Privacy Policy


 

Thank you for visiting our Website (the “Website”) and/or using our Services.

 

The term Website refer to any of the subdomains of the domain “dualthegame.com”.

 

NOVAQUARK is referred to in this privacy policy as “NOVAQUARK”, “we”, “us” or “our”.  

 

We are committed to protecting the privacy of all our visitors to our Website. This privacy policy (“Privacy Policy”) explains how we use information we collect about you (“User” or “you”) and the choices you can make about the way your information is collected and used.

 

By using the Website (which for the avoidance of doubt includes but is not limited to simply browsing the Website, completing and submitting a registration form on the Site), you are informed of the collection and use of your personal information in accordance with this Privacy Policy.

 

  1. Contacting us
    1. For the purpose of the applicable Data Protection Law, the data controller in respect of any personal data that you submit to us on our Website is NOVAQUARK with a capital share of 129.711,16 euros, SAS incorporated under French Law (company number: 799 791 926) before French Trade and Companies Register of Paris, whose registered office is 130 rue de Lourmel, 75015 Paris, France.
    2. You can contact us using the following contact information:
      NOVAQUARK
      130 rue de Lourmel
      75015 Paris
      FRANCE
      Or you can use the Website contact form : https://dualthegame.com/privacy
      Phone: +33 (0)9 67 48 04 04
    3. Should you have any questions, comments or queries regarding this Privacy Policy, please contact our Data Protection Officer’s (DPO) at the following address : privacy@novaquark.com.
  2. The information we collect from you
    1. To give you the best experience on our Website, NOVAQUARK may collect personal information from you. The information we collect includes but is not limited to:
      • (a) information that you provide us when you create a Dual Universe Account: first name, last name, email address, pseudonym. This information is mandatory to create an account. NOVAQUARK may also collect additional personal information for other services, such as your home address. If you purchase products via our online store, and if you want to pay by credit/debit card, you will need to provide a valid credit/debit card number, expiration date and cryptogram, information collected by our sub-contractor XSOLLA located in the USA and with whom NOVAQUARK has signed a GDPR addendum.
      • (b) information about your usage of the Website, including but not limited to your IP address (an IP address is a numeric address that is assigned to your computer by your Internet Service Provider and can be used to identify your computer when you log on), browser type, screen resolution, length of visit, number of page views and generally tracking your movements around the Website. We may use an analytics service provider for website traffic analysis to collect this information. This information may also be collected by cookies that are installed by the Websites. Please see the section on cookies below for more information.
      • (c) information about you from e-mails or letters that you send to us, including personal information that you voluntarily submit to us via e-mail when contacting customer services. For example, we provide on this Website a form through which an online visitor can contact our technical support staff addressing any issue a user encounters with the NOVAQUARK Website;
      • (d) information you may want to share with us when applying for a job at NOVAQUARK, and notably data pertaining to your personal and professional life;
      • (e) other aggregated information collected passively by NOVAQUARK in the form of logs (files that record website activity, including but not limited to how many “hits” a particular web page is getting, sometimes referred to as “click-through data”) which are generated anonymously; and
      • (f) any other information which you may voluntarily provide to us.
  3. How we use your information
    1. NOVAQUARK takes your privacy seriously, and takes every reasonable precaution to safeguard the personal information you supply to us. We will only use any information that we collect from you in accordance with this Privacy Policy and in compliance with French Data Protection Law and European Regulation. Without limiting the generality of the following we will use the information we collect from you:
      • (a) in order to register you as a user of this Website and/or to provide services to you;
      • (b) to help us understand customer trends and patterns and to ensure that content on our Website is presented in the most effective way (including but not limited to assessing overall site activity, tracking interest in particular portions of the Website, identifying the type of browser you are using, assessing any troubleshoot technical concerns and generally administering, improving and developing our Website);
      • (c) to guarantee use and improvement of our services;
      • (d) to process and supervise applications you may send us via our Website;
      • (e) to provide you with our email notifications, newsletters and other marketing communications that either you request from us or which you consent to by opting in when completing a registration form on the Website. You may opt out from receiving such marketing communications from us at any time by notifying us in writing at the address above, or contacting us through the Website contact form or, alternatively, by following the procedure to ‘unsubscribe’ that is specified in the marketing communication that you receive;
      • (f) to respond to any queries you may have including but not limited to any emails or letters you send to customer service. This information is used by NOVAQUARK for the sole purpose of responding to your question. Although most e-mail messages are deleted immediately after they are responded to, in certain cases hard copies or data from certain e-mail correspondence may be kept on file for security purposes. Any such copy or data will be stored in a secure location, and information from these messages will not be used for marketing purposes; and
      • (g) to register the termination of the access to the Website; and
      • (h) for our internal marketing and demographic studies, so we can constantly improve services that we provide. Your data, together with that of other users of this Website, may be aggregated (e.g. by postcode or age) for the purpose of building statistical and analytical reports. At no time will your data be individually identifiable in such reports.
  4. On which legal basis do we collect and use your data ?
    1. Contract
      If you create an account with Novaquark and/or if you wish to purchase products on our Website, the personal data mentioned above is necessary for the purposes of entering a contract with us and provide you with the following services:
      1. provision of our products;
      2. communicating with you about changes to our products and services;
      3. maintaining a commercial relationship with you;
      4. responding to any queries that you may submit to us.
    2. Legitimate interests
      We may also collect personal data for the purposes of legitimate business interests, including the following:

      You have the right to object to us processing your personal data on this basis at any time.

      1. to process the applications you send to us;
      2. to develop and improve our services to you and other customers;
      3. to learn from the way you use our services;
      4. to exercise or defend legal claims.
    3. Consent
      In certain circumstances, and in particular when the legal basis mentioned above are not applicable, we are required to obtain your express consent to the processing of your personal data. In such cases, you will be able to withdraw your consent at any time.

  5. How long do we keep your data ?

    The duration of storage of your data depends on the processing purposes for which the data is used :

    - in order to register you as a user of this Website and/or to provide services to you;

    We hereby undertake to delete your data at the same time as you delete your account with NOVAQUARK.
    - to communicate with you

    We hereby undertake to delete your data within a maximum of 3 years after our latest contact with you.
    - to process and supervise your applications

    We hereby undertake to delete your data within a maximum of 2 years after our final contact with you.

    Generally speaking, we retain your personal data only for as long as is necessary for their processing.

    Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited, in any nature whatsoever.
     
  6. What happens if I choose not to give my personal information?
    If you choose not to submit personal information when requested, you may not be able to access the services on the Website and subscribe Packs.
  7. Personal data concerning children
    NOVAQUARK does not knowingly collect any personal data concerning children under 16 years old.
  8. Information sharing

    1. The information that you disclose while visiting the Website will be collected and processed by us or by a data processor. Your personal information shall be automatically collected by and stored on secure servers owned and operated by third party data processor appointed on our behalf. We stringently request that our partners and providers act in compliance with the applicable data protection legislation and grant special attention to confidentiality of this data. By application of the applicable regulation, any sub-contractor who may process personal data for NOVAQUARK undertakes as follows:

      • to solely process data for the purpose(s) which is/are sub-contracted;

      • to process data in pursuance with NOVAQUARK’s instructions;

      • to guarantee the security and confidentiality of the data.

    2. Particularly, HEROKU is the hoster of the Website and is located in the USA. NOVAQUARK ensures an adequate level of protection of your information as HEROKU has adhered to the Privacy Shield and complies with European Union data privacy law.

    3. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access to that information. Where we have given you (or where you have chosen) a password that enables you to access certain parts of this Website, you are responsible for keeping this password confidential. You must not share a password with anyone.

    4. Any agents and contractors of NOVAQUARK who have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing. We will not disclose your personal information to any outside organisation who wants to market goods or services to you without first obtaining your express consent.

    5. We may disclose information we hold in response to legal proceedings, for example, in response to a court order. Consequently, although we will take all reasonable efforts to ensure that this Privacy Policy is complied with, we cannot guarantee that personal information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

    6. In the event that NOVAQUARK is sold, Users information that belongs to NOVAQUARK, that subsidiary or that business unit may also be transferred as part of the sale. Nevertheless, your personal information will still be subject to this Privacy Policy and French and European Data Protection Law.

  9. Links, advertisers, third party sponsors & Ad-servers
    Occasionally, the Website may contain links to other websites where information practices may be different to ours. For example, if you “click” on a banner advertisement, the “click” may take you off this Website. This includes links from advertisers, channel sponsors and partners that may use our logos as part of a co-branding agreement. You should consult these third party websites’ privacy notices and terms and conditions as we are not responsible for and have no control over and accept no liability for information that is submitted to, or collected by, these third parties.

  10. Your rights concerning data collected

    1. Your rights
      You have all of the following rights concerning the data we collect:

      • Right to access your data

        You are entitled to receive confirmation that your personal data is or is not processed and, when processed, you are entitled to access said data. This right also includes that of receiving a copy of data processed.

      • Right to request rectification of your data if incorrect.

        You are entitled to request that your data be amended, updated or completed when inaccurate, incorrect, incomplete or obsolete.

      • Right to request deletion of your data

        You are entitled to request deletion of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

        • data is no longer necessary in light of the purposes for which it is collected or processed in any other manner;

        • you withdraw consent over which processing is based, and there is no legal basis for processing;

        • you object to processing and there is no overriding legitimate ground for processing;

        • you consider that your data has been processed illicitly;

        • your data should be deleted to respect a legal obligation.

      • Right to restrict processing
        You are entitled to request that we limit the use of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

        • you dispute the accuracy of the data we are processing about you;

        • you consider that processing is unlawful and you object to deletion of your data;

        • data is still required for exercising or defending your rights in court even though NOVAQUARK no longer requires this data.

      • The right to object to processing by withdrawing your consent where we have obtained your consent to process your personal data for certain activities (with it being reiterated that this withdrawal may not harm the legality of processing based on the consent granted prior to its withdrawal). We will cease to carry out the particular activity you previously consented to, unless we consider that there is an alternative reason to justify our continued processing or you data for this purpose, which we will inform you of if applicable.

      • The right to benefit from data portability
        You are entitled to reclaim your data provided to NOVAQUARK, in a structured format, commonly used and machine-readable, and the right to transfer this data to another processing manager, for instance so as to change service provider.

      • Right to lodge a complaint to the National Data Protection Authority (CNIL)

        If you consider that NOVAQUARK has defaulted in respect of its obligations in light of your personal data, at any time you may issue a complaint or make a claim to the competent authorities. In France, the competent authority is the National Data Protection Authority (CNIL) to whom you may issue a claim electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

    2. Terms for exercising rights

      You may exercise the aforementioned rights with a written and detailed request at the following address: https://dualthegame.com/privacy.

      Due to the obligation of security and confidentiality in data processing incumbent upon NOVAQUARK, you are hereby informed that your request will be processed subject that you provide proof of your identity, notably by producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

      NOVAQUARK will determine whether this is admissible or not within one month following receipt of the claim. In such instance as it is deemed admissible, NOVAQUARK will provide all information requested or implement the rights claimed within the aforementioned deadline.

      If, given the complexity of the claim or the number of requests received, the aforementioned deadline cannot be respected, NOVAQUARK will notify you prior to expiry of this deadline, of this deadline being pushed back by a maximum of two months following its decision.

      NOVAQUARK hereby notifies you that it will be entitled, where applicable, to object to any requests which are clearly abusive (in their number, repetitive nature, or systematic).

      In such instance as NOVAQUARK does not follow up on your request, we will inform you in the aforementioned deadlines of the grounds on which our decision is based and your option to refer a complaint to the National Data Protection Authority (CNIL).

  11. Security
    Although absolute security cannot be guaranteed on the Internet, please be assured that we take reasonable steps in line with legal and technical developments to guard against the loss, misuse and alteration of the information under NOVAQUARK's control. We will continue to maintain and improve these measures over time. Personal information collected by NOVAQUARK and potential third party data processors appointed on our behalf is stored in secure operating environments that are designed so as not to be available to the public.

  12. Changes to our Privacy Policy
    If we decide to change this Privacy Policy, the changes will be posted on this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We will not use or disclose personal information provided to us in ways unrelated to the ones described above without informing you and providing you with an opportunity to opt-out of these unrelated uses.

  13. Access to your information
    You can contact us at any time through the Website contact form and request to see the personal information we have collected through this Website, which relates to you, and to ask us to make any necessary changes to correct or update your information. To protect your privacy and security we will take reasonable steps to verify your identity before granting access.

  14. Questions and complaints
    If you have any questions or complaints either relating to the Website or this Privacy Policy, you can contact our Data Protection Officer’s (DPO) at the following address : privacy@novaquark.com.

Last updated: May 25, 2018
Version 4