Below, you’ll find legal documentation for all Wargaming.net products & services.
Effective 12 November 2018
By “Personal Data”, we refer to data that relates to you as an identified or identifiable natural person. The term “Personal Data” may include your name, your address, your telephone number, your e-mail address, your age, your gender, your game preferences, for instance. Anonymous information, which we are not in a position to relate to you, does not qualify as “Personal Data”.
1. CONTROLLER’S NAME AND CONTACT DETAILS
Controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding our online and mobile games including, but not limited to, “World of Tanks“, “World of Warplanes“, “World of Warships“, “World of Tanks Blitz“, “World of Warships Blitz“, “Total War: Arena“, “Gods & Glory” , associated web-sites as http://worldoftanks.eu, http://worldofwarplanes.eu, http://worldofwarships.eu, https://wotblitz.eu, https://wowsblitz.com, http://totalwararena.net, http://wargaming.net, https://godsandglory.com, as well as any other Wargaming games and any other websites owned or operated by Wargaming:
Wargaming Group Limited
105, Agion Omologiton Avenue
Controller in the sense of the GDPR and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding “World of Tanks” on Xbox 360 and Xbox One, “World of Tanks” on PlayStation®4 (“Console Games”), for example, in relation to the https://console.worldoftanks.com/ website, is:
Wargaming World Limited
105, Agion Omologiton Avenue
Both entities are referred to as “Wargaming”, “we”, “our” and “us” in this Policy. The term “Services” refers to the act of providing you with the opportunity to use the named games (“Games”), websites (“Sites”), Wargaming account (“Account“), any of our other products and services (including support services, forums) related to the Games (“Ancillary Services“), for example, the “World of Tanks Assistant”, “Wargaming Check” and “Wargaming Game Center” applications.
2. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)
The contact details of Data Protection Officer of Wargaming are:
Wargaming Data Protection Officer
105, Agion Omologiton Avenue
3. GENERAL INFORMATION IN BRIEF
We process personal data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms for which require the protection of your Personal Data.
Our legitimate interests are to render and improve our Services in an effective, safe and harmless manner. We want to provide everyone with a fair and balanced experience when using our Services.
3.1. YOUR PREFERENCES
You can choose how we use your Personal Data using our Account Management Tool. As we need to verify your identity before we follow your instructions on Personal Data use, you need to have a registered Account in order to access the Account Management Tool. This means that if you are using a demo version of the Account, you will only be able to fully control our use of your data after you complete the Account here.
For example, through the Account Management Tool you can:
3.2. INFORMATION SECURITY
We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
3.3. PROCESSING INFORMATION BY THIRD PARTIES
We may share Personal Data with our affiliates, subsidiaries, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services. Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Those companies may be located outside of the European Economic Area. Read more in Section 6 “How we share your information”.
We recognise that we have a special obligation to protect personal information obtained from children. We will not knowingly collect Personal Data from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law).
3.5. DATA RETENTION
We keep most of your Personal Data gathered and processed for the purposes described in this Policy for as long as you continue to use our Services, e.g. you have an activated Account in one of our Games. We will delete your Personal Data after you request your Account deletion and the grace period of 45 (forty-five) calendar days, during which we can restore your Account, expires. The process of erasing your Personal Data can take up to one month from expiry of the grace period and, considering the complexity and number of requests, may be extended by a further two months. Read more in Section 7.4 “Right to erasure”.
3.6. GAMES NOT USING THE ACCOUNT
Some of the Games do not use the Account. You will not be able to exercise your rights with regard to those Games through the Account Management. For this reason, we are offering you other tools to export your Personal Data, delete it, and object to our use of your Personal Data in accordance with Section 7 “Your rights”, as well as to manage your subscriptions.
Also, there are some differences in the Personal Data that we collect about users of the Games for which the Account is created and users of other Games, for example, for “World of Warships Blitz”. For example, we do not collect your phone number and email address if you use the Games for which the Account is not created.
With regard to the Games that do not use the Account, you can exercise your rights by filing a request to that effect to Customer Support or as otherwise indicated in the respective Game.
Where such function is available, you may link to your Account some of the Games that do not use the Account. Please note that control over your Personal Data in such Games is separate from control over your Personal Data relating to your Account. So, to delete your Personal Data in “World of Warships Blitz” you will need to contact Player Support as suggested in this Game, while deletion of the Personal Data relating to your Account shall be performed through the Account Management.
4. INFORMATION WE COLLECT
In relation to your use of our Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g. through our Site’s technology).
4.1. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, your use of certain Services is possible only if you provide required information, e.g. while creating an Account.
When setting up an Account, you may be asked to provide Personal Data including, but not limited to, your name, email address and telephone number.
We may obtain your Personal Data when you register for and use our other Services, e.g. game forums, chats, or when you provide feedback about our Services. This data includes:
4.2. INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our Games, Sites and other Services.
This information may include, but is not limited to, anonymized browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information (“Other Information”). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If Other Information is combined with Personal Data, we will treat the combined information as Personal Data.
4.2.1. Tracking Data and Cookies
Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as “Tracking Data”. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. When you visit any of our Sites, our servers log your computer’s IP address.
4.2.2. Game-Related Information
In order to provide you with efficient services, we need to collect, store and use various information about your activity in our Games. “Game-Related Information” includes your in-game identifier, which for most of our Games is known as “Wargaming ID”, as well as what is usually referred to as “game statistics”. By “game statistics” we mean information about your Games preferences, progress in the Games, participation and performance in clans, frequency of playing.
4.2.3. Device Information and Geo-Location
In order to fix crashes and other technical issues that may arise while you are installing the Games and using our Services, as well as to make our Services more suitable for you, we collect, store and use information about the device you are using the Services on, including what type of device it is, what hardware and operating system you are using, the device settings, unique device identifiers, and crash data (if any). Whether we collect some or all of this information often depends on what type of device you are using and its settings. You may also install applications collecting and using additional data required for fixing crashes, errors and other technical issues arising during your use of the Services, e.g., Wargaming Game Center and Wargaming Check.
To make Services more suitable for you and only upon your permission we can also collect your precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location.
4.2.3. Information required for fraud and violations detection
We may also collect certain data (like IP address, username, etc.) that is required for our detection, investigation and prevention of cheating in the Game and EULA violations. This data, being used only for the purposes of detection, investigation and prevention of frauds and cheating in the Game is deleted six months after its collection, unless the data can be used to prove that cheating has occurred. If the data can be used to prove that cheating or another fraud or EULA violation has occurred, we will further store the data for the establishment, exercise or defence of legal claims during the applicable statute of limitations. Please note that the specific data stored for this purpose may not be disclosed to you or any third parties, since the disclosure will compromise the mechanism through which we detect, investigate and prevent frauds and cheating in the Game, as well as other EULA violations.
4.2.4. Information from publicly available online resources
We may use the information made publicly available, e.g. through YouTube, vk.com, Facebook, Instagram and Twitter, in order to find out your opinion about Games and Services, so that we could take them into account while improving our Services. Such data collection can be carried by Wargaming independently, or received from our partners making analysis of public sentiments on various issues, e.g., from Hootsuite Media Inc.
4.2.5. Information from our partners
In some cases, Wargaming receives your personal data as a data processor, which means that the data is controlled by our partners and we use it only in accordance with their instructions and applicable laws. We use this data in order to fulfil our obligation under the EULA, improve the Servcies, and when processing is required in order to comply with a legal obligation to which we are subject.
Payment partners. When you purchase virtual items, virtual currency, or time-limited premium memberships with your credit card, we may receive from our payment partners and process a part of your credit card number, information about your credit card issuer, as well as your full address for billing purposes;
Co-Promotion Partners. In order to provide you with in-game items and/or in-game currency for participation in various loyalty programs, we may also receive information from our partners, such as telecommunication companies (e.g., Rostelecom), banks (e.g., Alfa-Bank), cashback partners (e.g., Kopikot), travel agencies (e.g. Biletix), and others;
Platforms. We also receive and use your identifiers on other platforms like PlayStation®4, Xbox 360 and Xbox One, App Store, Google Play Store, so that you can play our gGames through these platforms;
Social networks. We have registered certain Games-related group accounts and pages at vk.com, Facebook, Twitter, Reddit, and other social networks to better communicate with our players in case they have questions about the Services, as well as prefer to learn about news about the Services through the social networks. Also, we get information relating to your profiles on social networking sites in order to allow integration with such social networking sites, e.g., your name, avatar, and date of birth, if you link a third party tool with our Services.
5. HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to perform the contract with you according to Article 6(1)(b) of the GDPR. As a user, we will use your Personal Data, unless otherwise prohibited by law, for the following purposes:
5.1. COMMUNICATION PURPOSES
We will use your Personal Data for our legitimate interests according to Article 6(1)(f) of the GDPR to advertise our products and services in accordance with this Policy. Namely, once you have created an Account we may use your email address, nickname, IP address, mobile phone number, in order to send you personalized marketing emails, messages, targeted in-game and web offers about Games. Also, if you opt-in, we will send you personalized marketing emails, messages and in-game and web offers about Wargaming offline events, co-projects of Wargaming and its partners, as well as about Wargaming games, not using Wargaming ID.
5.2. IN-GAME OFFERS
We will also use the Game-Related Information to send you in-game offers that we believe are most useful to you. To make the offer we first collect Game-Related Information from various players, identify patterns in their behaviour, and create algorithms that identify pools of players following the pattern or particular players who follow the pattern. To those players who actually follow the pattern – we send the in-game offers, which can be personalized (i.e., we want the in-game offer to reach you or a relatively small number of players specifically) or non-personalized (i.e., we want the in-game offer to reach a large number of players following a pattern). We make sure that such offers never have any significant impact on you or our other players. For example, we may notice that you are a player who is very good at playing with French vehicles and has registered the account more than five years ago: so, we may specifically offer you the new French vehicle for rent, but in any case not more expensively than it is offered to other users. You can unsubscribe from personalized in-Game offers through our Account Management tool.
5.3. SERVICES IMPROVEMENT PURPOSES
We analyse your information to identify how to improve the Services and our operations to make them more suitable and interesting for our players in general. We also may ask you to respond to our Services-related questionnaires, and you always have the choice about whether to respond to them and which information you provide.
5.4. FRAUD AND EULA VIOLATIONS DETECTION
We use the information required for our detection, investigation and prevention of cheating in the Game and violations of EULA and Game Rules and policies only for the purposes of detection, investigation and prevention. If the data can be used to prove that cheating or another fraud or EULA violation has occurred, we will further store the data for the establishment, exercise or defence of legal claims during the applicable statute of limitations.
6. HOW WE SHARE YOUR INFORMATION
For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data with the following categories of third parties:
When your personal data is shared with Wargaming affiliates and subsidiaries, as well as third parties outside the European Union or the European Economic Area, Wargaming guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with Wargaming affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the standard data protection clauses upon your request.
Sharing anonymous information. We also may share anonymous information, i.e. information which does not directly or indirectly disclose your identity, and aggregated information (meaning information about groups and categories of users, including game statistics and behaviour, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
7. YOUR RIGHTS
To allow you to exercise your data protection rights in a simple way we have improved the Account Management tools. If you are using a demo account, you will only be able to fully control our use of your data after you create the Account here or – for Console Games – here. This means that if you are using a demo version of the Account, you will only be able to fully control our use of your data after you complete the Account here. Please visit it to make choices about which direct communications you would like to receive, as well as to exercise your rights to data access, data erasure and objection to data processing.
7.1. OPT-OUT OF DIRECT MARKETING AND RIGHT TO OBJECT
You can opt-out of personalized advertising in mobile applications, including our mobile Games, by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). You can adjust your mobile push notifications in your Android or iOS device settings menu.
Where processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you can use your right to object at any time. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims.
7.2. RIGHT OF ACCESS
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through the “Data Export” tool available in the Account Management tools. Normally, we provide the duplicate of the Personal Data retained within 30 (thirty) days upon your request. Once the archive with the Personal Data we retain is ready, you will be able to download in it from our resources. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. We also will not be able to provide you with some Personal Data that you may post or provide using our Services regardless of our request not to provide the Personal Data in this particular field, website, etc.
7.3. RIGHT TO RECTIFICATION
You control which nickname, email, phone number, country, social networks accounts, trusted sites and payment methods we associate with your Account. If they change, please modify the data in the Personal Account directly. Please inform us if any of the Personal Data we retain about you is inaccurate.
7.4. RIGHT TO ERASURE
You have the right to obtain deletion by us of Personal Data concerning you by deleting your Account via our “Account Deletion” tool available in the Account Management tools.
As a result of deleting your Account, you will lose access to most Services, including the Account and Game-Related Information linked to the Account, subscriptions to Wargaming forums and the possibility to access other services you are using the Account for.
Grace period. We allow you to restore your Account during a grace period of 45 (forty-five) days from the moment you request deletion of your Account. This functionality allows you not to lose various Game-Related Information and other important information and options by mistake. During the suspension period, we will be able to finalise financial and other activities that you may have initiated before sending the Account deletion request.
No payments after Account deletion. As a result of deleting your Account, you will lose the possibility to make payments in the Premium Shop, including during the grace period. Should any payment be made after Account deletion due to a technical error or for any other reason, we will refund the amount paid by you and will not grant you the rights to the respective Additional Features.
Complicated Account deletion. In some cases, deletion of your Account, and therefore Personal Data deletion, is complicated. Namely, if you are a clan commander in the Games, it is highly likely that you will only be able to delete your Account after you have transferred the clan and placed it under the command of another user or dissolve the clan. In some cases, considering the complexity and number of the requests, the period for Personal Data erasure may be extended, but for no longer than two further months.
Earlier Personal Data deletion. We store most Personal Data we retain about you until you request deletion of your Account through the Account Management tools. However, certain Personal Data is deleted even while you have a valid Account. For example, we will delete:
Information we retain. Upon expiry of the suspension period we will delete all Personal Data about you, except for the data that are required for our compliance with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating in the Game and EULA violations. We will also retain anonymous information after your Account has been closed. Information you have shared with others (e.g. through in-Games chats, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
You also have the right to lodge a complaint at a supervisory authority.
8. WE CAN CHANGE THIS POLICY
We may change this Policy from time to time for various reasons, such as legal and regulatory changes, changes in industry practices and technological developments that need to be reflected.