Echoes of Empire Privacy Notice

Last Updated: January 17, 2024

Ion Games, a studio of Hit Factor Inc.(“Ion Games,” “we,” “us,” or “our”) welcomes you to the website (https://echoesofempire.game/) (the “Site”) for our game, Echoes of Empire, (the “Game”). Through the Site, we provide sales and marketing information about our company, our products, and our technologies (such information, together with the Site and the Game, the “Services”).

This Privacy Notice explains what Personal Data (defined below) we collect in connection with the Services, how we use and share that data, and your choices concerning our data practices. This policy applies only to information we collect via the Services and in email, text, and other electronic communications sent through or in connection with the Services.

This policy DOES NOT apply to information that you provide to or is collected by any third party, or which is collected outside of the Services (see “Third-Party Information Collection”).

Note: Information processed via the Gala Games website for the Game (https://games.gala.com/games/echoes-of-empire) (the “Gala EOE Site”) is NOT subject to this Privacy Notice. All information processed via the Gala EOE Site is subject to the Gala Games privacy policy available here: https://games.gala.com/privacy-policy.

This Privacy Notice is incorporated into and forms part of our End User License Agreement.

Before using the Services or submitting any Personal Data to Ion Games, please review this Privacy Notice carefully and contact us at privacy@hitfactor.com if you have any questions. By using the Services, you agree to the practices described in this Privacy Notice.

If you do not agree to this Privacy Notice, please do not access the Site, the Game or otherwise use the Services.

 

1. DATA CONTROLLER

Hit Factor Inc. will be the entity responsible for your data. To ask questions or comment about this privacy policy and our privacy practices, you can contact us at:

Email:  privacy@hitfactor.com 

Postal Address:
Ion Games
c/o Hit Factor Inc.
3960 W Point Loma Blvd., Ste. H
PMB 2731
San Diego, CA 
92110

 

2. CHILDREN

Our Services is not directed to or intended for children who are under the age of 18. Ion Games does not knowingly collect Personal Data from children under the age of 18. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you have reason to believe that a child under the age of 16 has provided Personal Data to Ion Games through the Services please contact us at privacy@hitfactor.com and we will endeavor to delete that information from our databases. This is in compliance with the Children’s Online Privacy Protection Act and Article 6(1)(c) of the GDPR.

 

3. PERSONAL DATA WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

Personal Data You Provide.  It is currently not possible for you to actively input personal information into the Site or the Game.

Automatically Collected Information. 

Information Collected Automatically Through the Site. No Personal Data is automatically collected through the Site.

Cookies: The Site does not deploy Cookies. All About Cookies.

Online Tracking and Do Not Track Signals:  Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Notice whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Notice to describe how we do so.

Information Collected Automatically Through the Game. We do not collect information passively through the Game. However, some of the features of the Game are serviced by Third Party Services (defined below). When you use the Game, these Third-Party Services use automatic information collection technologies to collect information about you or your device and we receive information from them about your use of the Game. See below for more about Third-Party Information Collection.

Third-Party Information Collection. Some features of the Services are served by third parties (“Third-Party Services”). These Third-Party Services include: the gaming platform you use in connection with our Game and our analytics provider. These Third-Party Services process your information for the purpose of providing the relevant services which are incorporated into our Services. For example when you log into the game we receive your Gala account name/ID and information about the contents of your Gala wallet from Gala Games. Additionally, when you play the game, our analytics provider collects your IP Address, device information, session information, and usage details such as information about the resources you have used and the stages that you have cleared within the Game. The Personal Data that we receive from Third-Party Services is covered by this privacy policy, while their processing of your information is covered by their privacy policy.

Please see the list of Third-Party Services below:

  • Gala Games – Information about Gala’s data practices may be found in its privacy policy available here: https://games.gala.com/privacy-policy
  • AWS (analytics) – Information about AWS’s data practices may be found in its privacy policy available here: https://aws.amazon.com/privacy/

     

Social Sites: We also have pages on social media sites like Discord (“Social Sites”). The Social Sites are operated by the owners of the relevant social media platforms and the collection of information by third parties on the Social Sites is governed by the privacy policy of the applicable platform. When you interact with our Social Sites, we may also collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Sites may provide us with aggregate information and analytics regarding the use of our Social Sites.

Links to Other Websites: The Services may contain links to Social Sites and/or other websites not operated or controlled by Ion Games (all such websites “Third-Party Sites”). The information that you share with Third-Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Notice. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third-Party Sites directly for information on their privacy practices and policies.

 

4. Our Legal Bases For Processing Your Information (For Residents of the UK/EU)

When we collect or otherwise process any of your Personal Data, we do so in reliance on the following legal bases:

  • Your consent. If you have provided us with your consent to process your information for a specific purpose we will do so based on your consent. You may withdraw your consent at any time by following the instructions provided below in the “Your Rights and Choices” section below.
  • Performance of a Contract with You. When the processing of your Personal Data is necessary in order for us to perform a contract with you, such as the EULA or Terms of Services associated with Game or the Site, or when you request that we process your information prior to entering into a contract with you, we will do so on this basis.
  • Our Legitimate Interests. When we believe the processing of your Personal Data is reasonably necessary in order for us to achieve our legitimate interests in conducting and managing our business and our relationship with you, we will do so on this basis, including the legitimate interest we have in:
    • personalizing, enhancing, modifying or otherwise improving the services and/or the communications that we provide to you;
    • retaining and engaging you and our other users;
    • detecting and preventing fraud and operating a safe and lawful business; and
    • improving the security and optimization of our network, sites and services.

When we use your information for our legitimate interests, we take into account any potential impact that such use may have on you by balancing our legitimate interests against your interests, rights and freedoms. We will not use your information if there is a less intrusive way for us to achieve our legitimate interests or if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation).

  • Our Legal Obligations. When we believe that the processing of your information is necessary in order for us to comply with our legal obligations (such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved) we will do so on this basis.
  • Vital Interests. When we believe that the processing of your information is necessary in order to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person, we will do so on this basis.
 

5. HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:

  • To provide, support and maintain the Services and their contents, and any other information, or services that you request from us.
  • To optimize, develop, and improve the Services.
  • To track sales.
  • To analyze how you interact with our Services.
  • To provide you with customer support.
  • To communicate about promotions, upcoming events, and other news about our games and services with your consent.
  • To respond to your inquiries, comments, feedback, or questions regarding the Services.
  • To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
  • To respond to you if you contact us.
  • To fulfill any other purpose for which you provide it.
  • To develop new products and services.
  • To prevent fraud, criminal activity, or misuses of our Services.
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
  • For any reason that we described to you when collecting your Personal Data or for any reason for which you’ve provided us with your consent.
  • To help maintain the safety, security, and integrity of the Services, our IT systems, architecture, networks, databases, and other technology assets.
  • To protect the rights, interests, and safety of us, you, and any third parties, and to exercise and defend our rights.
  • To create anonymous, de-identified, or aggregated datasets (“Aggregated Information”). Such datasets would not be “Personal Information” subject to this Privacy Notice. We may use anonymous, de-identified, or aggregated datasets for any purpose. For more information about Aggregation Information see below.

The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:

  • Recognize you when you use the Services.
  • Know what resources you have in your Gala wallet that are available for use in connection with the Game.
  • Estimate our audience size, demographics and usage patterns.
  • Store your preferences, consents and other user settings locally on your device.
  • Comply with your consents.
  • Understand how well Services features are working and whether users are having issues.
  • Identify and correct software defects.
  • Prevent fraud and illegal behavior by detecting behavior patterns that indicate such activity.

Aggregated Information: We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Notice.

 

6. SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share the categories of Personal Data described above without further notice to you, unless required by the law, with the following categories of third parties:

  • Vendors and Services Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.
  • Business Transfers: We may disclose your information to our subsidiaries and affiliates. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a court order, regulatory request or other legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
  • Enforcing our Rights: We may disclose your information as necessary to enforce our rights arising from any contracts entered into between you and use, such as our Terms of Service.
  • Necessary for Purpose: We may disclose your information as necessary to fulfill the purpose for which you provided it.
  • With Your Consent: We may disclose your information with your consent.
  • Other purposes: We may disclose your information for any other purpose disclosed by us and accepted by you when you provide the information.
 

7. WHERE, HOW AND HOW LONG WE STORE YOUR INFORMATION

Information that we collect through the Game is stored in the US. We store all Personal Data securely using third-party vendors who implement industry-standard security measures. By using the Services, you authorize us to receive, process, transfer, and store your information in and to the United States, as applicable. 

We keep your information only for the length of time necessary to fulfill the purposes for which the information was collected. For example, if we collect your Gala account information and you have not used the Game for a period of time longer than 2 years, we will delete that information. If applicable laws require us to store your information for a longer period, then we will keep your information for the period required by law. When it is no longer necessary or required for us to retain your data, we will delete it.

Cross-border Data Transfers: Where cross-border transfers of data are necessary, we will take reasonable steps to safeguard the privacy of your Personal Data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring Personal Data.

 

8. DATA SECURITY

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure by partnering with third parties who use industry standard security measures to protect your information.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

 

9. YOUR RIGHTS AND CHOICES

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features.

We strive to provide you with choices regarding the Personal Data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

  • Updating or correcting your information: Please contact us if you need to change or correct your Personal Data.
  • Promotion by us: If you have opted in to receiving email communications from us and you want us to discontinue using your email address to promote our own or third parties’ products or services, you can opt-out by clicking the unsubscribe link at the bottom of our emails and following the instructions provided.
  • Third parties: We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

For more information about the third parties that collect data through the Services, see the “Third Party Information Collection” section above to understand which third parties have access to your Personal Data through the Services. You can consult their privacy policies to see if they offer additional options for limiting collection.

Data Rights of European Residents: The laws of the United Kingdom and the European Economic Area and other territories provide their residents with certain data protection rights. If you are resident of the United Kingdom or the European Economic Area, these are your rights:

  • The right to access – You have the right to request Ion Games provide you with copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification – You have the right to request that Ion Games correct any information you believe is inaccurate. You also have the right to request Ion Games to complete information you believe is incomplete.
  • The right to be forgotten – You have the right to request that Ion Games erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request that Ion Games restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to Ion Games’ processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that Ion Games transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at privacy@hitfactor.com.

Personal Information Rights for California Residents:

Shine the Light. Under California Civil Code Section 1798.83, ( the “Shine The Light” law), California residents who use the Services may request and obtain from us, once a year and free of charge, information about categories of Personal Data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Minors. California residents who have an account with us and who are under 18 years of age have the right to request deletion of any data that such users post on the Services, if any. To request deletion of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

 

10. CHANGES TO THE PRIVACY POLICY

The Services and our business may change from time to time. As a result we may change this Privacy Notice at any time. When we do we will post an updated version on this page unless another type of notice is required by the applicable law. By continuing to use our Services or providing us with Personal Data after we have posted an updated Privacy Notice, or notified you by other means if applicable, you consent to the revised Privacy Notice and practices described in it.

 

11. CONTACT US

If you have any questions about our Privacy Notice or information practices, please feel free to contact us at:

Email:  privacy@hitfactor.com 

Postal Address:
Ion Games
c/o Hit Factor Inc.
3960 W Point Loma Blvd., Ste. H
PMB 2731
San Diego, CA
92110