EasyAntiCheat Oy (“Kamu”, “we” or “us”) is a Finnish company which provides solutions against online game cheating to game developers, publishers and other third parties alike (“Customers”) such as Freejam. In order to provide the said solutions, we provide a wide range of game security services to Freejam, including client-side protection, server-side middleware, and expert developer centric support (“Services”).
When providing the Services to Freejam, Kamu processes personal data of the players or other end-users (“Player” or “You”) who play or otherwise use the online video game CardLife or other services of Freejam (“Game”).
The purpose of this privacy statement is to provide you information regarding the collecting and processing of your personal data and information regarding your rights as a data subject in accordance with the applicable legislation in the EU. From this privacy statement You will find a more specific description of how your personal data will be processed when providing the Services to Freejam.
Information regarding the processor
- Processor: EasyAntiCheat Oy, Tammasaarenkatu 3, FI-00180 Helsinki. Business ID 2585063-4
- Name of the register: The end-user register of Kamu
- Contact person: Simon Allaeys.
- Contact information: www.easy.ac/contact/; Postal address: EasyAntiCheat Oy, Tammasaarenkatu 3, FI-00180 Helsinki.
The purposes for the processing
The purpose of processing personal data is to provide solutions against cheating and fraud in CardLife. In practice this means information is gathered of the Players interacting in the Game and the gathered information is exchanged between Kamu and Freejam.
Kamu uses your personal data to the following purposes.
- Prevention and solving of misuse of the Game by the Player (e.g. cheating and other unacceptable methods);
- Identification and solving of misuse of the Game by the Player (e.g. cheating and other unacceptable methods);
- Compilation of statistics, analyzing and auditing regarding Player;
- Identification of the Player’s digital player account;
- User-specific adaptation of the Service;
- Producing and developing the Services; and/or
- Other equivalent purposes of use
The legal basis for the processing
The processing of the personal data is based on a legitimate interest of Freejam and Kamu. In alignment with the various personal information protection regulations worldwide, Kamu has concluded that the legitimate interest to process the personal data is based on the following facts.
- Freejam has a legitimate interest to prevent cheating and fraud in CardLife, and the data subjects are aware of the processing activities while having the option to opt-out of processing by not accessing the Game;
- Processing of the personal data by Kamu is necessary in order to offer the Services and prevent cheating and fraud in the Customers’ Games; and
- Kamu only processes personal data which relates to interaction with the Game and the data is only shared with Freejam, the Customer operating the Game in question, for the sole purpose of Kamu providing the Services.
Kamu regularly assesses the legitimate interest for processing the personal data with a three-part balancing test, which considers the nature of the personal data, the reasonable expectations of the data subjects, and the likely impact of the processing activities. Based on this assessment, Kamu and Freejam have determined there is a legal basis for the processing of the personal data. The nature of the personal data is non-sensitive, while data subjects can reasonably expect Freejam to actively prevent and detect cheating and fraud in the Game. Freejam has a sole discretion to decide what kind of the methods identified in the information are being interpreted as cheating or fraud, and what kind of sanctions are to be implemented, if any.
Additionally to the above, your use of the Game requires You to have given your consent to process your personal data as provided in this privacy statement. By using CardLife as provided by Freejam or by accepting the terms and conditions of the Game, You also accept the collection and processing of the personal data referred to herein and the terms of this privacy statement. The processing of your personal data is necessary for the performance of the end-user license agreement between You and Freejam.
If You do not wish or allow your personal data to be processed, do not use or access CardLife.
Personal data we collect and process
Upon registration or during the use of CardLife, the following data may be collected and processed about You.
- Username and account identifier;
- In-game reports filed involving You;
- In-game movements and other gameplay behavior;
- Technical information about the hardware used to play the Game, such as motherboard manufacturer, CPU identifier, GPU identifier, and general performance indicators;
- Technical information about the methods, technics, technologies or alike used by You within the Game that may be suspected to indicate the use of methods that are considered unacceptable by Freejam; and/or
- Other equivalent information
In addition, the Service may collect automatically saved data, such as the technical log of the server (e.g. your IP-address, your session history), during the use of the Game.
The abovementioned data is primarily obtained from your use of CardLife. Additionally, player account identification data may also be obtained from Freejam or the Freejam’ service providers such as Steam, GOG, and others (“Service Providers”). You have accepted these disclosures by using the Game or Service Providers.
Sharing of your personal data
Your data will be regularly disclosed to Freejam and the Service Providers in order to prevent or investigate misuse within CardLife and to the extent required to implement the sanctions for misuse within the Game.
Your personal data will not be sold, rented, leased, licensed, borrowed or otherwise assigned or disclosed forward to third parties other than the ones expressed in this privacy statement. However, if the business regarding the Service or the shares of Kamu will be redeemed, sold or otherwise assigned, the Player data can be transferred to the party purchasing the shares or the business.
Transfers to third countries
Your Personal data may be transferred outside of the European Union or the European Economic Area to the parties expressed in this privacy statement.
For avoidance of doubt, the transfer of information is always executed in legal and professional manner. We are relying on valid EU data protection safeguards, such as the EU Model Clauses within our company, when transferring your personal data.
Storage period of your personal data
General profile data and aggregated statistical data about You are stored for the entire duration of the legitimate interest of the Customer and the service agreement between Kamu and Freejam for CardLife.
Other personal data are processed in real-time and stored for a duration of maximum 5 days. If the data is suspected to indicate misuse in the Game, the relevant data samples are stored for at most 3 months. If the data is determined to indicate misuse in the Game, the data remains stored until no longer necessary for the purposes provided herein.
Your rights as a data subject
As a data subject, You have the following rights with regards to your personal data. In order to use the rights referred to below, You may contact Freejam directly or alternatively Kamu at www.easy.ac/contact/
Right of access
You have the right for access, however restricted, to your personal data which we have collected, as well to other information provided in Article 15 of the General Data Protection Regulation. You will not gain access to the information which includes trade secrets or intellectual property, such as the information used to identify methods for cheating or fraud in CardLife.
Right of rectification
You have the right to obtain from us a rectification of inaccurate personal data concerning you. Inaccuracy of personal data shall be determined in good faith by an expert at Kamu.
Right to erasure
You have the right to obtain from us the erasure of your personal data if any of the following conditions are true.
- Your personal data is no longer necessary for the purposes provided herein, such as when you stopped playing CardLife.
- The legal ground for processing is no longer valid, such as when Freejam has terminated the data processing agreement with Kamu.
- You have objected to the processing and there are no overriding legitimate grounds for the processing.
- The personal data has been unlawfully processed.
Right to restriction of processing
You have the right to obtain from us restriction of processing if the circumstances provided in Article 18 of the General Data Protection Regulation apply. However, you will not be allowed to use or access the Game during the period You have restricted us from processing your personal data.
Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, such as the correspondence with the Kamu support team. In line with the right of access, You will not gain access to the information which includes trade secrets or intellectual property of Kamu.
The processing of your personal data will include automated-decision making. The way we process the data enables us to find out whether particular personal data is showing anomalies and may indicate misuse of the Game.
If You are deemed to have misused CardLife based on the automated-decision making, You will be flagged and reported to Freejam, who is the Customer operating the Game in question. It is up to Freejam to determine what consequences are implemented for the identified misuse of the Game. If Freejam decides to sanction You based on the information we have provided, You have the opportunity to appeal the automated-decisions by contacting our helpdesk at www.easy.ac/contact/, at which point an expert will review the data and revisit the decision.
The principles of how the data register is secured
The Service is provided through secured communication and the personal data is stored by using the best practices of the industry. The personal data is accessible only by parties obligated to maintain the confidentiality and the secrecy and whose employment tasks require to access to such data.
How to contact us
In case you have questions regarding this privacy statement or general questions regarding the privacy of your personal data, You can contact our customer support at www.easy.ac/contact/