances:
- you have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
- the processing of your personal data is unlawful and you request the restriction of use of the personal data instead of its erasure;
- we no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise or defence of legal claims; or
- where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds.
Corrections or Erasure (Right to Rectification and Right to Be Forgotten).
If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at email@example.com.
Your Right to Object.
You have the right to object to the processing of your personal data at any time:
- for direct marketing purposes
- for profiling to the extent it relates to direct marketing
- where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights and freedoms or in connection with the enforcement or defence of a legal claim.
To exercise your right to object at any time, please email firstname.lastname@example.org.
Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.
Profiling is an automated form of processing of personal data often used to analyse or predict personal aspects about an individual person. This could relate to a person’s performance at work, economic situation, health, personal preferences, reliability, behaviour, location or movements. An example of this would be where a bank uses an automated credit scoring system to assess and reject a loan application.
You have the right to be informed if your personal data will be subject to automated decision making, including profiling. You also have the right not to be subject to a decision based solely on automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary in connection with the performance of a contract between us, is authorised by law or where you have given your explicit consent to this automated processing.
The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned.
We will not use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you, unless we have your permission to do so.
Your right to object.
You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at email@example.com. You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.
THIRD PARTY MATERIAL
CHANGES TO THIS POLICY
Any changes made to this Policy from time to time will be published at the Site.
Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data, will be notified to you in advance via our website. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.
At all times, the English version of the Policy will be the prevailing one and the version valid as the agreement between the parties. By accessing and using our website, you warrant that you command the English language sufficiently to have understood this Policy in English. Any translation of this Policy from English into another language is made just for convenience purposes and the translation will not be valid as an agreement.
QUESTIONS OR COMPLAINTS.
Contact Us. If you have any questions or complaints relating to this Policy, please contact us at:
Random Step S.R.L.
str. Ing. T. Dragu 21 birou 1
Supervisory Authority. We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Office of the Data Protection Commissioner Ireland.
Effective Date of this Policy: May 2021