Privacy Notice

Azerion Connect’s Privacy Notice

We at Key Games Network B.V. (“Azerion Connect”, “we ”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data. The purpose of this privacy notice (“ Privacy Notice ”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing. This Privacy Notice applies whenever you use our Single Sign-On (SSO), identity, authentication and access management services or use any of our other services, all of which together we refer to as “Services”.

General Information

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

1. Who is responsible for the processing of your Personal Data?

Key Games Network B.V. Beechanvenue 182 1119PX SCHIPHOL-RIJK, Netherlands is responsible (“the data controller”) for the processing of your Personal Data.

2. What types of Personal Data do we process and how do we collect it?

When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation. The data we use depends on the purpose for which we process the data. We will only use your data for the purposes as described below in the next section and in the Service Specific Information section of this Privacy Notice. The information we collect differs on which of our Services you use and how you use them. We process the following types of your Personal Data:

2.1 Personal Data provided by you

When you use our Services, you provide or be asked to give us certain information, including:

Your account information: During your registration to our Services, we collect certain personal data about you. The following information must always be provided:

• An email address
• A password that meets the security requirements

For certain websites, further mandatory information may be required in addition to that referred above. What information specifically is required will be indicated in the registration form. We could collect or process that further mandatory information depending on the Services. Such information could include:

First and last name

Username

Date of birth

In addition, you can enter further details about you through your account settings. Further personal data might be processed when you add information to your personal profile.

Information provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details.

2.2 Personal Data we receive or generate from your use of our Services

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), the domain name of the website from which you came to the registration page, platform, portal or service ID (client id), country (based on your IP address), information about the internet browser (such as browser language and settings) operating system used by you, screen resolution, the creation date of the data record, a user ID assigned to you, a key known as “ident key” which allows you to unsubscribe from newsletters without logging in, date of the last change to the data record, and other technical information.

Cookie data: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), the domain name of the website from which you came to the registration page, platform, portal or service ID (client id), country (based on your IP address), information about the internet browser (such as browser language and settings) operating system used by you, screen resolution, the creation date of the data record, a user ID assigned to you, a key known as “ident key” which allows you to unsubscribe from newsletters without logging in, date of the last change to the data record, and other technical information.

Your Usage: We collect information about how you use our Services. This information includes the author of the data record (i.e. normally you, or in some cases an customer service agent whom you contacted), start and end of use of the authentication and access management service, your preferences, such as your interests in certain categories of platforms, the actions you take, the time and duration of your activity. Furthermore, we collect information about the websites that led you to our Services.

2.3 Personal Data we collect from other third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:

Social Networks and connected third-party platforms:: If you choose to connect our Services through Facebook or Google by using your credentials in our log-in process, we receive certain information about you from the Social Networks such as your public profile, first and last name, your profile picture, your email address, and your authentication token.

Other third parties: We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

To learn more about which data is processed, please see the section with service specific information below

3. Do we collect data from minors?

The Services are not targeted towards, nor intended for use by anyone under the age of 16. Our terms of use prohibit users aged under 16 years from accessing Azerion Connect. In the event that we learn that we have collected personal data from a user under 16 years of age, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team at Azerion Connect Support.

4. For what purpose do we process your data?

Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

4.1 Provision and improvement of our Services

Provision and improvement of our Services

to create, manage or administer your account

to identify you while signing-in

to restore your account if you ever lose access

to communicate with you in the context of account activation, password management

to simplify the registration process

to provide technical support and respond to your requests

to identify and correct any bugs/errors

to gain insights into the popularity of our Services

to assess the quality of our Services

to understand and improve your experience

to aggregate reports for our business partners

4.2 Personalization of experience

to remember your preferred settings

to recommend platforms you may like based on your preferences

to remember you next time you visit our Services

4.3 to remember you next time you visit our Services

to send you marketing communications or newsletters, informing your about new content and offers

4.4 Prevention of fraud and illegal activity

to investigate fraud and illegal behaviour

to comply with and enforce our policies and Terms of Use

4.5 Communication

to provide you with customer support based on your questions, requests, or complaints

to send you service emails, so that you can activate your account, for instance, or in case you forget your password

4.6 Compliance with our legal or regulatory obligations

to determine the legal requirements for processing of your Personal Data (such as your country based on your location)

to respond to your requests related to your data subject rights

to comply with our legal obligations (e.g. tax and accounting obligations)

to inform you about any changes to this Privacy Notice

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party, for example, in the context of customer service, where it is necessary for the creation and administration of your account, to support the operation of our Services or facilitate the delivery of requested Services.

Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations.

Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience.

Your consent:: We process your Personal Data if you have provided consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in the context of sharing your personal data with platforms or services. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.

Please see for additional information the section with service specific information below.

6. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support, and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

External service providers: : We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting, web analytics services and user notification services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

Third-party platforms: Azerion Connect’s authentication service generates a unique user ID for each user which can be recognised and verified by all third party platforms that are part of the Azerion Connect ecosystem. This allows you to have your account data (e.g. your name and email) stored in these third party platforms automatically to access the platforms or portals without the need of signing-in again manually. We also demonstrate anonymized statistics to these third-party platforms. Please note that by accessing these platforms or portals, your Personal Data can be processed by the third-parties (directly or through the use of cookies or similar technology) over which we have no control. We therefore advise you to check the privacy policies of any such third party platforms before accessing it. Furthermore, you can find the third parties your Personal Data may be processed in the following link: 3rd Party list.

Connected third-party platforms: We have included a Facebook and Google button on our Services to enable users to integrate with their social media profiles as and when they see fit to do so. Such parties may capture some of your data that way. These parties are controllers of the data for their own purposes. Learn more about our marketing activities in the service specific section below.

Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.

Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

7. Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

8. How do we protect your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

9. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see below for Service Specific Information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

10. What are your rights in respect of your Personal Data?

10.1 Your rights

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

Access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.

Request an update or correction of your Personal Data so that it is always accurate.

Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.

Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.

Restrict the processing of your Personal Data, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.

Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.

Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

10.2 Revoking permissions

If you want to revoke permissions from third party applications, you can do this from your Azerion Connect Account Settings as follows:
1. Log on to your Azerion Connect Account.
2. Click on “Applications”.
3. Scan the list and click the “Revoke Permission” on the right of any app you want to revoke permissions.

10.3 Deleting your Azerion Connect account

We would be sorry to hear you would like to delete your account. If you delete your account, you will lose access to all the products and services you have logged into via Azerion Connect. However, you can also revoke permissions only for certain third party applications if you wish. To revoke permission please check the instructions in the above section.
If you want to delete your account, here’s what to do:
1. Log on to your Azerion Connect Account.
2. Click on “Privacy”.
3. Enter your password and click “DELETE THIS ACCOUNT”. on the right of any app you want to revoke permissions.
Please be aware that your Azerion Connect Account will be deleted immediately. There will not be any grace period after you click “DELETE THIS ACCOUNT”.

11. How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support support@azerionconnect.com or info@azerionconnect.com or our Data Protection Officer via e-mail to dpo@azerion.com
For more information, please check https://azerionconnect.zendesk.com

12. How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.
This Privacy Notice was last updated on: 6/30/2021

Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.
We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
Category B– Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D – Commercial information (such as purchase history)
Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
Category G – Geolocation data
Category H – Audio, electronic, visual, thermal, olfactory, or similar information. The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.
You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.
Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.
You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Additional Information for Brazil Residents
Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

Service Specific Information

In this part of our Privacy Notice, you will find more specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting

Azerion Connect is hosted by external companies providing web servers. Every time you make a request, for example by clicking on a link on our environment, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our Service and ensure its functionality.

Creation/administration of your account

In order to use Azerion Connect, you have to create an account. We store your account data (log-in credentials, first-last name, email address and password (encrypted)) to allow you to log in on different devices, based on the performance of a contract.

If you choose to register using your e.g. Facebook or Google account, or enter our Services from a third-party platform (e.g. Facebook or Google), we receive certain information about you from the respective third-party provider like e.g. your email address, name, and other data that you have set to the public on your facebook profile and the authorization token.

Your account data will be stored for as long as your account exists. You can delete your Azerion Connect account at any time, for example through your Azerion Connect Account Settings or by submitting a deletion request to our support team using the contact feature within your Azerion Connect Account Settings or by contacting our Data Protection Officer.

Login

The internet portal transmits the data you have provided in your registration form (normally your email address and password) and a service URL to the authentication server. The authentication server then uses these data to verify the login request. If the login request is accepted on that basis, the user ID assigned to you will be transmitted to the server of the third party platforms concerned. We process this data on the basis of performance of contract.

Cookies

The authentication and access management service uses various authentication cookies. Cookies are small text files stored locally, in memory, by your browser. Authentication cookies automatically identify your web browser beyond the participating portals. They thereby serve as identifiers that save you from having to log in repeatedly to the participating websites.

When you login to any of the participating platforms or portals, you will be assigned an identifier for (at least) the current session that allows you to use the other participating platforms or portals and their offerings without the need for further logins (Single-Sign-On).

While the standard authentication cookie is automatically deleted from the single-sign-on when you log out, an authentication cookie that lasts longer (for 30 days) may be set that persists beyond the life of a session. However, this will only be the case if you actively select the “stay logged-in” option. However, you should be careful not to select this option if you use a public computer or a computer that is shared by multiple users.

If you want to disable the use of cookies, you can set your browser to reject and block any new cookies. Details about how this can be done in your browser can be found, for instance, in your browser’s help section. However, please note that, if you set your browser to automatically reject cookies, you will no longer be able to use the features of the authentication service. If you automatically delete all stored cookies at the end of each session, the “stay logged-in” feature will not be available. Please see our Cookie Notice for more information regarding the use of cookies and other technologies.

Facebook Connect

We’re offering you the opportunity to sign up for our Services through Facebook Connect. In order to do this, you will be redirected to Facebook where you can log in using your Facebook user data. Your Facebook account will then be linked to our Services. The link can be identified by the “Login with Facebook” symbol.

Depending on your Facebook settings, linking your account will allow the following data to be transmitted to us and/or retrieved by us: email address, name, profile picture and other data that you have set to the public on your Facebook profile. We shall only use this information for identification purposes. For more information on Facebook Connect and the privacy settings, please refer to the Privacy Policy and Terms of Use of Facebook Inc.

If you use Facebook Connect to register for and log into an account, your Personal Data will be transmitted to Facebook, Inc. 1601 Willow Road Menlo Park, California 94025 in the United States. You can unlink the accounts at any time and revoke the transfer of data with future effect by changing your settings on Facebook (here). We process this data on the basis of performance of a contract.

Google Button

Our Services also employ the Google Button, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (Google). The link can be identified by the “Login with Google” symbol against a white or color background.

We’re offering you the opportunity to sign up for our Services through Google Button. In order to do this, you will be redirected to Google where you can log in using your Google user data. Your Google account will then be linked to our Services.

Depending on your Google settings, linking your account will allow the following data to be transmitted to us and/or retrieved by us: email address, name, profile picture and other data that you have set to the public on your Google profile. We shall only use this information for identification purposes and contract processing. For more information on Google and the privacy settings, please refer to the Privacy Policy and Terms of Use of Google Inc.

The purpose and scope of data collection via Google, the processing and use of such data, as well as your rights thereof and personal settings regarding privacy protection can be found in the Google privacy settings.

If a user is a Google member and does not wish to have their data collected and linked to their saved Google member data via our web presence, the user must log out of their Google account before visiting our websites.You can unlink the accounts at any time and revoke the transfer of data with future effect by changing your settings on Google (here). We process this data on the basis of performance of a contract.

Customer service

If you contact us for customer support by using our email address, we will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend possible future legal claims. We process this data on the basis of performance of a contract to provide you with customer support, and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.

Monitoring user activities and reporting

We use analytics services to monitor your activities (e.g. login errors or incidents and failed login attempts) through your Azerion Connect Account. For this purpose, we process information about your device, request data (including the URL of the current webpage and the website visited before). We also process your full IP address to allow us to better understand how you use our Services and to improve our platform and websites. We process this data based on your legitimate interest.

Third party Platforms

Azerion Connect’s authentication service generates a unique user ID for each user which can be recognised and verified by all third party platforms that are part of the Azerion Connect ecosystem. This allows you to have the data stored in the platforms, portals and Services account (e.g. your name and email) used automatically, e.g. to access to platforms or portals without having to re-enter and re-verify the access data manually.

By accessing platforms or portals through Azerion Connect, your Personal Data can be processed by the third-parties (directly or through the use of cookies or similar technology). Please note that by choosing third-party platforms you will be able to play the game or buy the product in the third-party’s environment over which we have no control.

We disclose anonymous aggregate statistics about users of the third party platforms, in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personal data. We advise you to check the privacy policies of any such third party platforms before accessing it.

Your personal data will be disclosed to the following third parties for the purposes mentioned above:participating third party platforms have access to the data to assign access rights to you. We process this data on the basis of your consent.

Recaptchas

reCAPTCHA is a free service that protects websites against spam and abuse. It uses advanced risk analysis techniques to keep people and bots apart. With the new API, a significant number of your valid human users will pass the reCAPTCHA challenge without having to solve a CAPTCHA. We use reCAPTCHA by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to secure forms and to prevent spam. We process this data on the basis of our legitimate interest to protect Azerion Connect from bots and spam.

By using reCAPTCHA, data will be transmitted to Google using Google to determine whether the visitor is human or spam. To see what data Google collects and what this data is used for, visit https://policies.google.com/privacy?hl=en-AT. Further documentation can be found here: https://developers.google.com/recaptcha/, https://www.google.com/recaptcha/admin/create