Effective Date (07/02/2018):
Welcome to Xsolla. Xsolla values the privacy of the users, developers and others who visit and use Xsolla (collectively or individually, “You”, “User” or “Users”).
The Information Xsolla Collects
You may provide to Xsolla what is generally called “personally identifiable” information (including, but not limited to your name, email address, PayPal account, home/mobile telephone number, bank account and/or credit card number and billing information, behavioral or demographic attributes tied to personal identifiers) if you purchase Software or otherwise use the features and functionality of Xsolla.
“Cookies” Information: When you access Xsolla, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. Xsolla may use both session cookies and persistent cookies. A session cookie disappears after you close your web browser. A persistent cookie remains after you close your web browser and may be used by your web browser on subsequent visits to Xsolla. Persistent cookies can be removed. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.
“Automatically Collected” Information: When you access Xsolla or open one of our HTML emails, we may automatically record certain information from your system by using different types of tracking technology. This “automatically collected” information may include but is not limited to Internet Protocol address (“IP Address”), your geolocation, a unique user ID, version of software installed, system type, the content and pages that you access on Xsolla, and the dates and times that you visited Xsolla.
In some cases, Xsolla can combine automatically collected information and personally identifiable information, such as obtaining a geolocation from your IP address and combining behavioral data about the use of Xsolla features and capabilities with your name. If we combine these types of information, we will treat the combined information as personally identifiable.
The Principles Xsolla Uses
When processing personal data Xsolla is guided by the following basic principles:
1) Legitimacy, fairness and transparency. Personal data must be processed legally, fairly and transparently. Any information about the purposes, methods and volumes of processing of personal data we set out as accessible and simple as possible.
3) Minimize the data. We do not collect your personal data in a larger volume than Xsolla needs for processing purposes.
4) Accuracy. Personal data that is inaccurate, we will remove or correct immediately (at your request). You have the right to demand correction of your inaccurate personal data without undue delay on our part.
5) Restriction of storage. Personal data is stored in a form that allows you to identify the data subject for a period of no more than necessary for processing purposes.
6) Integrity and confidentiality. When processing user data, we try to protect personal data from unauthorized or illegal processing, destruction and damage.
The Way Xsolla Uses Information
Xsolla uses the information that you provide or that we collect to perform under the respective Xsolla End User Licensing Agreement, to operate, maintain, enhance, and provide all of the features found on Xsolla as well as to track user-generated content and Users to the extent necessary to comply with the Digital Millennium Copyright Act.
We may use your email address, without further consent, for administrative communications such as notifying you of major Xsolla updates, for customer service purposes, to address copyright infringement or defamation issues, for email advertisement and other marketing activities, or to contact you regarding any content that you have posted or purchased from Xsolla.
Xsolla uses all of the information that we collect to understand the usage trends and preferences of our Users, to improve the way Xsolla works and looks, and to create new features and functionality.
Xsolla may use “Automatically Collected” information and “Cookies” information to: (a) automatically update the Xsolla application on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access Xsolla; (c) monitor aggregate site usage metrics such as total number of visitors and pages accessed; and (d) track your entries, submissions, and status in any promotions or other activities.
Xsolla will use collected information in order to identify your location, domicile and the place of purchase for tax purposes.
When Xsolla Discloses Information
Please be aware that any personally identifiable information that you voluntarily choose to display on any publicly available portion of Xsolla – such as when you publish content, comments or profile information – becomes publicly available and may be collected and used by others without restriction.
Xsolla may disclose Automatically Collected and other aggregate non-personally-identifiable information with interested third parties to assist such parties in understanding the usage and demographic patterns for certain programs, content, services, advertisements, promotions, or other functionality of Xsolla.
Xsolla may disclose User information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws or to respond to a court order, judicial or other government subpoena, or warrant in the manner required by the requesting entity. We disclose information to tax authorities in order to comply with applicable tax laws.
Xsolla also reserves the right to disclose User information that we believe, in good faith, is appropriate or necessary to take precautions against liability; protect Xsolla from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of Xsolla; or to protect the rights, property, or personal safety of Xsolla, our Users, developers or others.
Third party providers
We may also allow third parties to use anonymous information or aggregated anonymous User information for their business purposes. We may share your personal information with our affiliates or unrelated third parties to use for their own marketing purposes.
You may decline to share your personally-identifiable information with Xsolla, in which case Xsolla will not be able to provide to you some of Xsolla’s features and functionality, or withdraw your consent to the processing of personal data and request the withdrawal of information. An appropriate application for revocation of your consent to the processing of personal data can be sent to firstname.lastname@example.org. In the case of such a request, we may require you to verify the identity through proper identification documents.
You also have the right to require Xsolla to remove your personal data submitted to us earlier, and we will do it immediately if such data is no longer needed for processing purposes. If the data you request for removal is still required for processing purposes, we will notify you of this and you will be able to decide to withdraw your request or withdraw your consent to the processing of personal data.
You may request us to limit the processing of your personal data if you believe that we use your inaccurate personal data, or you believe that their processing is illegal or you object to the processing of your personal data.
You may provide us with an objection regarding the processing of your personal data related to your particular situation at any time. Your request should be sent to email@example.com.
You may review and opt out of receiving personalized ads and sharing your information with third parties for direct marketing purposes at any time at http://optout.aboutads.info/.
You may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact Xsolla at firstname.lastname@example.org.
Xsolla uses commercially reasonable physical, managerial, organizational and technical safeguards to preserve the integrity and security of your personal information, as well as to effectively implement the principles of data protection, the timely selection of the necessary means of protecting personal data and ensuring the protection of your rights. Xsolla takes the appropriate technical and organizational measures to ensure that only the personal data that is required for each specific purpose of processing is processed by default. We cannot, however, ensure or warrant the security of any information you transmit to Xsolla, and you do so at your own risk. Once we receive your transmission of information, Xsolla makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If Xsolla learns of a security systems breach, then we attempt to notify you electronically so that you can take appropriate protective steps in a period not exceeding 72 hours from the moment of violation of security. Xsolla may send you a notice if a security breach occurs.
If you are under 13 years of age, then please do not use or access Xsolla at any time or in any manner. Protecting the privacy of young children is especially important. For that reason, Xsolla does not knowingly collect or maintain personally identifiable information from persons under 13 years-of-age. If Xsolla learns that personally-identifiable information of persons less than 13-years-of-age has been collected on or through the Xsolla, then Xsolla will take the appropriate steps to delete this information. If you are the parent or legal guardian of a child under 13 who has provided Xsolla with personally identifiable information, then please contact Xsolla at email@example.com to have that information deleted
Your California Privacy Rights
California Civil Code Section 1798.83 permits users of Xsolla that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact Xsolla at firstname.lastname@example.org.
Your Other Privacy Rights
Where provided under applicable law, you may request a copy of the personal information held by Xsolla about you and may ask about all recipients of the information, the purpose of the processing, request the correction of incorrect information, and request the blocking and deletion of such information by contacting us at email@example.com. We may require you to prove your identity with approved identification if you request this information. Any access request may be subject to a fee to provide you with details of the personal information we hold about you. You have the right, where provided under applicable law, to ask us not to process your personal information.
You have the right, where provided under applicable law, to ask us not to process your personal information for direct marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information or clicking “unsubscribe” on the emails you receive. You can also exercise the right at any time by contacting us at firstname.lastname@example.org. We will retain your personal information for as long as needed to provide you with any services which you request. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
How We Respond to Do Not Track Signals
Your web browser may allow you to automatically send a “Do Not Track” signal to all websites that you visit. Since the “Do Not Track” standard is currently being developed, we do not alter our practices when we receive a “Do Not Track” signal.
Xsolla Contact Information