PRIVACY POLICY
v.1.3
updated: October 11th, 2021
1. GENERAL PROVISIONS
1.1. The proper handling of Personal Data is extremely important to Us. We therefore take Your privacy seriously when processing and protecting Your Personal Data. This is done in accordance with provisions set out in the applicable privacy laws (including the General Data Protection Regulation). This Privacy Policy applies to a Website https://questera.games/ and to all Services We provide on the Website. If You do not agree with provisions of this Privacy Policy, You have to restrain from using of the Website or any of other Services offered on the Website. By visiting of the Website and by registering of the User Account and checking the box “I agree with provisions of Terms and Privacy Policy” (or similar) You provide Us a with an informed consent to process and use Your Personal Data as specified in this Privacy Policy.
1.2. We take great care to limit the Personal Data We collect and use only for the purposes, which are necessary for providing our Services.
1.3. Legal grounds for processing.
1.3.1. Existence of a contract between the User and Questera: By creating a User Account and using Services, You and Company enter into a contract for the provision of Services, as is stipulated in the Terms. In order to provide You with Services as a whole, as well as with a separate component, We have to collect and process certain Personal Data about you;
1.3.2. Legitimate interest: Company uses a legitimate interest in processing of Your Personal Data, for example, when Company processes Your data to fix bugs in the Services and to ensure its smooth operation, to improve the work of the our Services, to develop and to introduce new functions and services, to ensure security of User when using the Questera Services, and to ensure secure work of the Services, to transfer data within the organizational structure of Company, for example, to affiliated companies, to transfer certain information at the request of the intellectual property rights holders who claim that a particular User has placed illegal content. We will not use legitimate interest as a basis for processing of the User data if the rights, freedoms and interests of the User override the interest of Company or third party;
1.3.3. Legislative requirements: Company may process User’s Personal Data, if it is required by the law that applies to Questera. For example, Company may provide Personal Data on Users at the request of courts or other authorized bodies.
1.3.4. Consent: Company relies solely on Your consent when uses Personal Data for the purpose of opening and activation of User Account, usage of Services offered, and etc.
1.4. Company will not collect sensitive Personal Data except when permitted or required to do so by law, and will do so only for legitimate business purposes. If in any other instance a need arises to collect sensitive Personal Data, Company will do so only with the data subject’s express consent, which can be withdrawn at any time.
1.5. We do not transfer Your Personal Data to third parties, except circumstances mentioned in this Privacy Policy or Terms.
1.6. This Privacy Policy is subject to the Questera’s Terms of Use (which may be found on the Website). Your use of the Services and any Personal Data You provide on our Services remains subject to the terms of this Privacy Policy and our Terms of Use.
1.7. We reserve the right to update this Privacy Policy from time to time. If the changes are significant, We may inform You about such changes by posting a notice on our Website or by sending an email to Your registered email address. You can find the latest version of Privacy Policy on our Website at any time.
1.8. The definitions set forth herein and mentioned with capital letter, unless specifically introduced in this Privacy Policy, shall have the meaning as described in Terms of Use, which can be founded on the Website or, if the definition cannot be found in Terms of Use, shall have the meaning as is specified in the General Data Protection Regulation.
2. ABOUT US
2.1. The legal entity, which acts as a Personal Data Processing Company is M&H Krypton Development Ltd, registered address: Achaion, 35, 5th floor, flat/office 17, Agios Andreas, 1101, Nicosia, Cyprus, registration number HE 420377.
3. WHAT DATA WE COLLECT ABOUT YOU
3.1. «Personal Data» (also refereed as to the «PD», «Personal Information») shall mean any information, that identifies You, i.e. Your email, login (User name) requests to our support team, and etc. If You cannot be identified (for example, when Personal Data has been anonymized or this information solely bears statistical information), this Policy shall not apply.
3.2. Whenever You visit our Website or use our Services, We collect and process Your Personal Data.
3.3. We divide the information we collect about You as follows:
3.3.1. Information You provide us with by Yourself:
a) When You use our Services, You provide Us with Your Personal Data which includes following info:
i Username (in case if system-generated username is late changed);
ii Email address;
iii Password (pay attention to the fact, that We do not process the passwords despite the fact, that You create a one for opening of a User Account);
iv Game accounts information (Steam Username, Steam ID, gaming statistics from game accounts collected, availability of Steam Vac Ban, BattleTag);
v Real Name and Surname (optionally, when KYC is conducted);
vi Residential country and residing address (optionally, when KYC is conducted);
vii User Name ID, if social networks were used for the registration or login;
viii Proof of address (utility bill or bank reference letter or other confirming documents, as proof of the aforementioned address information during KYC);
ix Proof of ID (passport, ID-card, similar document as proof of the aforementioned name/surname ID information, when KYC is conducted);
x Card number, expiry date, CVC-code (this info is been solely processed by the respective payment provider integrated and is collected only subject to making a deposit);
xi Card number, expiry date, CVC-code (this info is been sent by Us straight forward and processed by the respective payment provider integrated in prior to making withdrawal, We don’t store this information and conduct no other actions);
xii Date of Birth (when KYC is conducted);
b) In certain cases, (when additional verification by bank or compliance authority is needed according to governmental rules, AML or KYC policies) Company may require You to provide additional information, and namely:
i Numbers, that You may use or have registered with Your local tax authority;
ii Additional photographs of You;
iii Confirmation of proceeds sources (for example, additional bank statements);
iv Sworn statements;
v Bank details and other payment information.
Be aware, that due to the Applicable Law, We are obliged to conduct KYC procedures (which are described in the Section 3 of the Terms). We preserve the right to conduct KYC at any time if Your Questera’s Platforms Usage, but not later, that before withdrawal of any funds from the Platform.
The abovementioned information and details shall be provided only upon special personal request to the User and specified in respective email or message on the Website.
3.3.2. Information We collect automatically (may apply even if You do not register User Account or use offered Services):
a) IP address;
b) Information, that is being collected by the Google Analytics (operating system, browser and its settings, crash reports, screen resolution, from where User-geo, which marketing campaign affect user to come); Please pay attention to the fact, that usage of such information is also a subject to the relevant policies published by Google;
c) gaming statistics (including kill/death ratio, assists, networth, rating, hero damage, tower damage, here healing, last hit, denies);
d) transactions count;
e) transaction amount;
f) geo of User;
g) deposit count;
h) deposits amount;
i) withdrawal count;
j) withdrawal amount;
k) wallet balance.
At the moment We also process some other types of cookie files (including, but not limited to: fbp; fr [Facebook], _gcl_au [Google AdSense]; _gid; _ga [Google Analytics], IDE [Google Doubleclick], hjIncludedInSample [Hotjar] and others. Detailed list of cookies, which are processed can be sent to You upon request as well as other technical information in relation to the usage of cookies. This information is useful to us because it helps us to better understand how You use of our Website and Services, so that We can improve them for You. For example, using information from Your browser, We can determine what language You speak and translate the Website into Your language. You can globally prevent the setting of cookies by adjusting the privacy settings of Your web browser (see Your web browser Help for how to do this). Be aware that disabling cookies will negatively affect the functionality of this and many other websites that You visit. Disabling cookies will also usually result in disabling of certain functionality and features of the Website. Therefore, it is recommended that You do not disable cookies. By using the Website and clicking the button “continue” You express Your additional consent for the processing of cookies by Us. We collect general anonymous analytical information on the use of the Services for their optimization.
3.3.3. Information We receive from third parties. We do not exclude the possibility of collecting Your Personal Data from other sources, for example, from publicly available sources, such as social networks, or from trusted third parties like payment providers. We use this information in addition to the Personal Data We have already collected about You in order to better personalize and improve our services for You, as well as to verify the Personal Data You provide Us with.
4. HOW WE USE YOUR PERSONAL DATA
4.1. We may deliver, personalize, and improve our Services by combining and using the information We have about You (including information We receive on and off our Services) to understand how You use and interact with our Services and the people or things You’re connected to and interested in. We also may use the information We have about You for the following purposes:
4.1.1. Provide, maintain, improve, and develop relevant features, content, and Services;
4.1.2. Fulfil Your requests (support) and when authorized by You;
4.1.3. Research and develop new Services;
4.1.4. Detect and defend against fraudulent, abusive, or unlawful activity;
4.1.5. We use Your location to personalize the content You provide and to serve targeted ads;
4.1.6. Research and develop new services;
4.1.7. Send You technical notices, updates, security alerts, invoices and other support and administrative messages;
4.1.8. Provide customer service;
4.1.9. Communicate with You about products, Services, offers;
4.1.10. To send You different promotions, and info regarding events, and to provide other news and information we think will be of interest to You;
4.1.11. Personalize the Services and provide advertisements, content and features that match User profiles or interests;
4.1.12. For publishing of news and updates in our official social networks, or on our Website (for such needs, We can use, including but not limited to: Your avatar, nickname and gaming statistics).
5. HOW WE SHARE YOUR PERSONAL DATA
5.1. Our Privacy Policy applies only to the Qustera Services, that are offered on the Website https://questera.games/. Website may contain links to other websites and file downloads from other websites. We do not exercise control over any website that may be linked to from within content on our Website. We are not responsible for the privacy practices or content of such websites.
5.2. When You use the Services, certain information may be shared with other Users and the public. For example:
5.2.1. when You play the game and win, Users of our Services will be able to see amount of Challenges played, username or other information sometimes.
5.3. We do not transfer Your Personal Data to third parties, except cases, that are mentioned in this Privacy Policy which are next:
5.3.1. With our partners. We may share information with Affiliates, vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out work for Us. The partner’s use of Personal Data will be subject to appropriate confidentiality and security measures.
a) KYC-provider – KYAID (https://kycaid.com/privacy-policy);
b) Payment-provider – Trust Payments (https://www.trustpayments.com/privacy/);
c) Google-analytics (https://policies.google.com/privacy?hl=en-US);
d) Steam (https://store.steampowered.com/eula/453480_eula_1?eulaLang=english);
e) Hotjar (https://www.hotjar.com/legal/policies/privacy/);
f) Zendesk (https://www.zendesk.com/company/agreements-and-terms/privacy-policy/);
g) Etc.
5.3.2. To comply with the law. We may share information in response to a request for information if We believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, We will attempt to provide You with prior notice before disclosing Your information in response to such a request. We may also share Your Personal Data with regulatory, state and law enforcement agencies, courts, fraud prevention agencies, licensing authorities or other third parties, in cases where applicable laws or regulations must be observed, as well as to implement, establish or protect our legal rights (when it is possible and appropriate, We will immediately inform You about disclosure of Your Personal Data to the third parties);
5.3.3. In an emergency. We may share information if We believe it's necessary to prevent imminent and serious bodily harm to a person;
5.3.4. To enforce our policies and rights. We may share information if We believe Your actions are inconsistent with our user agreements, rules, or other Questera policies, or to protect the rights, property, and safety of ourselves and others;
5.3.5. With our Affiliates. We may share information between and among Questera and any of our parents, affiliates, subsidiaries, and other companies under common control and ownership;
5.3.6. With Your consent. We may share information about You with Your consent or at Your direction.
5.4. As was already mentioned, We engage service providers to perform functions and provide services to Us. For example, We use a variety of third-party services to help operate our Services and to help Us understand the use of our Services, such as Google Analytics (https://policies.google.com/privacy?hl=en-US) such services may collect following Personal Data, as IP-address, gender information, type of the used web-browser, patterns of use on the Website and location). We may share Your Personal Data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use Your private Personal Data only on our behalf and pursuant to our instructions. We don’t store Your credit card and payment information, it’s transferred right to our PCI-DCC compliant for payment facilitation procedures, including, but not limited to; prevent, detect, and investigate fraud or other prohibited activities; facilitate dispute resolution such as chargebacks or refunds; and for other purposes associated with the acceptance of credit and debit cards. For means of customer support We will, however, have access to user transaction history, IP address, currency. Sensitive credit card information is only processed by our payment providers.
5.5. We may partner with third-party advertisers, ad networks to deliver advertising and content targeted to Your interests and to better understand Your use of the Services. These third parties may collect information sent by Your computer, browser, or mobile device in response to a request for content, such as unique identifiers, Your IP address, location or other information about Your computer or device.
5.6. Other information, that does not personally identify You as an individual is collected by Company (such as, by way of example, patterns of use) and is exclusively owned by Questera. We can use this information in such manner on our sole discretion, deems appropriate.
5.7. We may share specific aggregated, non-Personal Data with third parties, such as the number of Users who have registered with Us, the volume and pattern of traffic to and within the Website, etc. That information will not identify You, the individual, in any way.
5.8. As were mentioned above, when You send Us messages, We can keep them for administering of Your inquiries, for improving of our services. We shall not transfer information from such messages to third parties.
5.9. In other cases, We do not share Your Personal Data, but retain it encrypted on our servers, for more details about that please see section “Security of Your Personal Data”.
6. LENGTH OF DATA RETENTION
6.1. We retain Your Personal Data to fulfill our legal, operational, contractual and regulatory obligations. For each type of records, the recordkeeping requirements may vary so We guarantee that in no event shall We retain Your Personal Data longer than required. If You would like to know more about the length of retention for a specific data, please contact Us at support@questera.games / legal@questera.games.
7. SECURITY OF YOUR PERSONAL DATA
7.1. We provide the following safety measures regarding protection of Your Personal Data:
7.1.1. Evaluation of the effectiveness of used security measures, prior to the launch of the Website and its updates;
7.1.2. Establishing rules to access to Personal Data processed by the Website, as well as ensuring registration and recording of all actions performed with PD in the information systems of the Website;
7.1.3. Detection of the facts of unauthorized access to PD and the adoption of appropriate response measures;
7.1.4. Restoration of PD that was modified or destroyed due to unauthorized access to them (within the framework of technical capability of the Company).
7.2. WE USE, STORE AND PROCESS YOUR PD ON QUESTERA’S SERVERS IN VARIOUS JURISDICTIONS (GERMANY AND ANOTHER EU-COUNTRIES), WHERE OUR FACILITIES AND/OR SERVICE PROVIDERS ARE LOCATED. BY CHECKING A RELEVANT BOX, VIEWED ON THE WEBSITE DURING REGISTRATION PROCEDURE, YOU AGREE TO THIS TRANSFER, STORING, OR PROCESSING. COMPANY WILL TAKE ALL STEPS REASONABLY NECESSARY TO ENSURE THAT YOUR PERSONAL DATA IS TREATED SECURELY AND IN ACCORDANCE WITH THIS POLICY. Company protect Your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards Questera’s use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Company also authorize access to Personal Data only for those employees or contractors who require it to fulfil their job or service responsibilities. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations. Third parties may be located in other countries where the laws on processing of Personal Data may be less stringent than in Your country. From time to time, the Personal Data may be also stored in other locations, and in such cases, Company will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.
8. KNOW YOUR RIGHTS
8.1. You can opt-out of receiving certain marketing or promotional communications from Us at any time by using the unsubscription link in the email communications sent.
8.2. If You are a resident of the European Union, You have certain data protection rights under the GDPR:
8.2.1. You can access and change certain types of the Personal Data through the User Account themselves without contacting Company (this clause also apply for the non-EU residents);
8.2.2. You may delete several types of Your Account information, which were provided by Yourself, at any time from the relevant page. But We may retain certain Your Personal Data as required by law or for legitimate business purposes after You delete Your Account. If You initially consent to our collection of location information, You can subsequently stop the collection of this information at any time by changing the preferences on Your browser (this clause also apply for the non-EU residents);
8.2.3. You have the right to receive information regarding purposes of Personal Data collection, regarding third parties, to which we disclose Your Personal Data, information, regarding safeguards that are applicable for secure storage of Your Personal Data, period of time for which Personal Data will be stored;
8.2.4. You also have the right to demand full erasure of Personal Data concerning You sending Us a request via support [support@questera.games]. Questera shall fulfil Your request in appropriate period of time. If there is no other lawful ground for storing and processing of Your PD, as prescribed by Applicable Law, Questera shall erase such information. If there is another legal ground for such processing, Company shall notify You in appropriate period of time (this clause also applies for the non-EU residents);
8.2.5. You also have the right to demand restriction of the storing and processing of the PD, if legal grounds for such demands have arisen / or are prescribed in Applicable Law;
8.2.6. You have the right to object processing of Personal Data concerning Yourself under circumstances, that are prescribed in applicable law. In case of such objection, Company shall restrain from processing of Your PD, if there will be no other legal grounds for continuing of processing;
8.2.7. Company takes Your rights very seriously. However, if You are of the opinion that We have not dealt with Your complaints adequately, You have the right to submit a complaint to the data privacy protection authorities responsible;
8.2.8. You have the right to ask Company to provide You with a structured, list of previously provided PD (and of the currently processed PD by the Company). You also can ask Us to transmit Your PD to previously chosen third party.
8.3. To send a request for delete, rectification and submission of PD please contact support via or support@questera.games / legal@questera.games.
9. DATA TRANSFERS
9.1. When We transfer PD outside the European Union or EFTA, We ensure, that the adequate level of PD security is provided. During such transfer, We also ensure that adequate level of Your rights protection is also applied, on the basis of adequacy analysis of the third country Personal Data protection legislation, on the basis of contractual obligations, assumed by the PD recipient.
10. NOTIFICATION
10.1. If Company becomes aware of security systems breach, then We will attempt to notify You electronically so that You can take appropriate protective steps. Company may post a notice on our Website if the security breach occurs.
10.2. When the Personal Data breach is likely to result in a high risk to the rights and freedoms of Users, the Company will inform You as soon as reasonable possible.
10.3. In the event that Questera is acquired by or merged with a third party entity, We reserve the right, in any of these circumstances, to transfer or assign the information We have collected from our Users as part of such merger, acquisition, sale, or other change of control. If We become involved in a merger, acquisition, or any form of sale of some or all of its assets, We will notify Users before Personal Data is transferred and becomes subject to a different privacy policy. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how Your Personal Data is treated, transferred, or used.
11. COLLECTION OF CHILDREN’S PD
11.1. BY ACCESSING OR USING THE WEBSITE AND ONLINE SERVICES PROVIDED BY COMPANY, YOU HEREBY REASSURE THAT YOU ARE OVER 13 YEARS OLD. IF YOU DO NOT AGREE WITH PROVISIONS OF PRIVACY POLICY AND TERMS OF USE, YOU SHALL NOT USE THE WEBSITE AND ONLINE SERVICES AT THIS WEBSITE. YOU BARE ALL AND ANY RESPONSIBILITY FOR ANY CONSEQUANCES FOR USAGE OF THE WEBSITE OR PROVIDED SERVICES WITHOUT MEETING REQUIREMENTS SET BY THE TERMS OR THE PRIVACY POLICY.
11.2. PERSONNEL OF COMPANY DOES NOT KNOWINGLY COLLECT OR MAINTAIN PERSONALLY IDENTIFIABLE INFORMATION OR NON-PERSONALLY-IDENTIFIABLE INFORMATION ON OUR SERVICES FROM PERSONS UNDER 13 YEARS OLD, AND NO PART OF OUR SERVICES IS DIRECTED TO PERSONS UNDER 13. IF YOU ARE UNDER 13 YEARS OLD, THEN PLEASE DO NOT USE OR ACCESS THE COMPANY SERVICES AT ANY TIME OR IN ANY MANNER. IF COMPANY LEARNS THAT PERSONALLY IDENTIFIABLE INFORMATION OF PERSONS LESS THAN 13 YEARS OLD HAS BEEN COLLECTED ON THE QUESTERA’S SERVICES WITHOUT VERIFIED PARENTAL CONSENT, THEN COMPANY WILL TAKE THE APPROPRIATE STEPS TO DELETE THIS INFORMATION AND SUSPEND YOUR ACCOUNT.
11.3. Additionally, You must be over the age required by the laws of Your country to create an account or otherwise use the Services, or We need to have obtained verifiable consent from Your parent or legal guardian as it is prescribed in the Terms of Use. Only persons over 18 years old may access the full functionality of the Website.
12. CONTACT US
12.1. If You have any questions about this Privacy Policy, please feel free to contact Us or to write to Us at: E-mail: legal@questera.games.