EU Privacy Policy for Customers

Last updated April 26, 2024

This Privacy Policy (hereinafter “Policy”) informs you how Return Entertainment Oy (hereinafter “we”, “us” or “our”) collects, uses, and otherwise processes your personal data in connection with your use of Return gaming platform and our games such as Rivals Arena (hereinafter together “Services”). It is important that you read this Policy carefully before accessing or using our Services so that you are aware of how we use your personal data.

1. Data controller

The data controller in accordance with the applicable data protection law is Return Entertainment Oy.

Contact details of the data controller:

Return Entertainment Oy
Tammasaarenkatu 1
00180 Helsinki

Business ID: 3088344-9

legal@returnentertainment.com

2. Categories of Personal data

The personal data processed by us is collected directly from you when you use the Services or interact with us. As you interact with our Services, we can also automatically collect technical information which may be associated with you, including through cookies and similar technologies. For more information about the use of cookies, please see our Cookie Policy at the end of this Policy.

We do not process any special categories of personal data, such as personal data related to e.g. ethnic origin, political opinions, religious or philosophical beliefs, health, sex life or sexual orientation

3. Purpose and legal bases for processing personal data

We have set out below a chart of all the purposes for which we process your personal data, and which of the legal bases we rely on when doing so. We have also identified what our legitimate interests are where appropriate.

Where our processing is solely based on your consent you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal (please see section 7 of this Policy).

Purpose Legal basis Types of data
We will use the described data to manage your use of our gaming platform. This is necessary for the performance of a contract with you or to take steps at your request prior to entering a contract.
  • Player Data
  • Technical Data
  • Purchase Data
We will use the described data to create and maintain your player account in our game and provide you the game and associated features to enable you to play. This is necessary for the performance of a contract with you or to take steps at your request prior to entering a contract.
  • Player Data
  • Technical Data
  • Purchase Data
We will use the described data to send you service-related communication, such as security alerts and information about new features in our Services.

We will also use the described data when you interact with us and when we respond to you and when you solicit feedback about our products and when we provide customer support.
This is based on our legitimate interest to provide you with relevant service-related information and provide support and enable you to provide feedback at your discretion.
  • Player Data
  • Correspondence Data
We will use the described data to operate our Services, to ensure security, and to develop and improve our Services. This is based on our legitimate interest to ensure that our Services function as intended, has an appropriate level of security, and that we have sufficient and relevant information at hand to develop our Service.
  • Player Data
  • Technical Data
We will use the described data to personalise your game experience based on your activity in the game. This is based on our legitimate interest to ensure a better player experience.To the extent cookies and similar technologies are used for this purpose, the processing is based on your consent.
  • Player Data
  • Technical Data
We will use the described data to promote our Services to you. For this purpose we may either send you news and offers about our Services or show you ads based on your activity as well as analyse and measure our advertising and their effectiveness. We can use third party advertising partners for this purpose. In general, processing is based on our legitimate interest to promote our Services and analyse their effectiveness to our existing customers.

Newsletters and similar materials by email are only sent where you have consented in receiving such material.

To the extent cookies and similar technologies are used for this purpose, the processing is based on your consent.
  • Contact Data
  • Player Data
  • Marketing Data
  • Technical Data
We may collect or use described data to comply with applicable law, such as accounting and tax legislation or with any requests by competent authorities under law. It is our legal obligation to comply with applicable law and requests made by competent authorities.
  • Purchase data
  • Data requested by competent authority
We may process your personal data to analyse and improve our business procedures and services. It is necessary for our legitimate interest to analyse and improve our business, including our services
  • Player Data
  • Technical Data

When processing of personal data is based on our legitimate interest as mentioned above, we have conducted a so-called balancing test for those interests to ensure that our interest is not overridden by your interests or fundamental rights and freedoms. Please contact us by email at legal@returnentertainment.com if you wish to receive more information on the balancing test. Please note that you may object to processing based on legitimate interest at any time (please see section 7 of this Policy).

4. Transfers and disclosures of personal data

We may disclose personal data to third parties:

In addition, we may use third party service providers for IT services or for the purpose of analytics. These service providers work on behalf of us and under our instructions. We will control and be responsible for the use of your personal data at all times.

5. Transfers of personal data outside the EEA

The processing of your personal data takes place primarily in the United States. However, as a European service provider, we may also process your personal data within the European Union. In this case, we comply with European Union data protection legislation, especially the General Data Protection Regulation, the GDPR. We also use third-party service providers that are established outside the European Economic Area. This means that your personal data may be transferred from the European Economic Area to countries outside the European Economic Area, including the United States. However, to ensure that your personal data receive an adequate level of protection, we have ascertained that sufficient safety measures have been implemented to allow for the transfer. These include the transfer of personal data to countries that the European Commission has deemed to provide an adequate level of protection for personal data; or by use of specific contracts approved by the European Commission (Standard Contractual Clauses); or by adherence to another appropriate data transfer mechanism such as the EU-US Data Privacy Framework.

If you require further information on our current service providers established outside the EEA and the safety measures in place to allow for the transfer of personal data, you can request it from us – please send your request to us by email at legal@returnentertainment.com.

6. Retention of personal data

In accordance with our commitment to ensure the security and privacy of your personal data, we have specified the retention periods for different types of personal data we collect.

Player data is retained for as long as you have an active game account. If you delete your account, the data will be removed within a month.

Correspondence data will normally be kept for one year. However, in cases of ongoing matters such as disputes, we may need to retain the data for a longer period.

Technical data is not deleted for as long as you have an active game account. If you remove your account, this data will be deleted within a month.

Marketing data will be retained for up to two years. The retention period starts from the last date you interacted with our marketing content or Services. If you have given us your consent to receive marketing content, we will keep a record of your consent for two years after the last time we relied on it to send you marketing content. To the extent our marketing activities are based on your consent, we will stop sending you e-marketing materials if you withdraw your consent.

Purchase data is stored for bookkeeping and tax purposes for six full fiscal years after the expiry of the year to which the transaction relates.

Please note that if you are using our Services through a browser in incognito mode, no Service-related data is stored.

We only retain personal data for as long as we have a legitimate need to do so. When we no longer have a legitimate need to process your personal data, we will either delete or anonymize it.

7. Your rights

Under certain circumstances, you have the right to:

The fulfilment of requests concerning personal data that we process requires that we are able to identify both the person making the request and the person to whom the personal data we process relates. In accordance with the principle of data minimization in data protection legislation, we aim to process as little personal data as possible and do not process personal data that is not necessary for the provision of the Service. Data protection legislation does not require that we can link the personal data we process to the people to whom they relate, and we are not always able to identify the people whose data we process. In such cases, we may not necessarily be able to fulfil requests concerning your personal data. Data protection legislation also does not require that we collect more information about users just so we could fulfil requests concerning personal data.

If you think there is a problem with the way we are handling your personal data, you also have a right to lodge a complaint to your national data protection authority in the EU.

In Finland you can lodge a complaint with the Office of the Data Protection Ombudsman at https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman.

The list of all data protection authorities in the EU can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you wish to exercise any of the privacy rights that are available to you then please send your request to us by email at legal@returnentertainment.com.

8. Security

We maintain reasonable security measures (including physical, electronic, and administrative) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, we limit access to personal data to authorized employees and contractors who need to know the information in the course of their work tasks.

9. Changes to this Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will let you know it on our website at rivalsarena.com, where you will also find the latest version of this Policy.

10. Contact us

If you have any questions regarding this Policy or the personal data we process about you, please contact us at legal@returnentertainment.com.

Cookie Policy

Last updated April 26, 2024

This Cookie Policy explains how Return Entertainment Oy (hereinafter also “we”, “us” or “our”) uses cookies and other similar techniques within our Services.

1. What are cookies?

A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website’s server. Cookies are typically used to remember your device, for example, to enable functionality and to store your preferences, such as language, for a certain period of time.

We also use other forms of technology, such as web beacons and pixel tags, which serve a similar purpose to cookies and which allow us to monitor and improve our Services. When we talk about cookies in this Cookie Policy, this term includes these similar technologies.

2. What cookies do and how long?

Our Services use a variety of cookies for different purposes. We use the following categories of cookies:

Strictly necessary cookies cannot be disabled. For other types of cookies we will ask for your consent and you can at any time change your cookie settings in this respect (See Section 4).

Each cookie lasts for a different period of time. We use both session cookies and persistent cookies.

3. List of our cookies

The cookies can be set by us (so called “first-party cookies”) or by a third party (so called “third-party cookies”).

Your use of our Services may result in some cookies being stored that are not controlled by us. This may occur when the part of the Service you are visiting makes use of a third-party analytics or marketing automation/management tool or includes content displayed from a third-party website, for example, YouTube or Facebook. You should review the cookie policies of these services to find out how these third parties use cookies.

Below we have listed information on all our cookies, including the cookie type as well as the provider, purpose and duration of the cookie.

3.1. Strictly necessary cookies

Cookie type Provider Purpose Duration
Strictly necessary cookies Return Entertainment Oy To store details about the current game Session cookie
Strictly necessary cookies Return Entertainment Oy To authenticate the user Persistent cookie

3.2. Other cookies used only with your consent

Cookie type Provider Purpose Duration
Analytical cookies Matomo To measure the number and length of play sessions Persistent cookie, retention period 24 months
Marketing cookies Publica To provide targeted advertising Persistent cookie, retention period 6 months

4. Changes to this Policy

We may change this Cookie Policy from time to time. If we make any changes to this Cookie Policy, we will let you know it within our Services, where you will also find the latest version of this Cookie Policy.

5. Contact us

If you have any questions regarding this Cookie Policy or the personal data we process about you, please contact us at legal@returnentertainment.com.