Privacy Policy

Last Updated: March 4, 2024

Hello! Welcome to our Privacy Policy.
Here at Ation Studios, we take your privacy seriously and want you to feel safe while using our services. In this policy, we clearly explain how we collect, use, store, and protect your data, following the best international practices (such as the GDPR, LGPD, and the CCPA/CPRA standards) as well as local requirements.

1. Who We Are and How to Contact Us
ATION STUDIOS
Address: São Paulo – Brazil
Email: [email protected] (for privacy-related matters)
Online Form

2. Data We Collect
To provide a personalized and secure experience, we collect data in two ways: data that you provide directly and data collected automatically during the use of our Services.

A. Data Provided by You
This data is voluntarily submitted, usually when creating your account or interacting with us on certain services. Not all of our services require personal information – in some cases, we only collect data for internal analysis, which remains anonymous.

• Basic Information: Name, email, nickname (used for account creation).
• Profile Data (optional): Age, photo, gaming preferences.
• Security: Passwords (stored in encrypted form), recovery questions, and other authentication data.
• Important: For account-related data, you can request a copy or deletion of the data where applicable.

B. Data Collected Automatically
This data is generated during your interaction with our Services and is generally not linked to a personal identity, being used to improve and personalize your experience.

• Device: Model, operating system, unique device identifier.
• Location: Country (based on IP) and, if authorized, precise location data.
• Service Usage: Game progress, session time, interactions, etc.
• Cookies and Similar Technologies: Used for personalization, security, and analysis. You can manage your preferences in your browser.

Note: For services that do not require the creation of a personal account – where the collected data is used solely for internal analysis – it is not possible to identify the source of the data on an individual basis. Therefore, in these cases, we cannot provide copies or perform specific deletions since the data is kept in an aggregated and anonymous form.

3. Why We Collect Your Data
We use the collected data to ensure that our Services operate efficiently, securely, and tailored to your needs. Below is a simplified table of the purposes and respective legal bases (according to GDPR/LGPD):

Purpose	Legal Basis
Create and manage your account	Contract execution
Send offers and updates	Consent (you may opt out)
Prevent fraud	Legitimate interest
Improve our games and services	Legitimate interest

4. Data Sharing
Your data may be shared in the following situations:

• Service Partners: We use trusted partners to offer and enhance our services, such as:
  • Google Ads (for advertisements)
  • Unity Analytics and Game Analytics (for game analysis)
  • Google Cloud (for cloud storage)
  • Photon (for Multiplayer services)
    (Please refer to the links to each partner’s privacy policy.)
• Legal Authorities: In cases of investigations or to comply with legal obligations.
• International Transfers:
  Your data may be processed outside of Brazil or the European Union. When this occurs, we adopt measures such as standard contractual clauses or certifications (e.g., Privacy Shield for data directed to the USA) to ensure adequate protection.

5. Your Rights
You have control over your information and can exercise the following rights:

• Access, Correction, and Deletion: Request to view, correct, or delete the data associated with your account.
• Withdrawal of Consent: For example, canceling the receipt of newsletters.
• Portability: Request a copy of your data in a structured format.
• Opposition to Automated Decisions: Such as the creation of advertising profiles.

6. Data Retention and Deletion

• Active Accounts: Your data is maintained while you use our Services.
• Inactive Accounts: Data from accounts inactive for an extended period will be deleted, except when legal obligations exist (such as payment records).

7. Security
Your security is our priority. To protect your data, we have adopted:

• End-to-End Encryption: To secure sensitive information.
• 24/7 Monitoring: Security systems that monitor accesses and potential breaches.
• Continuous Training: Our team receives annual training on data protection.
• Secure Infrastructure: Servers and data centers with advanced physical and technological measures.

7.1 Procedure in Case of Security Incidents and Data Breaches

• Detection and Containment:
  We monitor our systems and, upon identifying suspicious activity, immediately activate measures to contain the incident and limit its impacts.
• Analysis and Notification:
  We investigate the origin and scope of the incident. If personal data is compromised, we notify the affected users and, when necessary, the competent authorities.
• Adoption of Corrective Measures:
  We correct the vulnerability, reinforce our systems, and update our team training to prevent future occurrences.

8. Children
We prioritize protecting the privacy of minors. To ensure compliance with applicable laws, we have established the following guidelines:

• Minimum Age Requirement:
  We require users to be at least 13 years old globally or 16 years old within the European Union. Our services are designed for individuals who meet these age requirements.
• No Intentional Collection:
  We do not intentionally collect personal data from minors. Our registration processes and services are structured to discourage the input of personal information by those below the minimum age.
• Parental Consent:
  In cases where there might be uncertainty regarding a user’s age, or if data from a minor is inadvertently provided, we require appropriate parental or guardian consent before any personal data can be retained or processed.
• Immediate Data Deletion:
  If we discover that personal data has been collected from a minor without proper parental consent, we will promptly delete that data from our systems to protect the minor’s privacy.
• Encouraging Parental Oversight:
  We encourage parents or guardians to contact us if they suspect that data from their child has been collected without consent. This allows us to take swift action and ensure the privacy and security of the minor’s information.

9. Cookies and Tracking
We use cookies and similar technologies to:

• Functionality: Save your progress and personalize the Service.
• Analysis: Understand how you use the Services to improve them.
• Personalized Advertising: Display advertisements that are relevant to you.
  You can manage your preferences in our Cookie Preferences or through your browser settings.

10. Updates and Complaints

• Policy Updates: Any relevant changes will be communicated by email or directly in the game.
• Complaints: If you have any questions or wish to file a complaint, please send an email to [email protected].

✨ Thank you for trusting Ation Studios!