Effective Date: March 23, 2025

KOSMONAUTS – Privacy Policy

1. Introduction

Antonio Noboa (“The Company”, “Company”, “we”, “our,” or “us”) collects, uses, and processes information about you (“you”, “user”, or “player”). We provide various services related to the Game (i.e. game, website, event, survey, Esports, or customer service) (“Games and Services”).  This Privacy Policy (“Policy”) covers the personal information that is provided, collected, or generated when you access, use, or subscribe to our Games and Services, except where separate privacy policies or terms and conditions apply. This Policy applies to our Games and Services, and explains the rights and choices you have with respect to this data, and how you can communicate with us. This Policy does not apply to and cannot control activities when you click or visit to other sites from our Game and Services.

We will occasionally update this Policy. When we do, we will revise the effective date above. While we will periodically inform you of this Policy or any material changes to it, your continued use of our Games and Services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when we offer our Games and Services.

2. What Information Do We Collect

We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. The information you provide to us may differ depending on the circumstances. For example, these include:

1) Identifiers such as, SteamID, nickname, name, IP address, email address, postal address, phone number, date of birth, gender, country of residence, language, nationality, etc.; 

2) Device or Network Information such as, device model, OS version, MAC address, device ID, etc.; 

3) Game information, such as information about crash report and system activity details(game setting, play date/time, etc.); and

4) Purchase information, such as purchase date, items, etc.When you participate in social features (such as in-game chat), the information that you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Additional data, such as personally identifiable information, is collected only with user consent.

We use this data to operate and improve our Game and Services. Some of this information is collected through our use of cookies and related online tools/technologies. See our “Cookies and Related Technologies” section below for more information. 

3. How We Use Your Information

We use the collected information for a variety of purposes, primarily, to provide the Games and Services to players like you and to improve the quality of our Games and Services. These include:

1) To operate and provide our Games and Services;

2) To develop new games, improve the quality of our Games and Services, and fix bugs; 

3) To detect and act upon the illegal or unauthorized use of our Games and Services;

4) To manage inquiries and requests from you (e.g. refund items in-game, etc.);

5) To provide advertising information and other information on marketing and promotional events and surveys; 

6) To track usage patterns, analyze trends of users, and calculate statistics on Games and Services; 

7) To prepare user statistics and provide in-game metrics (such as a leaderboard);

8) To operate Esports and provide opportunities participate in tournament(s);

9) To participate in partnership programs;

10) To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, cheating, hacking or criminal activity; and

11) To comply with and enforce legal requirements, agreements, and policies.

We may share aggregated or anonymized gameplay data with third-party partners for business analytics, marketing strategies, and the development of industry partnerships. This data does not include personally identifiable information unless you have explicitly consented to such sharing.

We may also share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, with our affiliates for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction. 

5. Cookies and Related Technologies

We use cookies, and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Games and Services. 

Cookies are small files downloaded to your device (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your device hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of our websites may not function properly.

We use third parties analytics service to improve Services and your experience. Analytics services providers could collect your activity data during use our Games and/or Services. However, we do not allow the collection or access to information that directly identifies you, such as your name, email address, etc. You can find the information you need to manage collecting your data on the below.

– Google Analytics: https://tools.google.com/dlpage/gaoptout

We also strive to provide a safe and fair gaming environment for all players.  When you play the Game, we or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security, and authentication purposes. 

In addition to Google Analytics, we may use tracking technologies such as in-game telemetry, AI-powered analytics, or advertising pixels. Players may disable these in their device settings where applicable.

6. International Data Transfers

We operate globally and to provide our Games and Services may transfer your data to countries and other regions outside of the country where you are located. If your personal information is transferred, stored, or processed by us, we take reasonable steps to safeguard the privacy of your personal information, including entering confidentiality and standard contractual clauses with vendors where appropriate. Additional information concerning the international transfer of your information is available depending on your region. See the supplemental terms section below for more information.

7. Retaining and Deleting Personal Information

In principle, we will remove your personal information without delay after the purpose of collecting personal information is achieved. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a player. Gameplay analytics may be retained indefinitely in an anonymized form.

8. Our Policy Concerning Children

This Game and/or Service are not intended for underage users. Thus, we do not knowingly collect, use, or share any information about them. When we process the child’s information under 18, we will be obtaining consent from parents or guardians for the collection of personal information from their children before they are using our Games and Services. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.

9. Links and Third-Party Services

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Games and Services, you should consult that site’s privacy policy before providing any personal information.

10. Security of Your Information

We have put in place appropriate security measures, including encryption and de-identification, to protect your personal information. In addition, we limit access to your personal information to those employees, agents, persons, or companies who have a business need to know or access the information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality where appropriate. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed. Our information protection activities are audited by external authorities consistent with the Ecuadorian Data Protection Law.

 11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “13. Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Amendments

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Games and Services. If we make material changes, we will post a prominent notice on our websites or in our Games and Services or give you other reasonable notice before any material changes take effect. All other changes are effective upon posting.

13. Contact Us

If you have any questions about this Policy, or your dealings with our Games and Services, please contact us by sending an email to kosmonautsgame@gmail.com.

This Privacy Policy has been translated into other languages for your convenience. In case of any discrepancies between the English version and the other versions, the English version shall prevail.

Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC 

If a dispute regarding personal data arises between you and Company, our goal is to provide you with a neutral and cost-effective means of resolving the dispute quickly. This Privacy Policy shall be interpreted and governed by the laws of the Republic of Ecuador, specifically, Ecuador’s Data Protection Law. Other laws may apply if you use the Game outside of the Republic of Ecuador. Where local data protection laws (e.g., GDPR, CCPA) provide additional rights, they will take precedence over conflicting provisions.

In such event, the applicable local laws shall only affect this Privacy Policy to the extent required by the applicable jurisdiction, and these Terms shall be construed as to make their terms and conditions as effective as possible. You must comply with all local laws to the extent that applicable local law applies. In jurisdictions with more specific data protection laws, such as the European Economic Area where the GDPR is in effect, this Privacy Policy should be interpreted to best adhere to said laws, for example, by using Standard Contractual Clauses (SCCs) for data transfers outside the EU. 

This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls. Company reserves the right to further develop upon this section as the Game market expands. 

1. United States

1) Privacy Rights for United States Users

Several U.S. states provide their residents with rights to:

a. Confirm whether we process their personal information;

b. Access and delete certain personal information;

c. Take their data from one location to another (data portability);

d. Opt-out of personal data processing for targeted advertising and sales;

e. Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose; and

f. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights submit a request in our support page (email: kosmonautsgame@gmail.com). 

1.1) Nevada

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: (e-mail: kosmonautsgame@gmail.com). However, please know we do not currently sell data triggering that statute’s opt-out requirements.

1.2) California

If you are a California resident, you may have additional rights as detailed below if within the preceding 12 months we have collected or disclosed the following categories of personal information about you: 

a. Identifiers, such as SteamID, nickname, name, email address, postal address, phone number, date of birth, gender, country of residence, etc.

– How it is collected: When you access or play our Game or Services, we collect this directly from you.

– How it is disclosed: With our affiliates and service providers (e.g., platform service provider, chatting service provider, block cheating tool service provider, cloud storage service provider, payment service provider, marketing platform service provider, online survey service provider, customer service provider, esports event provider). 

b. Characteristics of protected classifications such as sex, date of birth, language, nationality, etc. 

– How it is collected: When you access or play our Games or Services, we collect this directly from you.

– How it is disclosed: With our affiliates and service providers (e.g., platform service provider, cloud storage service provider, online survey service provider, customer service provider, esports event provider). 

c. Internet or other similar network activity, such as browsing behavior while using our Games and Services (e.g., device model, OS version, MAC address, device ID, game information, etc.), identifiers such as IP address.

– How it is collected: When you access or play our Games or Services, we collect this automatically.

– How it is disclosed: With our affiliates and service providers (e.g., platform service provider, chatting service provider, block cheating tool service provider, cloud storage service provider, marketing platform service provider, customer service provider, esports event provider).

d. Geolocation information obtained by IP address.

– How it is collected: When you access or play our Games or Services, we collect this automatically.

– How it is disclosed: With our affiliates and service providers (e.g. platform service provider, block cheating tool service provider, cloud storage service provider, payment service provider, marketing platform service provider, customer service provider, esports event provider).

e. Commercial information, such as purchase date, items, etc.

– How it is collected: When you purchase items in Games or Services, we should be automatically collected from third party’s 

– How it is disclosed: With our affiliates and service providers (e.g., platform provider, cloud storage service provider, payment service provider, customer service provider).

f. Audio, electronic, visual, thermal, olfactory, or similar information such as voice chat data, profile image (when you login with social media account), etc. 

– How it is collected: When you access or play our Game or Services, we collect this automatically.

– How it is disclosed: With our affiliates and service providers (e.g., platform service provider, chatting service provider, block cheating tool service provider, cloud storage service provider, customer service provider, esports event provider)

We determine the retention period for each of the categories of personal information listed above based on our business or commercial purposes for obtaining the information, our legal or regulatory requirements applicable to such information, and in relation to litigation or to protect our rights.

– Your California Privacy Rights

You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at kosmonautsgame@gmail.com.

Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.

We will verify your identity and respond to your request within 45 calendar days. If necessary, we may take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, in which case we will notify you to explain the reason for the delay.

a. Right to Know & Right to Access

You have the right to request the following information from us up to two times within a 12-month period: 

– the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;

– the categories of sources from which personal information was collected;

– the business or commercial purposes for which personal information is collected;

– the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months; and 

– the categories of third parties to whom the information was disclosed or sold (if applicable).

b. Right to Delete 

You have the right to request that the personal information collected from you be deleted.

c. Right to Correct 

You have the right to correct your personal information. You can edit your personal information via email to kosmonautsgame@gmail.com. 

d. Right to Non-Discrimination

You have the right not to be discriminated against for exercising these privacy rights.

e. Right to opt-out of Selling and Sharing

You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. With respect to targeted advertising, you can control the sharing of your personal information for targeted advertising purposes through our website by choosing to opt out.

f. Rights for California Minors

Minors under the age of 16 have the right to request the deletion, correction or copies of information publicly posted by you, such as on forums or bulletin boards. 

g. Shine the Light

You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.

h. Limit Use and/or Disclosure of Sensitive Personal Information 

You have the right to limit our use of your sensitive personal information. However, WE DO NOT USE YOUR SENSITIVE PERSONAL INFORMATION for purposes that require us to offer this limitation option. If we collect your sensitive personal information, we will get your consent. 

– Authorized Agent 

You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf to make a request to know or to delete.

To use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to kosmonautsgame@gmail.com.

The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.

If you have any questions about this Policy, or about exercising your rights described above, you can contact us by email at kosmonautsgame@gmail.com.

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