Last update: 23 August 2021
We respect your privacy and therefore appreciate your trust and confidence in us.
This Privacy Notice explains how XTEN Limited (“XTEN”, “we”, “our” or “us”) collects and processes your personal data provided by you and/or received by us (“personal data” or “personal information”) when you use our website www.bloodofheroes.online (the “Website”), interactive entertainment software - session multiplayer fighting videogame under the title “Blood of Heroes” or derivatives thereof (the “Game”), and related products and/or services (collectively the “Services”).
Please read it carefully, because it is important for you to understand what we do with your personal information, the rights you are entitled to and how you can control it.
What information do we collect?
We generally collect information that you voluntarily provide us with, such as by creating an account, signing up for mailouts, information from your use of the Website or the Services, such as cookies or similar automated technologies and software, and information that we might collect from third parties, such as partner platforms or social networks. Information received by us from third parties shall be treated in accordance with the terms of this Privacy Notice. Anonymized or aggregated information is not Personal Information.
When collecting and processing your personal information, we are striving to be as transparent as possible, thus consider checking the list of personal information that we collect and process. Please note that the list is not comprehensive and might be extended by us at our sole discretion, provided that the extension and our use of personal information does not violate applicable legislation, therefore consider checking this Privacy Notice from time to time.
Information you provide
We collect the information that you directly provide to us when you enter it on the Website or while using the Services or include it in an email or other messages that you send to us. Such kind of information collection would happen during usual business processes. This information may include:
- Contact details and registration data. We collect your e-mail address you provide us with upon filling in registration form on the Website or when using the Services in order to confirm your registration and receive further instructions regarding further use of the Website or the Services. We also collect your username, password and other information that you might provide us with.
- Information about your hobbies which you provide to us when filling in the registration form and links to social media.
- Promocode (optional): a unique set of letters, symbols and (or) digits you may provide us with by filling in the registration form, that might have various profits for you depending of its purpose.
- Questionnaires/surveys/application forms information: we collect survey information you provide to us when filling in the registration form.
- Any information provided by you when contacting us, addressing the following email: firstname.lastname@example.org
Information we collect automatically
We may automatically collect information when you use the Website and our Services. Such information may include:
- Device Data. We automatically collect device-specific and device event information from the devices you use to in order to get access to the Website or Services. Such information may include your IP address, location, operating system version, processor type, amount of RAM, video card settings, keyboard and game controller type, graphics quality settings, gaming input device settings, browser data.
- Game Data. We automatically collect information from the devices you use in order to get access to the Game. Such information may include game identification number (ID). An ID is assigned to you automatically when installing and starting the Game and is a randomly specified set of characters that alone cannot identify you. Also we may collect information regarding the Game, including information about your in-game achievements, completed game levels and actions, crashes, reports and other information that might be generated by the Game.
Information we received from third parties
We may receive information from third party sources and combine it with the information we receive directly from you. This information may include:
How we process personal information?
XTEN strictly abides by all data protection regulations and strives to render the best level of information security and protection. We are transparent about our privacy practices and follow the principles of data minimization, and purpose limitation, accuracy and accountability.
We limit the storage of your Personal Information to the term necessary for the purposes of processing it. Among others, for legal, reporting, and accounting obligations.
For what purposes do we process your personal data?
Generally, we process your personal data to provide you access to the Website and Services, to ensure proper and secure functioning thereof, to comply with applicable laws and regulations, and to enhance your experience while using the Website or Services. We also use your personal data to contact you when necessary.
We process your Contact details and registration data for the following purposes: we may use your personal data to create an account, to contact you, to ask you to participate in Game activities, to enable your to access the Services, to reset your password, to ensure mailing of the Services’ announcements and surveys, to send you a unique link for accessing the private section to Discord. We may use your email address in order to exclude you from advertisement and/or marketing campaigns. Also your email address may be used for the purposes of targeted and direct marketing.
We process your Device and Game data for the following purposes: we may use your personal data to fix Game errors, to improve your gaming experience, to ensure the security of your account, to collect statistics on the equipment used for the Website and Services functioning, to analyze the performance thereof. We may also trace the approximate location of your IP address. We process this data in order to adjust the language and currency of payments when you use the Services. We use your Game ID to isolate your data from the data of other users. Data regarding the Game, as well as other information you provide, is used to provide you with the most comfortable mechanism for interacting with the Game.
We process Third parties and integration partners data for the following purposes: we may use your personal data provided to us by third parties and integration partners in order to improve the Website and Services.
We do not and will not process your personal data in order to sell it.
We also process your personal data in order to collect analytical data on the Services' functioning. For more information, please check the "Analytics" section of this Privacy Notice.
In addition, we may process your personal data in case when we are obliged to do so by applicable laws. We may also process your personal data in case when we are entitled to do so by the applicable data protection laws without obtaining your consent.
What is the legal basis for processing your personal data?
We process your personal data based on performance of contractual obligations and, in certain cases, on the basis of our legitimate interest or your consent to such processing to ensure the security and improvement of our services, to monitor the success of our marketing/ads programs, to ensure the security of transactions.
When processing your personal information based on your consent to do so, you therefore are entitled to withdraw your consent at any time (please see the description below), provided, however, processing preceding such a withdrawal shall remain valid and legitimate.
You also have the right not to be subject to a decision based solely on automated processing of your Personal Information, including profiling, which produces legal or similarly significant effects on you, and thus we avoid any automated decision making, including profiling that can produce any legal or similarly significant effects for our Website visitors or Service recipients.
Do we collect your payment information?
We do not and will not collect or process any information related to your payment instruments, such as your credit card number, its expiration date or your name as written on your card.
Do we provide third parties with your personal data?
We may provide third parties with your data on our behalf since their respective technical solutions may form an integral part of the Website or Services. However, we do not own these technical solutions and we do not affect their functionality. We may transfer your personal data to our partners on the basis of a written contract.
We may use third-party services to collect analytical data and advertisement display. You can learn about our partners' terms and conditions of personal data use in the "Analytics" section of this Privacy Notice.
We may transfer your personal data to our partners for mailings and improving your Website and Services experience as well as for excluding you from advertising and/or marketing campaigns. In particular, you can learn about our partners' terms and conditions of personal data use at the following link:
We may use third-party service to be sure you are a real person for whom the Website and Services were designed. The data we make available to this third-party service provider includes information collected as a result your answering prompts through the service, such as image labeling data, text converted from audio files played to you, answers to questions, and other prompts and information collected from you as part of the service to that is required to determine whether you are human, such as mouse movements, scroll position, keypress events, touch events, and gyroscope / accelerometer information. You can learn about our partners' terms and conditions of personal data use at the following link:
We may also transfer your personal data to third parties (e.g. Independent Data Controllers) in case we are obliged or entitled to do so by applicable laws. In such cases we transfer data according to applicable personal data protection laws, including, but not limited to, General Data Protection Regulation 2016/679.
International transfers of Personal Information
We may transfer your Personal Information in and outside the EEA, EU, UK, Switzerland or the U.S. in the course of the Services provision. We apply the Standard Contractual Clauses approved by the European Commission or other appropriate means as legal mechanisms for any such transfer, and make sure that such transfers occur only if there are adequate safeguards in place.
By using our Website and Services or providing us with any information through them, you acknowledge such transfer, processing, and storage of your Personal and other information in countries in which privacy regulations may be not as comprehensive as those in the country of your residence.
How long do we process your personal data?
We store all the data we collect for as long as you use the Website or Services and 2 years after your last use thereof. After the expiry of this time limit we erase your personal data from our database, as well as request same erasure from any third parties whom your data may have been transferred to. We can also delete your personal data as soon as we do not need it anymore.
Do we process any personal data of children?
We do not allow access to the Website or Services to anyone under the age of 18. We do not knowingly collect any personal data of those individuals.
If you are aware that we unintentionally process personal data of an individual under 18 years old, please contact us and we will make all reasonable efforts to stop processing such data and erase it as soon as possible.
What rights do you have with regard to your personal data?
You are entitled to all rights granted in accordance with the applicable domestic laws and cross-border legislation. In particular, under General Data Protection Regulation 2016/679 you are entitled to the following rights:
- Right to access your data;
- Right to correct your data;
- Right to have your data deleted;
- Right to transmit your data;
- Right to object to processing of your personal data;
- Right to restrict processing of your personal data;
- Right to withdraw your consent for personal data processing.
Right to access your data. You have the right to access your personal data, which we process. If you want to exercise the right, please contact us by sending the relevant request to our email.
Right to rectify (correct) your data. You have the right to ask us to update any inaccurate data about you. If you think that the data we process are incomplete for the purpose of processing as stated in this Privacy Notice, you may ask us to complete your personal data accordingly. If you want to exercise the right, please contact us by sending the relevant request to our email.
Right to have your data erased (deleted). You have the right to ask us to delete your personal data completely. If you want to exercise the right, please contact us by sending relevant request to our email.
Please, be aware that if you ask us to delete your personal data, all your data from the Registration form, as well as your profile data may be irrevocably lost. Deletion of personal data is irreversible. You will not be able to restore your personal data.
We emphasize that processing your personal data is absolutely necessary to allow you to access the Game.
Right to object to processing of your personal data. You have the right to object to processing your personal data for the purpose of direct marketing. If you want to exercise the right, please contact us by sending the relevant request to our email.
Right to withdraw your consent for personal data processing. You have the right to withdraw your consent for personal data processing. Any withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. If you want to exercise the right, please contact us by sending the relevant request to our email.
Right to restrict processing of your personal data. Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679. If you want to exercise the right, please contact us by sending the relevant request to our email.
Right to transmit your data. You have the right to ask us to receive your personal data 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. If you want to exercise the right, please contact us by sending the relevant request to our email.
California Residents rights
If you are a resident of California state, United States of America, you are entitled to the following rights: the right to know what personal information is being collected about you; the right to know whether your personal information is sold or disclosed and to whom; the right to say no to the sale of personal information; the right to access your personal information; the right of equal service and price, even if you exercise your privacy rights.
Also, being a California resident, you have the following rights:
- to request deletion any personal information about you;
- to request disclosure of the categories and specific pieces of personal information that we have collected about you;
- to request disclosure to you the following: the categories of personal information we have collected about you; the categories of sources from which the personal information have been collected; the business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information; the specific pieces of personal information we have collected about you; the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold.
We shall not discriminate against you because you exercised any of the California resident rights, including, but not limited to, by: denying goods or services to the resident; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to the resident; suggesting that the resident will receive a different price or rate for goods or services or a different level or quality of goods or services.
We collect and process certain data on how you interact with the Website or Services in order to analyze various aspects of the its functionality. Such information may include your location and device data. We use third-party technology solutions provided by our analytics partners to collect analytical data. We adopt such technologies and our partners process your data on our behalf in order to provide us with analytical data.
You can learn about our partners' terms and conditions of personal data use at the following links:
Yandex GDPR terms https://yandex.ru/support/metrika/general/gdpr.html
Yandex WebVisor https://yandex.ru/support/metrica/webvisor-v2/info.html?lang=en
Facebook Analytics GDPR https://developers.facebook.com/docs/facebook-pixel/implementation/gdpr/
Data processing for analytical purposes is based on legitimate interest of XTEN LIMITED, i.e. to analyze the data of the Website or Services’ users for commercial purposes. We rely on analytics to provide our users with high quality services, to update and develop the Website and Services. We can use analytical data to fix functionality errors, to collect demographic statistics of users.
You can learn about our partners' terms and conditions of personal data use at the following links:
Yandex GDPR terms https://yandex.ru/support/metrika/general/gdpr.html
In case you have any questions with regard to this Privacy Notice, please contact us via email: email@example.com or via regular post at the address stated below, and we will get back to you as soon as possible.
The controller of your personal data is XTEN LIMITED, a company registered in Cyprus under registration number HE365174, located at 21 Theklas Lysioti street, Melas court, office 101, 3030, Limassol, Cyprus.