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Disclaimers and Limitation of Liability
XERA: Survival includes the Unreal® Engine code and other code, materials, and information (the “Epic Materials”) from Epic Games, Inc. (“Epic”). All Epic Materials are provided on an “as is” and “as available” basis, “with all faults” and without warranty of any kind. Spotted Kiwi Interactive, Epic, and Epic’s affiliates disclaim all warranties, conditions, common law duties, and representations (express, implied, oral, and written) with respect to the Epic Materials, including without limitation all express, implied, and statutory warranties and conditions of any kind, such as title, non-interference with your enjoyment, authority, non-infringement, merchantability, fitness or suitability for any purpose (whether or not Epic knows or has reason to know of any such purpose), system integration, accuracy or completeness, results, reasonable care, workmanlike effort, lack of negligence, and lack of viruses, whether alleged to arise under law, by reason of custom or usage in the trade, or by course of dealing. Without limiting the generality of the foregoing, Spotted Kiwi Interactive, Epic, and Epic’s affiliates make no warranty that (1) any of the Epic Materials will operate properly, including as integrated in XERA: Survival, (2) that the Epic Materials will meet your requirements, (3) that the operation of the Epic Materials will be uninterrupted, bug free, or error free in any or all circumstances, (4) that any defects in the Epic Materials can or will be corrected, (5) that the Epic Materials are or will be in compliance with a platform manufacturer’s rules or requirements, or (6) that a platform manufacturer has approved or will approve XERA: Survival, or will not revoke approval of XERA: Survival for any or no reason. Any warranty against infringement that may be provided in Section 2-312 of the Uniform Commercial Code or in any other comparable statute is expressly disclaimed by Spotted Kiwi Interactive and Epic. Spotted Kiwi Interactive, Epic, and Epic’s affiliates do not guarantee continuous, error-free, virus-free, or secure operation of or access to the Epic Materials. This paragraph will apply to the maximum extent permitted by applicable law.
To the maximum extent permitted by applicable law, neither Spotted Kiwi Interactive, Epic, Epic’s licensors, nor its or their affiliates, nor any of Spotted Kiwi Interactive’s or Epic’s service providers, shall be liable in any way for loss or damage of any kind resulting from the use or inability to use the Epic Materials or otherwise in connection with this EULA, including but not limited to loss of goodwill, work stoppage, computer failure, or malfunction, or any and all other commercial damages or losses. In no event will Spotted Kiwi Interactive, Epic, Epic’s licensors, nor its or their affiliates, nor any of Spotted Kiwi Interactive’s or Epic’s service providers be liable for any loss of profits or any indirect, incidental, consequential, special, punitive, or exemplary damages, or any other damages arising out of or in connection with this EULA or the Epic Materials, or the delay or inability to use or lack of functionality of the Epic Materials, even in the event of Spotted Kiwi Interactive’s, Epic’s, or Epic’s affiliates’ fault, tort (including negligence), strict liability, indemnity, product liability, breach of contract, breach of warranty, or otherwise and even if Spotted Kiwi Interactive, Epic or Epic’s affiliates have been advised of the possibility of such damages. These limitations and exclusions regarding damages apply even if any remedy fails to provide adequate compensation.
Because some states or jurisdictions do not allow the exclusion or the limitation of liability for consequential or incidental damages, in such states or jurisdictions, the liability of Spotted Kiwi Interactive, Epic, Epic’s licensors, its and their affiliates, and any of Spotted Kiwi Interactive’s or Epic’s service providers shall be limited to the full extent permitted by law.
End-User License Agreement
Throughout history, several anti–cheat solutions have gained a reputation of being invasive to the end-user privacy, and have thereby given the entire sector a bad name. We don't see countering cheating as a fight based on witch hunts and assumptions, but rather as one based on merit and coding excellence. We do not get involved with screenshots, keylogging, or scanning your hard disk. We are not interested in anything that is personal to you as an individual, and merely wish to deliver a clean and fun game experience to all players alike.
The end-user license agreement for EasyAntiCheat Oy (“Kamu”) services is typically embedded in the game's EULA. The following two paragraphs provide the terms which, in order for the services to be delivered, Kamu has required Spotted Kiwi Interactive Limited to specify to you. Spotted Kiwi Interactive Limited may have chosen for alternative language, but generally the terms will always be highly similar.
Publisher is using the Kamu Game Security service (“Easy Anti-Cheat”), which is operated by a third-party service provider offering services to Publisher. Easy Anti-Cheat has a client software (“Client”) that is integrated into the Software Product. When you start a new Game session the Client will automatically load and install its latest version to the Unit. When you are using the Software Product on your Unit Easy Anti-Cheat is monitoring the Unit, analyzing the Game binaries and scanning the memory of the Unit for the purpose of detecting and preventing cheating in the Game (“Purpose”). For the Purpose Easy Anti-Cheat is storing information regarding cheating methods used in the Game (“Data”). The Data will contain your personal data as described in of the privacy statement of Easy Anti-Cheat. By installing, copying, or otherwise using this Software Product, you give your consent that Easy Anti-Cheat may gather, store, share and publish Data for the sole purpose of the Purpose. You also acknowledge and agree that the processing activities of Easy Anti-Cheat include automated decision-making which may have significant effects to you as you may be banned from the game if you have been found to be cheating in it. The Data will be used solely for the Purpose including but not limited to identifying and banning player accounts which are used for cheating in computer games, analyzing cheating behavior and cheating codes, as well as sharing data about cheats with affiliates of Easy Anti-Cheat. You are entitled to use the Game (i.e. Software Product) only in accordance with these terms and conditions and privacy statement of Easy Anti-Cheat.
You will find more information about the privacy practices of Easy Anti-Cheat on the privacy statement of Easy Anti-Cheat, which you can find from . If you deny Easy Anti-Cheat to process your personal data in accordance with the said privacy statement or request Easy Anti-Cheat to remove or delete your personal data, the Publisher, Easy Anti-Cheat or a third party (appointed by the Publisher or Easy Anti-Cheat) has a right to block your access to the Game and prevent your use of the Game.
Terms Used
Publisher
The legal entity making the license agreement with the end-user, in this case Spotted Kiwi Interactive Limited.
Software Product:
All video game related software for XERA: Survival. May include associated media, printed media, and on-line or electronic documentation.
Game:
Alternative term for Software Product
Unit:
Computer or any other game play device on which the Game is used.
Clarification on Extracts
This section expands on extracts from the EULA and documents the exact intent behind the language. For a more general overview on data protection policies, read the full privacy statement on
We try to be as transparent and clear as possible in the terms and policies affecting you as a player. Should any questions remain after going through the materials, please do not hesitate to contact us on
Loading and installing
When you start a new Game session the Client will automatically load and install its latest version to the Unit.
During Easy Anti-Cheat's loading sequence the latest anti–cheat module is being streamed and loaded to the Unit. To find instructions on how to install and uninstall the Easy Anti-Cheat service, please visit the FAQ on Easy Anti-Cheat’s official website.
Monitoring of the Unit
When you are using the Software Product on your Unit Easy Anti-Cheat is monitoring the Unit, analyzing the Game binaries and scanning the memory of the Unit for the purpose of detecting and preventing cheating in the Game (“Purpose”).
Easy Anti-Cheat only runs when the game is running, and is only concerned with the memory space of the game process. To verify the runtime duration, monitor the Easy Anti-Cheat service status in the Services panel in Windows Task Manager (CTRL+ALT+DEL). If the Easy Anti-Cheat service is manually stopped prior to the game exiting, it may be so that parts of Easy Anti-Cheat remain active in memory until the Unit is restarted.
Monitoring of the Unit
For the Purpose Easy Anti-Cheat is storing information regarding cheating methods used in the Game (“Data”).
We only handle data relevant to the identification of cheats, as found in the Unit's runtime memory or as collected by the game server. Other than that, we do not store any data on individual users and have no intent to ever do so. There are three steps in how session specific data is stored and processed.
Third–party data sharing
The Data will be used solely for the Purpose including but not limited to identifying and banning players who are cheating in computer games, analyzing cheating behavior and cheating codes as well as sharing data about cheats with affiliates of Easy Anti-Cheat.
We see two ways in which we may end up sharing Data with third parties.
Privacy Statement
EasyAntiCheat Oy (“Kamu”, “we” or “us”) is a Finnish company which provides solutions against online game cheating to game developers, publishers and other third parties alike (“Customers”) such as Spotted Kiwi Interactive Limited. In order to provide the said solutions, we provide a wide range of game security services to Spotted Kiwi Interactive Limited, including client-side protection, server-side middleware, and expert developer centric support (“Services”).
When providing the Services to Spotted Kiwi Interactive Limited, Kamu processes personal data of the players or other end-users (“Player” or “You”) who play or otherwise use the online video game XERA: Survival or other services of Spotted Kiwi Interactive Limited (“Game”).
The purpose of this privacy statement is to provide you information regarding the collecting and processing of your personal data and information regarding your rights as a data subject in accordance with the applicable legislation in the EU. From this privacy statement You will find a more specific description of how your personal data will be processed when providing the Services to Spotted Kiwi Interactive Limited.
Information regarding the processor
Processor: EasyAntiCheat Oy, Tammasaarenkatu 3, FI-00180 Helsinki. Business ID 2585063-4
Name of the register: The end-user register of Kamu
Contact person: Simon Allaeys.
Contact information: Postal address: EasyAntiCheat Oy, Tammasaarenkatu 3, FI-00180 Helsinki.
The purposes for the processing
The purpose of processing personal data is to provide solutions against cheating and fraud in XERA: Survival. In practice this means information is gathered of the Players interacting in the Game and the gathered information is exchanged between Kamu and Spotted Kiwi Interactive Limited.
Kamu uses your personal data to the following purposes.
The legal basis for the processing
The processing of the personal data is based on a legitimate interest of Spotted Kiwi Interactive Limited and Kamu. In alignment with the various personal information protection regulations worldwide, Kamu has concluded that the legitimate interest to process the personal data is based on the following facts.
Kamu regularly assesses the legitimate interest for processing the personal data with a three-part balancing test, which considers the nature of the personal data, the reasonable expectations of the data subjects, and the likely impact of the processing activities. Based on this assessment, Kamu and Spotted Kiwi Interactive Limited have determined there is a legal basis for the processing of the personal data. The nature of the personal data is non-sensitive, while data subjects can reasonably expect Spotted Kiwi Interactive Limited to actively prevent and detect cheating and fraud in the Game. Spotted Kiwi Interactive Limited has a sole discretion to decide what kind of the methods identified in the information are being interpreted as cheating or fraud, and what kind of sanctions are to be implemented, if any.
Additionally to the above, your use of the Game requires You to have given your consent to process your personal data as provided in this privacy statement. By using XERA: Survival as provided by Spotted Kiwi Interactive Limited or by accepting the terms and conditions of the Game, You also accept the collection and processing of the personal data referred to herein and the terms of this privacy statement. The processing of your personal data is necessary for the performance of the end-user license agreement between You and Spotted Kiwi Interactive Limited.
If You do not wish or allow your personal data to be processed, do not use or access XERA: Survival.
Personal data we collect and process
Upon registration or during the use of XERA: Survival, the following data may be collected and processed about You.
In addition, the Service may collect automatically saved data, such as the technical log of the server (e.g. your IP-address, your session history), during the use of the Game.
The abovementioned data is primarily obtained from your use of XERA: Survival. Additionally, player account identification data may also be obtained from Spotted Kiwi Interactive Limited or the Spotted Kiwi Interactive Limited’ service providers such as Steam, GOG, and others (“Service Providers”). You have accepted these disclosures by using the Game or Service Providers.
Sharing of your personal data
Your data will be regularly disclosed to Spotted Kiwi Interactive Limited and the Service Providers in order to prevent or investigate misuse within XERA: Survival and to the extent required to implement the sanctions for misuse within the Game.
Your personal data will not be sold, rented, leased, licensed, borrowed or otherwise assigned or disclosed forward to third parties other than the ones expressed in this privacy statement. However, if the business regarding the Service or the shares of Kamu will be redeemed, sold or otherwise assigned, the Player data can be transferred to the party purchasing the shares or the business.
Transfers to third countries
Your Personal data may be transferred outside of the European Union or the European Economic Area to the parties expressed in this privacy statement.
For avoidance of doubt, the transfer of information is always executed in legal and professional manner. We are relying on valid EU data protection safeguards, such as the EU Model Clauses within our company, when transferring your personal data.
Storage period of your personal data
General profile data and aggregated statistical data about You are stored for the entire duration of the legitimate interest of the Customer and the service agreement between Kamu and Spotted Kiwi Interactive Limited for XERA: Survival.
Other personal data are processed in real-time and stored for a duration of maximum 5 days. If the data is suspected to indicate misuse in the Game, the relevant data samples are stored for at most 3 months. If the data is determined to indicate misuse in the Game, the data remains stored until no longer necessary for the purposes provided herein.
Your rights as a data subject
As a data subject, You have the following rights with regards to your personal data. In order to use the rights referred to below, You may contact Spotted Kiwi Interactive Limited directly or alternatively Kamu at
Right of access
You have the right for access, however restricted, to your personal data which we have collected, as well to other information provided in Article 15 of the General Data Protection Regulation. You will not gain access to the information which includes trade secrets or intellectual property, such as the information used to identify methods for cheating or fraud in XERA: Survival.
Right of rectification
You have the right to obtain from us a rectification of inaccurate personal data concerning you. Inaccuracy of personal data shall be determined in good faith by an expert at Kamu.
Right to erasure
You have the right to obtain from us the erasure of your personal data if any of the following conditions are true.
Right to restriction of processing
You have the right to obtain from us restriction of processing if the circumstances provided in Article 18 of the General Data Protection Regulation apply. However, you will not be allowed to use or access the Game during the period You have restricted us from processing your personal data.
Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, such as the correspondence with the Kamu support team. In line with the right of access, You will not gain access to the information which includes trade secrets or intellectual property of Kamu.
Automated decision-making
The processing of your personal data will include automated-decision making. The way we process the data enables us to find out whether particular personal data is showing anomalies and may indicate misuse of the Game.
If You are deemed to have misused XERA: Survival based on the automated-decision making, You will be flagged and reported to Spotted Kiwi Interactive Limited, who is the Customer operating the Game in question. It is up to Spotted Kiwi Interactive Limited to determine what consequences are implemented for the identified misuse of the Game. If Spotted Kiwi Interactive Limited decides to sanction You based on the information we have provided, You have the opportunity to appeal the automated-decisions by contacting our helpdesk at , at which point an expert will review the data and revisit the decision.
The principles of how the data register is secured
The Service is provided through secured communication and the personal data is stored by using the best practices of the industry. The personal data is accessible only by parties obligated to maintain the confidentiality and the secrecy and whose employment tasks require to access to such data.
How to contact us
In case you have questions regarding this privacy statement or general questions regarding the privacy of your personal data, You can contact our customer support at
XERA: Survival includes the Unreal® Engine code and other code, materials, and information (the “Epic Materials”) from Epic Games, Inc. (“Epic”). All Epic Materials are provided on an “as is” and “as available” basis, “with all faults” and without warranty of any kind. Spotted Kiwi Interactive, Epic, and Epic’s affiliates disclaim all warranties, conditions, common law duties, and representations (express, implied, oral, and written) with respect to the Epic Materials, including without limitation all express, implied, and statutory warranties and conditions of any kind, such as title, non-interference with your enjoyment, authority, non-infringement, merchantability, fitness or suitability for any purpose (whether or not Epic knows or has reason to know of any such purpose), system integration, accuracy or completeness, results, reasonable care, workmanlike effort, lack of negligence, and lack of viruses, whether alleged to arise under law, by reason of custom or usage in the trade, or by course of dealing. Without limiting the generality of the foregoing, Spotted Kiwi Interactive, Epic, and Epic’s affiliates make no warranty that (1) any of the Epic Materials will operate properly, including as integrated in XERA: Survival, (2) that the Epic Materials will meet your requirements, (3) that the operation of the Epic Materials will be uninterrupted, bug free, or error free in any or all circumstances, (4) that any defects in the Epic Materials can or will be corrected, (5) that the Epic Materials are or will be in compliance with a platform manufacturer’s rules or requirements, or (6) that a platform manufacturer has approved or will approve XERA: Survival, or will not revoke approval of XERA: Survival for any or no reason. Any warranty against infringement that may be provided in Section 2-312 of the Uniform Commercial Code or in any other comparable statute is expressly disclaimed by Spotted Kiwi Interactive and Epic. Spotted Kiwi Interactive, Epic, and Epic’s affiliates do not guarantee continuous, error-free, virus-free, or secure operation of or access to the Epic Materials. This paragraph will apply to the maximum extent permitted by applicable law.
To the maximum extent permitted by applicable law, neither Spotted Kiwi Interactive, Epic, Epic’s licensors, nor its or their affiliates, nor any of Spotted Kiwi Interactive’s or Epic’s service providers, shall be liable in any way for loss or damage of any kind resulting from the use or inability to use the Epic Materials or otherwise in connection with this EULA, including but not limited to loss of goodwill, work stoppage, computer failure, or malfunction, or any and all other commercial damages or losses. In no event will Spotted Kiwi Interactive, Epic, Epic’s licensors, nor its or their affiliates, nor any of Spotted Kiwi Interactive’s or Epic’s service providers be liable for any loss of profits or any indirect, incidental, consequential, special, punitive, or exemplary damages, or any other damages arising out of or in connection with this EULA or the Epic Materials, or the delay or inability to use or lack of functionality of the Epic Materials, even in the event of Spotted Kiwi Interactive’s, Epic’s, or Epic’s affiliates’ fault, tort (including negligence), strict liability, indemnity, product liability, breach of contract, breach of warranty, or otherwise and even if Spotted Kiwi Interactive, Epic or Epic’s affiliates have been advised of the possibility of such damages. These limitations and exclusions regarding damages apply even if any remedy fails to provide adequate compensation.
Because some states or jurisdictions do not allow the exclusion or the limitation of liability for consequential or incidental damages, in such states or jurisdictions, the liability of Spotted Kiwi Interactive, Epic, Epic’s licensors, its and their affiliates, and any of Spotted Kiwi Interactive’s or Epic’s service providers shall be limited to the full extent permitted by law.
End-User License Agreement
Throughout history, several anti–cheat solutions have gained a reputation of being invasive to the end-user privacy, and have thereby given the entire sector a bad name. We don't see countering cheating as a fight based on witch hunts and assumptions, but rather as one based on merit and coding excellence. We do not get involved with screenshots, keylogging, or scanning your hard disk. We are not interested in anything that is personal to you as an individual, and merely wish to deliver a clean and fun game experience to all players alike.
The end-user license agreement for EasyAntiCheat Oy (“Kamu”) services is typically embedded in the game's EULA. The following two paragraphs provide the terms which, in order for the services to be delivered, Kamu has required Spotted Kiwi Interactive Limited to specify to you. Spotted Kiwi Interactive Limited may have chosen for alternative language, but generally the terms will always be highly similar.
Publisher is using the Kamu Game Security service (“Easy Anti-Cheat”), which is operated by a third-party service provider offering services to Publisher. Easy Anti-Cheat has a client software (“Client”) that is integrated into the Software Product. When you start a new Game session the Client will automatically load and install its latest version to the Unit. When you are using the Software Product on your Unit Easy Anti-Cheat is monitoring the Unit, analyzing the Game binaries and scanning the memory of the Unit for the purpose of detecting and preventing cheating in the Game (“Purpose”). For the Purpose Easy Anti-Cheat is storing information regarding cheating methods used in the Game (“Data”). The Data will contain your personal data as described in of the privacy statement of Easy Anti-Cheat. By installing, copying, or otherwise using this Software Product, you give your consent that Easy Anti-Cheat may gather, store, share and publish Data for the sole purpose of the Purpose. You also acknowledge and agree that the processing activities of Easy Anti-Cheat include automated decision-making which may have significant effects to you as you may be banned from the game if you have been found to be cheating in it. The Data will be used solely for the Purpose including but not limited to identifying and banning player accounts which are used for cheating in computer games, analyzing cheating behavior and cheating codes, as well as sharing data about cheats with affiliates of Easy Anti-Cheat. You are entitled to use the Game (i.e. Software Product) only in accordance with these terms and conditions and privacy statement of Easy Anti-Cheat.
You will find more information about the privacy practices of Easy Anti-Cheat on the privacy statement of Easy Anti-Cheat, which you can find from . If you deny Easy Anti-Cheat to process your personal data in accordance with the said privacy statement or request Easy Anti-Cheat to remove or delete your personal data, the Publisher, Easy Anti-Cheat or a third party (appointed by the Publisher or Easy Anti-Cheat) has a right to block your access to the Game and prevent your use of the Game.
Terms Used
Publisher
The legal entity making the license agreement with the end-user, in this case Spotted Kiwi Interactive Limited.
Software Product:
All video game related software for XERA: Survival. May include associated media, printed media, and on-line or electronic documentation.
Game:
Alternative term for Software Product
Unit:
Computer or any other game play device on which the Game is used.
Clarification on Extracts
This section expands on extracts from the EULA and documents the exact intent behind the language. For a more general overview on data protection policies, read the full privacy statement on
We try to be as transparent and clear as possible in the terms and policies affecting you as a player. Should any questions remain after going through the materials, please do not hesitate to contact us on
Loading and installing
When you start a new Game session the Client will automatically load and install its latest version to the Unit.
During Easy Anti-Cheat's loading sequence the latest anti–cheat module is being streamed and loaded to the Unit. To find instructions on how to install and uninstall the Easy Anti-Cheat service, please visit the FAQ on Easy Anti-Cheat’s official website.
Monitoring of the Unit
When you are using the Software Product on your Unit Easy Anti-Cheat is monitoring the Unit, analyzing the Game binaries and scanning the memory of the Unit for the purpose of detecting and preventing cheating in the Game (“Purpose”).
Easy Anti-Cheat only runs when the game is running, and is only concerned with the memory space of the game process. To verify the runtime duration, monitor the Easy Anti-Cheat service status in the Services panel in Windows Task Manager (CTRL+ALT+DEL). If the Easy Anti-Cheat service is manually stopped prior to the game exiting, it may be so that parts of Easy Anti-Cheat remain active in memory until the Unit is restarted.
Monitoring of the Unit
For the Purpose Easy Anti-Cheat is storing information regarding cheating methods used in the Game (“Data”).
We only handle data relevant to the identification of cheats, as found in the Unit's runtime memory or as collected by the game server. Other than that, we do not store any data on individual users and have no intent to ever do so. There are three steps in how session specific data is stored and processed.
- Analysis: Data is sent from the Unit and processed in real-time on the Easy Anti-Cheat back–end. If nothing abnormal is found, the data is discarded automatically within 5 days upon receival.
- Red flag analysis: If unknown or suspicious patterns are found, the Data is stored for further manual analysis. If the pattern doesn't proof to repeat itself and/or not to be a cheat, the Data is discarded usually within one month and at most three months. This means that a delayed ban can be placed up to three months after the offense.
- Known cheat pattern: The Data remains to be stored as evidence for the duration of the agreement with Spotted Kiwi Interactive Limited for XERA: Survival. This allows any decision to reliably be re-evaluated upon request.
Third–party data sharing
The Data will be used solely for the Purpose including but not limited to identifying and banning players who are cheating in computer games, analyzing cheating behavior and cheating codes as well as sharing data about cheats with affiliates of Easy Anti-Cheat.
We see two ways in which we may end up sharing Data with third parties.
- Spotted Kiwi Interactive Limited can use our online service portal or query our web API with Player account identifiers to get the ban status. We provide ban reason, ban time, and the IP of the game server on which the relevant detection occurred.
- We may hire services that could be considered as 3rd party, e.g. freelance programmers. The purpose is to develop competent anti–cheat software. The 3rd party is required to follow the same privacy policies as Easy Anti-Cheat.
Privacy Statement
EasyAntiCheat Oy (“Kamu”, “we” or “us”) is a Finnish company which provides solutions against online game cheating to game developers, publishers and other third parties alike (“Customers”) such as Spotted Kiwi Interactive Limited. In order to provide the said solutions, we provide a wide range of game security services to Spotted Kiwi Interactive Limited, including client-side protection, server-side middleware, and expert developer centric support (“Services”).
When providing the Services to Spotted Kiwi Interactive Limited, Kamu processes personal data of the players or other end-users (“Player” or “You”) who play or otherwise use the online video game XERA: Survival or other services of Spotted Kiwi Interactive Limited (“Game”).
The purpose of this privacy statement is to provide you information regarding the collecting and processing of your personal data and information regarding your rights as a data subject in accordance with the applicable legislation in the EU. From this privacy statement You will find a more specific description of how your personal data will be processed when providing the Services to Spotted Kiwi Interactive Limited.
Information regarding the processor
Processor: EasyAntiCheat Oy, Tammasaarenkatu 3, FI-00180 Helsinki. Business ID 2585063-4
Name of the register: The end-user register of Kamu
Contact person: Simon Allaeys.
Contact information: Postal address: EasyAntiCheat Oy, Tammasaarenkatu 3, FI-00180 Helsinki.
The purposes for the processing
The purpose of processing personal data is to provide solutions against cheating and fraud in XERA: Survival. In practice this means information is gathered of the Players interacting in the Game and the gathered information is exchanged between Kamu and Spotted Kiwi Interactive Limited.
Kamu uses your personal data to the following purposes.
- Prevention and solving of misuse of the Game by the Player (e.g. cheating and other unacceptable methods);
- Identification and solving of misuse of the Game by the Player (e.g. cheating and other unacceptable methods);
- Compilation of statistics, analyzing and auditing regarding Player;
- Identification of the Player’s digital player account;
- User-specific adaptation of the Service;
- Producing and developing the Services; and/or
- Other equivalent purposes of use
The legal basis for the processing
The processing of the personal data is based on a legitimate interest of Spotted Kiwi Interactive Limited and Kamu. In alignment with the various personal information protection regulations worldwide, Kamu has concluded that the legitimate interest to process the personal data is based on the following facts.
- Spotted Kiwi Interactive Limited has a legitimate interest to prevent cheating and fraud in XERA: Survival, and the data subjects are aware of the processing activities while having the option to opt-out of processing by not accessing the Game;
- Processing of the personal data by Kamu is necessary in order to offer the Services and prevent cheating and fraud in the Customers’ Games; and
- Kamu only processes personal data which relates to interaction with the Game and the data is only shared with Spotted Kiwi Interactive Limited, the Customer operating the Game in question, for the sole purpose of Kamu providing the Services.
Kamu regularly assesses the legitimate interest for processing the personal data with a three-part balancing test, which considers the nature of the personal data, the reasonable expectations of the data subjects, and the likely impact of the processing activities. Based on this assessment, Kamu and Spotted Kiwi Interactive Limited have determined there is a legal basis for the processing of the personal data. The nature of the personal data is non-sensitive, while data subjects can reasonably expect Spotted Kiwi Interactive Limited to actively prevent and detect cheating and fraud in the Game. Spotted Kiwi Interactive Limited has a sole discretion to decide what kind of the methods identified in the information are being interpreted as cheating or fraud, and what kind of sanctions are to be implemented, if any.
Additionally to the above, your use of the Game requires You to have given your consent to process your personal data as provided in this privacy statement. By using XERA: Survival as provided by Spotted Kiwi Interactive Limited or by accepting the terms and conditions of the Game, You also accept the collection and processing of the personal data referred to herein and the terms of this privacy statement. The processing of your personal data is necessary for the performance of the end-user license agreement between You and Spotted Kiwi Interactive Limited.
If You do not wish or allow your personal data to be processed, do not use or access XERA: Survival.
Personal data we collect and process
Upon registration or during the use of XERA: Survival, the following data may be collected and processed about You.
- Username and account identifier;
- In-game reports filed involving You;
- In-game movements and other gameplay behavior;
- Technical information about the hardware used to play the Game, such as motherboard manufacturer, CPU identifier, GPU identifier, and general performance indicators;
- Technical information about the methods, technics, technologies or alike used by You within the Game that may be suspected to indicate the use of methods that are considered unacceptable by Spotted Kiwi Interactive Limited; and/or
- Other equivalent information
In addition, the Service may collect automatically saved data, such as the technical log of the server (e.g. your IP-address, your session history), during the use of the Game.
The abovementioned data is primarily obtained from your use of XERA: Survival. Additionally, player account identification data may also be obtained from Spotted Kiwi Interactive Limited or the Spotted Kiwi Interactive Limited’ service providers such as Steam, GOG, and others (“Service Providers”). You have accepted these disclosures by using the Game or Service Providers.
Sharing of your personal data
Your data will be regularly disclosed to Spotted Kiwi Interactive Limited and the Service Providers in order to prevent or investigate misuse within XERA: Survival and to the extent required to implement the sanctions for misuse within the Game.
Your personal data will not be sold, rented, leased, licensed, borrowed or otherwise assigned or disclosed forward to third parties other than the ones expressed in this privacy statement. However, if the business regarding the Service or the shares of Kamu will be redeemed, sold or otherwise assigned, the Player data can be transferred to the party purchasing the shares or the business.
Transfers to third countries
Your Personal data may be transferred outside of the European Union or the European Economic Area to the parties expressed in this privacy statement.
For avoidance of doubt, the transfer of information is always executed in legal and professional manner. We are relying on valid EU data protection safeguards, such as the EU Model Clauses within our company, when transferring your personal data.
Storage period of your personal data
General profile data and aggregated statistical data about You are stored for the entire duration of the legitimate interest of the Customer and the service agreement between Kamu and Spotted Kiwi Interactive Limited for XERA: Survival.
Other personal data are processed in real-time and stored for a duration of maximum 5 days. If the data is suspected to indicate misuse in the Game, the relevant data samples are stored for at most 3 months. If the data is determined to indicate misuse in the Game, the data remains stored until no longer necessary for the purposes provided herein.
Your rights as a data subject
As a data subject, You have the following rights with regards to your personal data. In order to use the rights referred to below, You may contact Spotted Kiwi Interactive Limited directly or alternatively Kamu at
Right of access
You have the right for access, however restricted, to your personal data which we have collected, as well to other information provided in Article 15 of the General Data Protection Regulation. You will not gain access to the information which includes trade secrets or intellectual property, such as the information used to identify methods for cheating or fraud in XERA: Survival.
Right of rectification
You have the right to obtain from us a rectification of inaccurate personal data concerning you. Inaccuracy of personal data shall be determined in good faith by an expert at Kamu.
Right to erasure
You have the right to obtain from us the erasure of your personal data if any of the following conditions are true.
- Your personal data is no longer necessary for the purposes provided herein, such as when you stopped playing XERA: Survival.
- The legal ground for processing is no longer valid, such as when Spotted Kiwi Interactive Limited has terminated the data processing agreement with Kamu.
- You have objected to the processing and there are no overriding legitimate grounds for the processing.
- The personal data has been unlawfully processed.
Right to restriction of processing
You have the right to obtain from us restriction of processing if the circumstances provided in Article 18 of the General Data Protection Regulation apply. However, you will not be allowed to use or access the Game during the period You have restricted us from processing your personal data.
Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, such as the correspondence with the Kamu support team. In line with the right of access, You will not gain access to the information which includes trade secrets or intellectual property of Kamu.
Automated decision-making
The processing of your personal data will include automated-decision making. The way we process the data enables us to find out whether particular personal data is showing anomalies and may indicate misuse of the Game.
If You are deemed to have misused XERA: Survival based on the automated-decision making, You will be flagged and reported to Spotted Kiwi Interactive Limited, who is the Customer operating the Game in question. It is up to Spotted Kiwi Interactive Limited to determine what consequences are implemented for the identified misuse of the Game. If Spotted Kiwi Interactive Limited decides to sanction You based on the information we have provided, You have the opportunity to appeal the automated-decisions by contacting our helpdesk at , at which point an expert will review the data and revisit the decision.
The principles of how the data register is secured
The Service is provided through secured communication and the personal data is stored by using the best practices of the industry. The personal data is accessible only by parties obligated to maintain the confidentiality and the secrecy and whose employment tasks require to access to such data.
How to contact us
In case you have questions regarding this privacy statement or general questions regarding the privacy of your personal data, You can contact our customer support at