PRIVACY POLICY

MiroWin LLC and its affiliates ("MiroWin Studio", “MiroWin”, “us”, “our” or "we") are dedicated to protecting the privacy rights of our users ("users" or "you"). This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our website, including mirowin.com (the “Site”) and any MiroWin game provided on the game stores (for example, Steam, Oculus store, Viveport, Playstation store, Humble Bundle).
Please note that the scope of this Policy is limited to information collected or received by MiroWin through your use of the MiroWin products. MiroWin is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.
By using MiroWin products, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you have questions or concerns about our privacy policy or practices, please contact us at contact@mirowin.com.

Overview
We think transparency is important. Here we summarize the personal information we collect and how we use it, which is further explained in our Privacy Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.

There are a number of ways in which we can collect your personal data. In this section we explain which personal data we may collect from you.
We will make use of cookies when you visit our website.
While you are browsing MiroWin Studio’s website, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may use this information to monitor, develop and analyze your use of the information on our website and MiroWin products. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age or birthday, links to your profiles on social networking websites and other third party sites, user names and e-mail and mail addresses. We may use this information to create a user profile and provide you services. We may use your email address to contact you about your experience with MiroWin Studio Site and MiroWin products and notify you about company news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions. Your mail address may be used if we have merchandise or other physical promotional materials that we want to send to you. If you no longer wish to receive these types of promotional materials, you may opt-out from receiving them at any time by emailing us at contact@mirowin.com.
We use Google Analytics software and cookies to process the following personal data up to 2 years after collecting the personal data:
Google Analytics may store this personal data outside of the EEA. Google has guaranteed us to store the information in accordance with the General Data Protection Regulation.
- For the players of MiroWin games
If you play our games, we process the following personal data up to 10 years after your last use of the game:
- Your in-game progression data
- Your in-game friends and relations
Our purpose is to provide you the quality game support and to provide the analysis of your game experience.
To provide matchmaking services, we process the following personal data up to 2 weeks after the matchmaking:
- Username
- IP-address
To be able to secure our games, we process your IP-address up until 1 year after collection of the IP-address or 1 year after an incident in which your IP-address was involved has been handled. Our processing ground is our legitimate interest to secure our games.
If you contact us as a player, we process the personal data mentioned below up to 5 years after our last contact moment. Our processing ground is our legitimate interest to be able to reply on your requests.
- Name
- E-mail address or other kind of contact
- Communication and content of e-mails
We may send our e-mail via Mailchimp. Mailchimp may store this personal data in the United States. Mailchimp has guaranteed us to store the information in accordance with the General Data Protection Regulation.
- For the MiroWin business partners and suppliers.
We have a legal obligation to maintain a decent administration. For this purpose, we process the personal data mentioned below up to 7 years after receiving the information.
- Name
- Company name
- Responsible person name
- Address
- Payment data and information
- Invoice data
- VAT identification number
To handle payments, we process the personal data mentioned below up to 2 years after the end of the agreement for which the payment was made. Our processing ground is the performance of a contract with you.
- Payment data and information
- Invoice data
If you use a foreign payment provider, your personal data may be stored outside of the EEA.
We may send you marketing material. We process the personal data mentioned below up to 5 years after our last contact moment. Our processing ground is our legitimate interest to send our customers and suppliers marketing materials for comparable services.
- Name
- Company name
- Address
- E-mail address
- Telephone number

- For press
To be able to contact you, we process the personal data mentioned below.
If you contact us, we process the personal data mentioned below up until 5 years after our last contact moment. Our processing ground is our legitimate interest to be able to reply on your requests.
- Name
- Company name
- E-mail address
- Communication and content of e-mails
- The type of games you are interested in (if provided in the contact form)
- Your general location (country and/or province level)
If you opened our e-mail sent via Mailchimp this service may store this personal data in the United States. Mailchimp has guaranteed us to store the information in accordance with the General Data Protection Regulation.
If we contact you without a prior request from you, we process the personal data mentioned below up until 5 years after our last contact moment.
- Name
- Company name
- E-mail address
- Telephone number
- Communication and content of e-mails
- The type of games you are interested in (if provided in the contact form)
- Your general location (country and/or province level)
- Your work related function
- If you opened our e-mail
- Twitter account name
- Professional information and statistics (such as your website, channel, number of visitors and/or biographic information)
- VR platform/headset that is used (if any)

- Other collection
We may also acquire information from you through your participation in MiroWin surveys regarding the MiroWin products or your participation in a sweepstakes or contest through the MiroWin pages or game stores.

If you participate, we will request certain personal information from you. Participation in these sweepstakes and contests are voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code).
We use this information to notify winners and award prizes, to monitor traffic. We may use a third party service provider to conduct these sweepstakes or contests; that company is prohibited from using your users’ personal information for any other purpose.

2. Protection of personal data
Protecting your personal data is of the utmost importance for us. We have therefore taken appropriate technical and organizational security measures in order to protect your personal data. We protect our databases with physical and electronic measures, to minimize the risk of unauthorized access, loss or misuse of personal data. We make backups of personal data.
We would like to point out that we cannot guarantee absolute security when sending personal data via the internet or storing personal data. We advise you to take this into account before sharing personal data.
3. Links to third party sites
Our website and social pages may contain links to other websites and services, so third party websites and services can collect and retain information about you. If you provide your personal data to third parties, then we are not involved. We have no control over this sites or the activities of the third parties. In that case, the privacy policy of the third party applies. We are not responsible for the content of the privacy policy of these parties and the way in which these parties deal with personal data. We encourage you to review their privacy and security practices and policies before you provide personal information to them.
4. Your rights
Privacy legislation gives you certain rights with regard to your own personal data:
4.1. Right of access. You have the right to request which personal data we process about you. You can also ask us to provide insight into the processing grounds, relevant categories of personal data, the (categories of) recipients of personal data, the retention period, the source of the data and whether or not we use automated decision making. You may also request a copy of your personal data that we process. If you want additional copies then we can charge a reasonable fee for this.
4.2. Right to rectification. If the personal data processed by us about you is incorrect or incomplete, you can request us to adjust or supplement the personal data. If we grant your request, we will, to the extent reasonably possible, inform the parties to whom we provide information.
4.3. Right to erasure. If you no longer want us to process certain personal data about you, then you can request us to delete certain (or all) personal data about you. Whether we will delete data depends on the processing ground. We only delete data that we process on the basis of a legal obligation or for the performance of the agreement if the personal data is no longer necessary. If we process data based on our legitimate interest, we will only delete data if your interest outweighs ours. We will make this assessment. If we process the data on the basis of consent, we will only delete the data if you withdraw your consent. If the data is necessary for the settlement of a legal proceeding or a (legal) dispute, we will only delete the personal data after the end of the proceedings or the dispute. If we grant your request, we will, to the extent reasonably possible, inform the parties to whom we provide information.
4.4. Restriction of processing. If you dispute the accuracy of personal data processed by us, if you believe that we have processed your personal data unlawfully, if we no longer need the data or if you have objected to the processing, you can also request us to restrict the processing of that personal data. For example, during the time that we need to assess your dispute or objection, or if it is already clear that there is no longer any legal ground for further processing of those personal data, but you still have an interest in us not deleting the personal data. If we limit the processing of your personal data at your request, we may still use that data for the settlement of legal proceedings or a (legal) dispute.
4.5. Right to data portability. At your request, we may transfer the data that we automatically process to execute the agreement or based on your consent, to you or another party designated by you. You can make such a request at reasonable intervals.
4.6. Automated individual decision making. We do not take decisions based solely on automated processing.
4.7. Right of restriction of processing and withdrawal of permission. If we process data on the grounds of a legitimate interest, you may object to the processing. If we process data on the basis of your consent, you may withdraw that consent. For more information, please refer to the relevant processing purposes above.
4.8. Exercising your rights. You can send a request for access, correction, deletion, data transfer of your personal data or request for withdrawal of your consent or objection to the processing of your personal data to contact@mirowin.com.
To prevent abuse, we ask you to identify yourself adequately in the case of a written request for access, rectification or erasure. You can do this by sending a copy of a valid proof of identity. Do not forget to screen off your citizen service number and passport photo on the copy.
We strive to process your request, complaint or objection within a month. If it is not possible to make a decision within a month, we will inform you of the reasons for the delay and the time when the decision is expected to be made (no longer than 3 months after receipt).

The rights that we describe are not absolute rights. We will always consider whether we can reasonably meet your request. If we cannot meet your request, or if it would be at the expense of the privacy of others, we can refuse your request. If we refuse a request, we will let you know and explain our reasons.
5. Contact
If you have questions, concerns or comments about this privacy statement or our data processing, please contact us:
MiroWin LLC
apt. 258, Obolonskyi Ave 28, Kyiv
Ukraine
Attention: Legal – Privacy
contact@mirowin.com