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Políticas de Privacidad

The present Privacy and Security Policy is provided to you only in English. If you do not understand the content of this document, please do not use our website. By using our website, you hereby declare that you understand the provisions of this document and that you agree to be bound by it.

(1) Here at eRepublik we care about your privacy and we respect your privacy rights.

(2) By using eRepublik and/or the eRepublik.com Service, you permit the collection and use of your personal information as outlined below and you signify your agreement to this Privacy Policy (last updated on the 3rd of March 2012). If you do not agree with these terms, you should not use eRepublik and/or an eRepublik.com Service.

1 About our Privacy Policy

Our website www.erepublik.com, which includes the eRepublik application programming interface system (further described at http://api.erepublik.com/eapi-docs.pdf) (“eAPI System”), all the webpages containing that address and any webpage containing this domain name, including any page that is enabled for use by a mobile device (“eRepublik”) and the eRepublik Service (as defined in the Terms and Conditions of Use) are operated and provided by eRepublik Labs Limited of The Seapoint Building, 44/45 Clontarf Road, Dublin 3, Ireland, registration no. 462101, VAT No. IE - 9693023K (“we”, “us” and “our”) and is administered by SC ERPK LABS SRL of 39-41 Nicolae Filipescu street, 2nd floor, 2nd District, Bucharest, Postal Code 020961, Romania, registered with the Romanian Trade Register under No. J40/6415/2009, having the Sole Registration No. 25622297 on our behalf.

1.1 eRepublik and the eRepublik Service allows people to register as “Citizens” in order to engage and participate in a variety of activities through the medium of an mass multiplayer online social strategy game, a mixture between social platform and a text- based game with social, economical, political, military and media modules. eRepublik users, referred to as “Citizens”, live in virtual replicas of their “real life” countries, with the possibility to become employees, soldiers, party presidents or members, business members, congress members or even country presidents, and use other functionality made available on eRepublik from time to time.

1.2 This policy (together with our Terms and Conditions of Use http://www.erepublik.com/ en/terms-and-conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2 How we Collect Information on EREPUBLIK

2.1 When registering as a user of eRepublik or during your time as a user of eRepublik you will be asked to provide information to us. We will inform you at the time of collecting other information from you whether you must provide the information to use eRepublik or a particular eRepublik Service or whether the provision of information requested by us is optional. We will inform you at the time of collecting information from you whether the information that you provide to us will be accessible to other users of eRepublik or by third parties so that you can decide whether to provide the information to us.

2.2 We may collect and process the following data about you:

2.2.1 if you contact us, we may keep a record of that correspondence;

2.2.2 information that you submit when you register for the Website including your name, date of birth and e-mail address.

2.2.3 information that you submit in response to a news post or discussion thread, shouts, private messages or through any other in- game communication channels;

2.2.4 the functionality that you use through the eRepublik Service, including your gameplay choices;

2.2.5 details of transactions you carry out through eRepublik; and

2.2.6 details of your visits to eRepublik including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

2.3 Persons under 14 years of age are not entitled to register as Citizens on eRepublik. If you are between 14 and 18 years of age you agree that you have made sure that you have brought this Privacy Policy to the attention of a parent or guardian or a grandparent, uncle, aunt, brother or sister of the person and that they have consented to you agreeing to this Privacy Policy and using the eRepublik (provided that the giving of such consent is not prohibited by law).

3 Uses made of the information

3.1 eRepublik users partake in the virtual eRepublik community by writing shouts about topics of interest, private messages, articles, article comments and blog comments, interacting with other users in the eRepublik discussion forum, using Citizen ads aimed at a particular target audience, creating articles to communicate to other users and creating virtual organisations, companies and parties, and so on. All of these publications and organisations can be accessed in various areas of eRepublik including but not limited to the company homepage, Citizen profiles, organisation profiles, party homepages, articles, articles comments, private messages, law proposals, presidential messages, the eRepublik official wiki, Citizenship request messages, all debate links, as well as in any other areas of eRepublik not listed here, that will or may be created in the future. These shouts, forum topics, Citizen ads and articles can then be accessed and read by other users of eRepublik. You can search for other registered users of eRepublik. If you choose to be a registered user of eRepublik, we will not display your personal information. Only in- game information will be available to other users, which is information that will allow users to evaluate your views and your eRepublik communications.

3.2 We use information held about you in the following ways:

3.2.1 to ensure that content from eRepublik is presented in the most effective manner for you and for your computer;

3.2.2 to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes including by interacting with advertising functionality in eRepublik;

3.2.3 to carry out our obligations arising from any contracts entered into between you and us;

3.2.4 to deliver and maintain a high quality service;

3.2.5 to allow you to access eRepublik and to participate in interactive features of our service, when you choose to do so;

3.2.6 to notify you about new games or applications developed by our company, changes to our service, new features or new versions of the eRepublik game;

3.2.7 for the purposes of compiling statistics;

3.2.8 to determine whether you are in compliance with the eRepublik rules and to impose sanctions where necessary; and

3.2.9 to process payments.

3.3 Information such as your username, photograph (avatar), geographic location within eRepublik, personal profile, Website history profile, and any personally identifiable information you have included in the shouts, Citizen ads, articles you publish, or other details you post in any of the areas of eRepublik, may be shown to other users of eRepublik and the eRepublik Service, as well as to other people, through the eRepublik application programming interface system (further described at http:// api.erepublik.com/eapi-docs.pdf) (“eAPI System”). eRepublik history profile consists of, for example, your date of joining, your rating information, information about the amount of money available in your account, information about your economic, political or military activity in eRepublik and other material which you have contributed. Your personal profile would consist of, for example, your eRepublik birthday and national rank.

3.4 Information such as shouts (which may contain personally identifiable information) and details of latest news, alliances, wars and military events may be exported to third party websites which you have chosen to use in eRepublik via the eAPI System. No personally identifiable information will be exported to third party websites via the eAPI System, other than with your express authorisation in response to a request from a third party user of the eAPI System. Please note that any authorisation that you give to a third party user of the eAPI System to use your data is a matter for you and a third party user of the eAPI System; we are not responsible for the manner in which you choose to allow them use your data.

3.5 We may sell or licence your shouts, articles, content, data and any other messages you post on any area of eRepublik to third parties for their use, in which case your username and any personally identifiable information you have included in your shouts, articles, private messages or through any other in-game communication channels may be shown to users of such third party websites. Except as set out in this Privacy Policy, we do not sell, rent, share, trade or give away any of your personal information.

3.6 We may also use your email address to send you updates or news regarding eRepublik, but you may choose not to receive emails of this type by unchecking the “Sign up for the weekly newsletter” box on the eRepublik registration page. You can also subscribe/unsubscribe to this weekly newsletter in the Subscriptions page erepublik.com/en/messages/subscribes/1. Additionally, we may contact you using your email address to notify you that other users have sent you a personal message and to inform you that someone wants to add you as a friend, or that they simply want to contact you.

3.7 We may use your shouts, citizen ads, articles or other details you post in any area of eRepublik to personalise eRepublik and identify/feature popular members. For example, we may promote the most popular and latest shouts, groups, listings and members. We may also promote most active members. While we do not expect totransfer the complete member database to others, we use the database throughout our networks and to generate results for others, including, but not limited to, enabling users to contact each other and facilitating inter-user communications.

4 Disclosure of your information to other people

4.1 We do not disclose to any third party personal information that you provide to us unless we have your permission or we believe the law permits or requires it.

4.2 If you provide personal information to us you understand and agree that we may disclose your personal information to the following third parties:

4.2.1 to the eRepublik hosting provider: Heruvim, Inc., with registered office at 12020 Sunrise Valley Drive, Suite 100 PMB 121, Reston, Virginia 20191, United States of America. You acknowledge that we may change the hosting providers at any time and any such change will be posted on eRepublik by an amendment to this Privacy Policy. You consent to the transfer of your personal data to any new hosting provider’s servers. You may communicate any questions, comments or requests in relation to any change in hosting provider by emailing office@erepublik.com or by post to 39-41 Nicolae Filipescu street, 2nd floor, 2nd District, Bucharest, Postal Code 020961, Romania.

4.2.2 if you have indicated at registration, or at any time during your time as a user of eRepublik, that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, you consent to us sending you such offers or information. You may opt out of receiving such offers or change your preferences at any time by emailing office@erepublik.com;

4.2.3 any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;

4.2.4 to companies that provide emailing services, with the sole purpose of sending you information about our services, including about any updates, new features or new versions of the eRepublik game. These companies are prohibited from using your personally identifiable information for any other purpose than as mentioned in this article. You may opt out of receiving such offers or change your preferences at any time by emailing office@erepublik.com;

4.2.5 any third party user of the eAPI System who or which you have authorised in the manner described in paragraph 3.4 above;

4.2.6 to the prospective seller, buyer or assignee of any business or assets related to eRepublik or all or part of eRepublik Labs Limited, SC ERPK LABS SRL, or any other member of our group of companies; and

4.2.7 to a third party if we are under a duty to disclose or share your personal data with that third party in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of use http:// www.erepublik.com/en/terms-and-conditions and other agreements, or to protect the rights, property, or safety of our group of companies, eRepublik, our customers, other registered users or others. This includes exchanging information with third parties for the purposes of fraud protection and credit risk reduction.

4.3 We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing at the time that we notify you.

4.4 We do not disclose personal information about you to other third parties (including advertisers or marketing companies) except those set out in this policy, but we may provide them with aggregate anonymised information about eRepublik users. Forexample, we may inform them that 500 men aged under 30 have clicked on their advertisement displayed on eRepublik on any given day, or we might inform third parties regarding the number of unique users who visit eRepublik, the demographic breakdown of our community users of eRepublik or the activities that visitors to eRepublik engage in while on eRepublik. We may also use such aggregate anonymised information to help advertisers reach the kind of audience they want to target (for example, women in the southeast of Ireland) when displaying advertisements on our website. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. You agree to these practices.

4.5 It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the European Economic Area (EEA). This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA. The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU but in these instances we will take steps to ensure that your privacy rights are respected. You agree that we may transfer your personal data on that basis.

5 SECURITY and control OF your personal data

5.1 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy .

5.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of eRepublik, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You are responsible for the security of your password and our Terms and Conditions of Use http://www.erepublik.com/en/terms-and-conditions deal with this in more detail.

5.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to eRepublik; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner .

5.4 You should be aware that when you voluntarily disclose personally identifiable information and agree to make that information public on eRepublik (e.g., user name, e-mail address) via shouts, personal messages, forums, postings, articles or in other areas of eRepublik and/or eRepublik Service or via the eAPI System, that information, along with any substantive information disclosed in your communication, can be collected, correlated and used by third parties. These third parties or other eRepublik users may use your information to send you unsolicited messages. Such activities are beyond our control. Please do not post any personal information on eRepublik or in other areas that you wish to keep private.

6 LINKS TO THIRD PARTY WEBSITES

6.1 eRepublik may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, including any link to a third party website facilitate through the eAPI System, please note that thesewebsites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies or for the activities on those websites.

7 IP addresses and cookies

7.1 We may collect information about your computer, including (where available) your IP address, alphanumeric IDs, operating system and browser type, information regarding the volume and status of data transmission, click-through statistics, the name of the domain and host from which you access the Internet, the date and time you accesses portions of eRepublik, for system administration and statistical purposes. This is statistical data about our users’ browsing actions and patterns, and we do not use them to identify any individual, except if required by the law .

7.2 For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting eRepublik our computer server will recognise the cookie, giving us information about your last visit. They help us to improve eRepublik and to deliver a better and more personalised service. They enable us:

7.2.1 to estimate our audience size and usage pattern;

7.2.2 to store information about your preferences, and so allow us to customise eRepublik according to your individual interests; and

7.2.3 to speed up your use of the eRepublik Service and searches.

7.3 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access or use certain parts of eRepublik. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to eRepublik. For information on how to control your cookies go to www.allaboutcookies.org.

8 Access to information and updating, verifying and deleting personal data

8.1 At any time, you can make a written request to have access to all the personal information that we hold about you. We will provide this information to you and may request a small administrative charge.

8.2 As a registered user of eRepublik and/or eRepublik Service, you can modify and update your personal information at any time by accessing your public profile on eRepublik and choosing the option “Edit Profile” or by contacting us at office@erepublik.com. If you choose to delete your account, you may contact us at the above email address or via the Support Centre available in the “Contact” section of eRepublik and request that your account be deleted. However , your username, avatar, gender, posts on eRepublik, such as shouts, private messages, forum posts, and so on, will remain recorded in the eRepublik History. The only information that will accompany such posts will be your Username, avatar and gender .

9 Changes to our Privacy Policy

9.1 Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. You should visit this page periodically to review any changes to the Privacy Policy .

10 user feedback and complaints

10.1 Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to office@erepublik.com or by post to 39-41 Nicolae Filipescu street, 2nd floor, 2nd District, Bucharest, Postal Code 020961, Romania.

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