privacy policy
Last version: 16/10/2020
A – MAIN GOALS OF THIS PRIVACY POLICY
Our Privacy Policy shows users (referred to as “You” on this document) of the Profane game, its respective website and other auxiliary platforms how we process your personal data. This processing may involve collection, use, storage and even changes to these data.
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The purpose of this document is to be as transparent as possible with you. To accomplish this goal, we keep our Privacy Policy always updated, and we will inform you whenever we make any changes to our personal data processing activity.
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However, besides that purpose, this document should also serve as a guideline that you can follow if you want to be informed about your rights. This document, therefore, empowers you regarding the processing of your personal data.
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Finally, you should be aware that this Privacy Policy has been designed for INSANE to comply mainly with the European General Data Protection Regulation (Regulation (EU) 2016/679 – “GDPR”) and the Brazilian General Data Protection Act (Federal Law n. 13.709/2018 – “LGPD”) with regards to your rights. Notwithstanding, we chose to present you some key concepts (such as “legitimate interest”, “consent”, “performance of a contract” etc.) without referring to any of the above legislations, as we understand that those concepts have been reproduced on the majority of the data protection legal frameworks. Should there be any specific provisions that we have to comply with (considering the territorial scope of the various legal frameworks), contact us and we will update this Privacy Policy to ensure that your rights will be fully respected.
B – Personal and Anonymous Data and its Process
Personal Data means any information relating to an identified or identifiable natural person. Your social security number, for example, identifies you almost immediately. On the other hand, there are some data that, even though they may not identify you as easily as your social security number, combined with other data or through the usage of a software, lists and systems, can make you identifiable. Take, for example, your usage data of our platform, website or Profane. When some usage data is collected, it is possible to identify some standards and combine data that can result in your identification.
Anonymized data, on the other hand, are personal data which, after some processes involving reasonable efforts, costs and technology, may lose the capacity to identify someone or make a person identifiable.
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After this brief explanation, we will expose the personal or anonymized data that we actually process, but it is important to remember that this process involves several activities. We will describe below the collected data and their respective processing:
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Data collected when you browse our Site (“Site Usage Data”):
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When you register on our site, we collect your e-mail and account password, which is encrypted.
If you choose to take our survey, we also collect your name, email address, country and favorite game(s), as well as whether you wish to be recruited to test the Alpha version of Profane.
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Besides those data, we do not collect any other information, not even if you just browse our site without a registration.
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Data we collect when you subscribe to our Newsletter ("Newsletter Data"):
If you choose to receive news from Profane via our Newsletter, we will collect your name, e-mail and country.
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Data we collect when you browse our blog or forum ("Profane Network Data"):
When our internal social networks are active, and when you browse our blog or forum, we may collect your IP, the operating system of your access device, the date and time of access, the browser and the respective version you used.
In our blog, if you choose to receive news of our posts, we will collect your name and email. Additionally, if you interact to our posts, we will also collect: comments, likes and shares.
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Finally, if you sign up to our Forum, we will also collect your email, username and account password. In addition, we also store all posts.
Data we collect when you make a purchase ("Ecommerce Data"):
We use third-party payment services to operate purchases on our platform, including of the Profane itself. We may collect, in connection with these third-party payment services, data such as: name, email, account login and password, IP, the operating system of your access device, the date and time of access, your browser and its version, date of birth, address, identification document, purchase history, history of payment attempts and login records at Profane.
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Please note that when using third-party payment services, you may be subject to the privacy policies and specific terms of those third-parties.
Data we collect when you browse Profane pages on third party social networks ("Social Network Data"):
When you browse Profane pages on third party social networks, such as Discord, INSANE collects data in a “Dashboard” format (a type of graphical interface that provides generalized visualizations), in a collective and anonymous way, in order to conduct some analytics.
However, we emphasize that those social networks belong to third-parties, and therefore you are subject to the privacy policy of those third parties.
Data we collect when you play the Profane ("Profane Data"):
Every time you access and play the Profane, as long as it is available, INSANE collects the following data: name, login and password, type of access key purchased, IP, computer specifications (video card and CPU data), duration of each session in the Profane, activities and evolution inside the game and messages exchanged inside the game.
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Data we collect when you communicate with us ("Contact Data"):
If you contact INSANE, for example to make a report, we store all information provided by you, including the name and e-mail from which the information was obtained.
C – Personal Data Processing
In order to facilitate our explanation and to show you how we process your personal data and for which purpose, we have prepared the sheet below:
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Data Type: Site Usage Data
Processing Purpose:
- Verification and protection against fraud and other illegal activities;
- Improvement of the features offered by our platform;
- Creation of generic statistics to improve Profane;
- Creation of generic statistics to understand the generality of our players’ profile in order to improve Profane;
- Recruitment of users for the trial of Alpha Version of Profane and other tests that we may be running.
Legal Basis:
Legitimate Interest.
Consent, in the event that the user chooses to answer our survey and informs that he would like to be recruited to test the Alpha version of Profane and other tests that we may be running.
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Data Type: Newsletter Data
Processing Purpose:
- Communication with our users;
- Support and promotion of our activities.
Legal Basis: Consent
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Data Type: Profane Network Data
Processing Purpose:
- Verification and protection against fraud and other illicit activities related to posting;
- Communication channel with Users;
-Support and promotion of INSANE and Profane activities;
- Development of new features for our platform;
- Improvement of the features offered by our platform;
- User Support.
Legal Basis: Legitimate Interest.
Data Type: Ecommerce Data
Processing Purpose:
- Verification and protection against fraud and other illicit activities;
- Development of new features for our platform;
- Creation of generic statistics to evaluate the performance of our platform;
- Improvement of the features offered by our platform;
- Billing the user;
- Validate the user's access to the Profane;
- User Support.
Legal Basis: Performance of a Contract.
Legitimate Interest, in the event of verification and protection against frauds and other illegal activities, the development of new features for our platform and the creation of generic statistics.
Data Type: Social Network Data
Processing Purpose:
-Support and promotion of INSANE and Profane activities;
- Development of new features for our platform;
- Improvement of the features offered by our platform.
Legal Basis: Legitimate Interest.
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Data Type: Profane Data
Processing Purpose:
-Run Profane;
- Verification and protection against frauds and other illicit activities;
- Development of new features for our platform;
- Creation of generic statistics to evaluate the performance of our platform;
- Improvement and correction of the features offered by our platform;
- Inspection and punishment of offensive and/or illegal practices by users;
-User Support.
Legal Basis: Performance of a Contract.
Legitimate Interest, in the event of verification and protection against frauds and other illicit, statistics and improvement and correction of some features.
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Data Type: Contact Data
- Communication Channel with users;
- Improvement and correction of the features offered by our platform;
- Inspection and punishment of offensive and/or illegal practices of Users;
-User Support
Legal Basis: Performance of a Contract.
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D – Security of Your Data
You should be aware that all security systems are subject to errors and illegal intervention by third parties. However, safety is one of our top priorities and we have adopted high standards of protection in accordance with industry best practices.
INSANE only contracts companies that are qualified to offer services such as hosting, database and payment methods and which adopt information security practices that are in accordance with the highest standards of the market, such as encryption of stored data.
But you know very well that the security of our systems does not automatically implies the security of our work environment. Therefore, we also have internal security standards and processes that reduce the risk of leakage and/or breach of your personal data, including among our employees and collaborators.
To begin with, INSANE is committed to ensure that any access to your personal data by our employees and collaborators will be confidential. Furthermore, one of the principles that we respect is that only employees and collaborators who need to access your personal data (to enforce the contract with you, for example) will access them.
We also seek to make our employees and collaborators aware of the importance of protecting your personal data and our data, in which privacy and the protection of personal data are part of our DNA. This awareness generates reflexes in our work environment, and in addition we try to prevent the use of our systems outside this environment.
Finally, INSANE processes your data only in the limits that are necessary for the achievement of its purposes, and seeks to keep the data stored for the shortest period of time as possible, based on the fulfillment of some regulatory and/or administrative obligations.
E – Data Shared with Third Parties
We share your data with our employees and collaborators (see item above), and also with third-party service providers (inside and outside Brazil), but always as an exceptional way and in accordance with the relevant legislation.
The third-party service providers with whom we may share your personal data are:
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Third Parties: AMAZON WEB SERVICES, INC. (“Amazon”) or other similar service provider in addition or in substitution of Amazon.
Shared Data:
- Profane Network Data;
- Ecommerce Data.
Purpose:
INSANE uses Amazon's database services and respective auxiliary services (or of a similar service provider) to enable the operation of the Profane website and other auxiliary platforms. This is an indispensable transfer for the execution of INSANE services and the running of the Profane.
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Third Parties: WIX (https://pt.wix.com/), Sendgrid (https://sendgrid.com/) or other similar service provider in addition or in substitution of WIX.
Shared Data:
- Newsletter Data.
- Site Usage Data (to WIX).
Purpose:
INSANE uses auxiliary services to enable the mailing of e-mails containing Profane's news.
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Third Parties: Google LLC and affiliates (Google Analytics) or other similar service providers in addition or in substitution of Google.
Shared Data:
- name, email, IP, the operating system of your access device, the date, and time of access..
Purpose: We share your data with Google or other similar service provider to monitor user behavior on our site, such as navigation performed and session time.
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Third Parties: Facebook Inc. and affiliates (Facebook Pixel), Twitter or other similar service provider in addition or in substitution of Facebook and Twitter.
Shared Data:
- IP, the operating system of your device, the date and time of access.
Purpose: The data we share with Facebook and Twitter or similar service providers are used to provide you better targeted ads. In addition, Facebook tracks some of your information from a Cookie (see our explanation on Cookies below).
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Third Parties: Unity Technologies, Inc. (Unity Analytics) or other similar service provider in addition or in substitution of Unity.
Shared Data:
- IP; the operating system of your device, the CPU of your machine, the date and time of access.
Purpose: We share this data with Unity or other similar service provider to monitor new users who are playing Profane, as well as the number of active users daily and monthly, in order to improve the Profane and our other services. In addition, some of this data is shared with Unity for marketing purposes.
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Our third-party service providers, in some cases, maintain their data centers, places where the data we share with them are physically stored, in the United States of America or other countries in different locations around the world. Consequently, INSANE can perform an international transfer of your data, which should always be done in accordance with the competent legislation. In the case of your personal data, the transfer made by INSANE has the main goal of making it possible to fulfill the contract signed with you, and in any cases involving international transfer, we carefully choose third-party service providers who adopt the highest standards of data protection.
In addition, please note that in some cases you can change your browser's privacy settings to disable the collection of your data from Cookies, or perform some acts to stop the processing of your data. Therefore, if you have any questions about how these companies process your data, we suggest that you visit the official website of these companies and read their privacy policies, as well as other documents dealing with the privacy and confidentiality of your data.
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F – COOKIES POLICY
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A Cookie is a small file that is downloaded on your computer when you visit a website, and it is stored for a certain time.
Cookies are used by many websites and applications and can do several things, such as remembering your preferences, recording what you have put in a shopping basket, and counting the number of people looking at a website. The Cookies also allow a personalized navigation, within certain limits. For instance, if you access a website from an IP located in Brazil, and this website uses Cookies, this website’ information will probably appear to you in Portuguese.
The data that are stored with Cookies can be temporary (i.e. such data is discarded at each access) or can be stored for a longer period (which allows, for example, the access to a site without the need to log in).
INSANE uses Cookies when you browse our site, blog, forum and Ecommerce platform, in order to validate the authentication of the user who is accessing an account and to prevent improper access. It is usually possible, from your browser settings, to disable Cookies. However, be aware that, depending on the settings you choose, this may block your access to our services (especially if the settings you make prevents us from validating your access) or change your experience in relation to what we offer to you.
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G – YOUR RIGHTS REGARDING YOUR PERSONAL DATA.
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You, as the holder of your personal data, have numerous rights guaranteed by law. Those rights mainly involve easy access to information related to the processing of your personal data.
This information shall be provided by INSANE, upon your request, in a clear and plain language and free of charges most of the time. You may request, for example, information on the following topics:
(a) specific purpose for which we process your personal data (information already contained in this Privacy Policy);
(b) form and duration of the processing of your personal data;
(c) our identification and other information necessary for you to contact us (information already contained in this Privacy Policy);
(d) information about the sharing of your personal data with third parties, if those third parties jointly determine with us the purpose of the processing of your personal data (information already contained in this Privacy Policy);
(e) confirmation that we process your personal data and which data are being processed;
(f) access to your data that is being processed by us (INSANE is obligated, by law, to store your personal data in a manner that facilitates your access);
(g) correction of any incomplete, inaccurate, or outdated personal data that is being processed by us; and
(h) anonymization, blocking or deletion of personal data that is unnecessary, excessive or processed in violation of the provisions of this Privacy Policy or the relevant personal data protection legislation.
In addition, you may choose to revoke the consent given for the subscription of our Newsletter and/or for the recruitment of the Alpha version of Profane and other tests we may be running, as well as choose to delete this data, provided the legal grounds of conservation by INSANE are respected.
H – ADDITIONAL INFORMATION
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INSANE is concerned with the privacy and protection of your personal data, from the conception of our products and services to their actual offering. For that reason, we describe in this chapter some additional information that may interest you:
(a) Every time we change any purpose of the processing of your personal data, the form or duration of this processing and/or establish the shared use of such data with third parties, you will be informed as soon as possible; and
(b) You may exercise the right of objection against certain personal data that is being processed by us, in particular when such processing is not based on your consent. As INSANE aims to respect the principle of necessity (we only process your personal data when it is strictly necessary to enable our services and the features offered through Profane), we believe that this will not be necessary, but it is your right and we feel that you need to be informed.
I – CONTACT
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Profane belongs to INSANE DESENVOLVIMENTO DE SOFTWARE LTDA., a limited liability company duly incorporated and validly existing under the laws of Brazil, whose registered office is at Avenida Nove de Julho, nº 4877 – Sala 61 – Bloco B - Jardim Paulista, Zip Code 01407-200, City of São Paulo, State of São Paulo, Brazil.
If you want to clarify any question about our Privacy Policy, you can contact us directly through the following e-mail: contact@profanemmo.com
Our average response time is up to 5 days, but we guarantee that you will be treated with all the care and attention you deserve!
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