MIDNIGHT FORGE OY (VIRTUAL DAWN)
Revised: 11/11, 2023
Midnight Forge Oy (Virtual Dawn) VAT number 2504471-2
[email protected], Uittotunnelinkatu 8 C17, 33250 Tampere FINLAND
This Privacy Policy explains Midnight Forge Oy’s (Virtual Dawn, hereinafter referred to as Virtual Dawn) data practices for the products, services, and websites (collectively the “Services”) that Virtual Dawn offers to consumers and businesses. [cite: 1]
* Scope of this Policy and Who We Are [cite: 2]
* Information We Collect and Our Lawful Bases for Processing [cite: 2]
* Cookies and Similar Technology [cite: 2]
* How We Use Information [cite: 2]
* When We Share Information [cite: 2]
* Manage Your Account, Communications, and Data [cite: 2]
* Data Retention [cite: 2]
* Children’s Privacy [cite: 2]
* Data Security [cite: 2]
* International Transfers [cite: 2]
* Other Midnight Forge Oy (Virtual Dawn), Third-Party Terms, and Links to Other Sites [cite: 2]
* Public Postings [cite: 2]
* Contact Us [cite: 2]
* Changes to Privacy Policy [cite: 2]
Asianajotoimisto Puranen, Kiviluoto & Co Oy
Kauppakatu 41 A, PL 7940100 Jyväskylä (014) 4110 600 www.puranen-kiviluoto.fi
[email protected] [cite: 2]
SCOPE OF THIS POLICY AND WHO VIRTUAL DAWN IS
This Privacy Policy applies to Virtual Dawn. [cite: 3] Please read this Privacy Policy carefully. [cite: 4] The Services also are subject to Virtual Dawn’s Limited Software Warranty and License Agreement (“EULA”), Terms of Service, and any other policies included in Virtual Dawn’s Services. [cite: 4] This Privacy Policy supplements privacy disclosures provided with your software product and from your software manufacturer. [cite: 5]
* Virtual Dawn is the data controller responsible for information. [cite: 6]
INFORMATION VIRTUAL DAWN COLLECTS AND VIRTUAL DAWN’S LAWFUL BASES FOR PROCESSING
You provide Virtual Dawn with information directly, such as when you set up an account with Virtual Dawn. [cite: 7] Virtual Dawn also collects information about you and your activity when you use Virtual Dawn’s Services Via Head Set and installed Virtual Dawn software. [cite: 8] Virtual Dawn may use online tracking, such as cookies and similar technology, to collect information when you connect to Virtual Dawn’s Services, and Virtual Dawn collects information from third parties (such as advertising networks and external business partners). [cite: 9] Virtual Dawn also installs administration tools for the headsets that they rent to the client. [cite: 10] This is the way to get newest updates and content expansions to clients with minimal work for the client and with efficiency. [cite: 11] This gives Virtual Dawn the ability to control the device from distance for problem solving. [cite: 12] This can be done also to clients own headsets but the client must be aware that Virtual Dawn can control the headset if this is in place. [cite: 13] Clients can also become the admin of their own headsets and mass update the simulations independently. [cite: 14] The administration tools are not needed for Virtual Dawn software to work, but are given as an option to maximize the ease of use. [cite: 15]
The types of information that Virtual Dawn collects depend on how you use the Services and interact with Virtual Dawn. [cite: 16] You can control the personal information Virtual Dawn collects from you unless Virtual Dawn needs it for the requested activity (e.g., to provide the Services you’ve requested or purchased, to confirm who you are, or to participate in an event). [cite: 17] Virtual Dawn will let you know when information is necessary. [cite: 18]
Information You Provide
You provide Virtual Dawn with information when you use the Services, such as when you:
* create an account, or register for or use the Services; [cite: 19]
* subscribe to newsletters and communications; [cite: 20]
* comment on Virtual Dawn’s message boards, forums, chat rooms, feeds, sites, or other Services; [cite: 20]
* purchase or redeem one of Virtual Dawn’s products or services, including physical items, virtual items, or add-ons; [cite: 21]
* download, install, or access demos, programs, or other software; [cite: 22]
* contact Virtual Dawn for support or other purposes; [cite: 22]
* use Virtual Dawn’s email / share features; [cite: 23]
* participate in events, contests, promotions, or surveys; [cite: 23, 24] or
* participate in an activity where you can provide, or need to provide, your information. [cite: 24]
Depending on the Service or your activity, Virtual Dawn collects information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, hardware configuration, hardware ID, software products played, survey data, IP address, geolocation, and the systems you play on. [cite: 25] Virtual Dawn combines this information across computers or other devices that you use. [cite: 26] Using the simulations Virtual Dawn has created/ or any other software provided by Virtual Dawn. [cite: 27]
When you use the Services on hardware connected to the Internet, Virtual Dawn receives information about your session with the simulations even if you are not specifically notified at the time or do not take any actions to actively give Virtual Dawn this information. [cite: 28] Your session with the simulation’s information includes achievements, scores and performance, IP address, MAC address or other device ID, device information, and other information and statistics regarding your Service use. [cite: 29] Virtual Dawn collects information even if you do not register for the Services and Virtual Dawn may collect VR Session / Desktop version session use information while you are offline. [cite: 30] Offline information is transmitted to Virtual Dawn when you next connect to the Internet. [cite: 31] Virtual Dawn may combine use of Virtual Dawn’s software information with other information Virtual Dawn has about you. [cite: 32]
Social Networking Information
Virtual Dawn collects information when you use third-party platforms like a APP platform account, app purchase network service account, or social networking service account to connect to or engage with Virtual Dawn’s Services. [cite: 33] When you use these third-party platforms or link your Virtual Dawn account, the third-party platforms provide Virtual Dawn with information about you. [cite: 34] For example, depending on your use of, or activity on the third-party platform, Virtual Dawn receives your username, your friends list, or account information necessary to provide a purchased item. [cite: 35] The third-party platform may allow you to control what information is provided to Virtual Dawn. [cite: 36] Virtual Dawn is not responsible for the terms, policies, disclosures, or actions of any third-party platforms. [cite: 37]
Information from Third Parties
Often with games published by Virtual Dawn, created with Virtual Dawn SDK or has anything to do with Virtual Dawn, we do use Unity Game Engine and its Unity Gaming Services as to which you can find more information here <https://unity.com/legal/game-player-and-app-user-privacy-policy> this is industry standard procedure to take care about rankings in video games and keep up the achievements. [cite: 38] You cannot “remove” data from this system since it is already anonymous. [cite: 39]
Virtual Dawn receives information from third parties to update the information that Virtual Dawn collects about you. [cite: 40] For example, Virtual Dawn receives information from public databases, hardware manufacturers, analytics providers, game developers, and other business partners that include demographic information and information about your interests. [cite: 41] Virtual Dawn obtains information from social media and other publicly available sources, which Virtual Dawn may use to better understand its users or to seek intelligence about breaches of Virtual Dawn’s Terms of Service. [cite: 42] Virtual Dawn also receives information from other individuals who use its Services. [cite: 43] This may include information about you if you are mentioned in comments on Virtual Dawn’s message boards, forums, chat rooms, or other Services, or an individual sends Virtual Dawn a direct message, for example, about an alleged breach of our Terms of Service. [cite: 44]
Lawful Basis to Process in Certain Locations
Virtual Dawn collects, uses, and otherwise processes your information when Virtual Dawn has a lawful basis, as follows:
* Consent: Virtual Dawn asks you for consent to collect or use your personal information for specific purposes, such as when Virtual Dawn wants to send you emails about special offers or competitions, or if you decide to link your Virtual Dawn account with a third-party service. [cite: 46]
* Contract Performance: Virtual Dawn processes your personal information when Virtual Dawn needs to perform and manage a contract with you, such as Virtual Dawn’s Terms of Service, or to take steps at your request before Virtual Dawn enters into a contract with you, such as to complete transactions with you and to allow you to use our software online. [cite: 47]
* Legal Requirement: Virtual Dawn processes your personal information when required by law. [cite: 48]
* Legitimate Interest: Virtual Dawn processes your personal information when necessary for Virtual Dawn’s, or others’, legitimate interests and when these interests do not outweigh your own rights and interests. [cite: 49, 50, 51, 52, 53, 54] This covers processing for purposes such as improving Virtual Dawn’s products and services; performing analytics and using surveys to better understand Virtual Dawn’s users; conducting direct marketing (when Virtual Dawn does not need your consent); otherwise supporting Virtual Dawn’s business, operations, and services; ensuring the proper function, security, and integrity of Virtual Dawn’s services; dealing with user questions; enforcing Virtual Dawn’s Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of Virtual Dawn’s EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement. [cite: 49, 50, 51, 52, 53, 54]
COOKIES AND SIMILAR TECHNOLOGY
Cookies are very small text files that companies place on your device when you visit or use some sites, applications, or other web-based services to help identify a computer, browser, or device. [cite: 55] Virtual Dawn uses cookies, web beacons, Internet log files, and similar tracking technologies (Virtual Dawn’s and from third-party providers) to allow Virtual Dawn’s Services to function; maintain your preferences and settings; provide enhanced features; analyze how users use Virtual Dawn’s Services; combat fraud; prevent violations of Virtual Dawn’s EULA and policies; and to provide you with targeted advertising based on your interests. [cite: 56, 57, 58] If you choose to provide Virtual Dawn with information, it may be linked to the information collected by cookies and similar technologies including advertising cookies. [cite: 59, 60] Virtual Dawn’s system may not respond to Do Not Track requests or headers from some or all browsers. [cite: 61] The Manage Your Account, Communications, and Data section below provides additional information about Virtual Dawn’s use of cookies and similar technologies and your ability to manage cookies You may also use the cookie preference tool, where available, or visit the cookie policy posted on the Service for more information. [cite: 62]
Cookies
Cookies are used to identify a computer, browser, or device. [cite: 63, 64] Certain cookies are necessary for the Services to function and others let Virtual Dawn to provide you with an enhanced experience. [cite: 64] You can disable cookies on your device or set your browser to alert you when Virtual Dawn or others send cookies to your device but disabling cookies may affect your ability to use certain Services. [cite: 65] For more information, including details of specific cookies Virtual Dawn uses, applicable for the Service, see the cookie preference tool or visit the cookie policy posted on the Service you are visiting. [cite: 66] You can find more information and make choices about third-party cookie providers in the following sections of this Privacy Policy: When Virtual Dawn Shares Information, Advertising and Manage Your Account, Communications, and Data. [cite: 67]
Flash Cookies
Virtual Dawn may use flash cookies, also known as “local shared objects.” [cite: 68, 69, 70] You can clear flash cookies already on your device by adjusting the flash local storage setting on your device to zero. [cite: 69, 70] You may also prevent entities from placing flash cookies on your device by adjusting your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com. [cite: 70]
Web Beacons
A web beacon is an electronic image or tag that helps Virtual Dawn deliver cookies, count users who have visited certain pages or viewed certain advertisements or mailings, and conduct analytics for Virtual Dawn’s Services and communications. [cite: 71, 72, 73, 74, 75]
Internet Log Files
Virtual Dawn may collect Internet log files when you use the Services. [cite: 73, 74, 75] These log files can include IP addresses, MAC addresses or other device IDs, depending on your network configuration. [cite: 74, 75] Depending on the Service you use or the activity you engage in, Virtual Dawn associates these log files with your information. [cite: 75]
HOW VIRTUAL DAWN USES INFORMATION
Virtual Dawn uses the information it collects from and about you within Virtual Dawn for a variety of business purposes including to: provide the Services; fulfill orders and requests; analyze and improve Virtual Dawn’s Services and business; communicate with you; respond to questions or technical problems; develop internal marketing and demographic studies; provide support and security for Virtual Dawn’s products; and as more fully described in this Privacy Policy. [cite: 76, 77, 78, 79, 80, 81, 82]
Virtual Dawn also uses your information within Virtual Dawn for commercial purposes, including: send you and similar consumers direct marketing and online / social media advertising from Virtual Dawn and Virtual Dawn’s business partners, including use of demographic information; for other purposes identified when you provide your information; or otherwise with your permission. [cite: 79, 80, 81, 82] Virtual Dawn may further use your information as permitted by law. [cite: 81, 82] If Virtual Dawn finds that you have breached its Terms of Service or other applicable policies, this could lead to your temporary or permanent exclusion from the Services. [cite: 82, 83]
Virtual Dawn uses information collected from and about you for business purposes including to:
* Provide the Services; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Fulfill product orders and other requests, respond to your questions, and communicate with you; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Enhance your experience on the Services, including to recognize you, maintain your preferences and settings, and link to your third-party hardware, gaming, and social networking platforms; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Provide technical and other support; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Review the use and operations of the Services, develop new products or services, and conduct analyses to enhance or improve Virtual Dawn’s software, content, internal marketing, support, and Services; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Conduct internal marketing and demographic studies; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Analyze Virtual Dawn’s users, in combination with other data, to assess Virtual Dawn’s user base and target marketing at other similar groups; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* Address issues with the Services or other business needs; [cite: 83, 84, 85, 86, 87, 88, 89, 90]
* To protect the security or integrity of the Services and Virtual Dawn’s business such as by protecting against and preventing violation of Virtual Dawn’s EULA and policies, including combating fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and managing risk exposure; [cite: 83, 84, 85, 86, 87, 88, 89, 90] and
* Interact on your behalf with the third-party social networking platforms you connect with Virtual Dawn’s Services.
