GDPR Rights and Data Protection

Last Updated: January 1, 2025

As a user of Base Commander, you have specific rights under the General Data Protection Regulation (GDPR) if you are located in the European Economic Area. This page explains your rights and how to exercise them.

1. Data Controller Information

Data Controller: TelesphorosGame
Website: telesphorosgame.com
Address: 152 Stratford Avenue, Amsterdam, Netherlands
Contact Email: support@telesphorosgame.com

2. Your GDPR Rights

2.1 Right of Access (Article 15)

You have the right to know whether we process your personal data and to access that data. You can request:

  • Confirmation of whether we process your personal data
  • A copy of your personal data we hold
  • Information about how we use your data
  • Details about data retention periods
  • Information about data sharing with third parties

2.2 Right to Rectification (Article 16)

You can request correction of inaccurate or incomplete personal data. We will update your information promptly and notify any third parties who received the incorrect data.

2.3 Right to Erasure (Article 17)

Also known as the "right to be forgotten," you can request deletion of your personal data when:

  • The data is no longer necessary for its original purpose
  • You withdraw consent and there's no other legal basis
  • You object to processing and there are no overriding legitimate grounds
  • Your data has been unlawfully processed
  • Deletion is required for compliance with legal obligations

2.4 Right to Restriction of Processing (Article 18)

You can request that we limit how we process your data in certain situations:

  • While we verify the accuracy of disputed data
  • When processing is unlawful but you prefer restriction over deletion
  • When we no longer need the data but you need it for legal claims
  • While we determine whether our legitimate interests override your objection

2.5 Right to Data Portability (Article 20)

You can receive your personal data in a structured, machine-readable format and transfer it to another service provider when:

  • Processing is based on consent or contract
  • Processing is carried out by automated means

2.6 Right to Object (Article 21)

You can object to processing of your personal data based on:

  • Legitimate interests (including profiling)
  • Direct marketing purposes
  • Scientific, historical research, or statistical purposes

2.7 Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to decisions based solely on automated processing that produce legal or significant effects. You can request human intervention in such decisions.

3. How to Exercise Your Rights

3.1 Submitting Requests

To exercise any of your GDPR rights, contact us through:

3.2 Identity Verification

To protect your privacy, we may need to verify your identity before processing requests. We may ask for additional information to confirm you are the data subject.

3.3 Response Timeline

We will respond to your request within one month of receipt. In complex cases, we may extend this period by two additional months and will inform you of any delay.

3.4 Free of Charge

We will handle your requests free of charge unless they are manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable fee.

4. Cookie Management

4.1 Cookie Preferences

You can manage your cookie preferences through:

  • Our cookie consent banner when you first visit
  • Your browser settings
  • Third-party opt-out tools

4.2 Types of Cookies

We use different types of cookies:

  • Essential Cookies: Required for basic functionality (cannot be disabled)
  • Analytics Cookies: Help us understand site usage
  • Marketing Cookies: Used for advertising and personalization
  • Functional Cookies: Remember your preferences and settings

4.3 Withdrawing Cookie Consent

You can withdraw cookie consent at any time by:

  • Clearing your browser cookies
  • Contacting us to reset your preferences
  • Using browser privacy settings

5. Data Processing Lawful Basis

We process your personal data based on the following legal grounds:

  • Consent: For marketing communications and optional features
  • Contract: To provide Base Commander game services
  • Legitimate Interest: For analytics, security, and service improvement
  • Legal Obligation: To comply with applicable laws and regulations

6. Data Retention

We retain personal data for different periods based on the type of information:

  • Account Data: Until account deletion or 3 years of inactivity
  • Game Progress: 3 years after last game session
  • Support Communications: 5 years for service quality purposes
  • Marketing Data: Until consent is withdrawn
  • Analytics Data: Aggregated data retained indefinitely

7. International Data Transfers

When we transfer your data outside the EEA, we ensure adequate protection through:

  • European Commission adequacy decisions
  • Standard Contractual Clauses (SCCs)
  • Binding Corporate Rules
  • Certification schemes

8. Data Breach Notification

In case of a data breach that poses a high risk to your rights and freedoms, we will notify you within 72 hours of becoming aware of the breach, including:

  • Nature of the breach
  • Categories and number of affected individuals
  • Likely consequences
  • Measures taken or proposed to address the breach

9. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe your GDPR rights have been violated. For the Netherlands:

Autoriteit Persoonsgegevens (AP)
Website: autoriteitpersoonsgegevens.nl
Email: info@autoriteitpersoonsgegevens.nl
Phone: +31 70 888 8500

10. Children's Data Protection

Base Commander is designed for users aged 13 and above. For children under 16 in the EU, parental consent may be required for data processing. We:

  • Do not knowingly collect data from children under 13
  • Verify parental consent when required
  • Provide additional protections for minors' data
  • Allow parents to access and delete their child's data

11. Automated Decision-Making

We may use automated systems for:

  • Game difficulty adjustment
  • Content personalization
  • Fraud detection
  • Customer support routing

You can request human review of automated decisions that significantly affect you.

12. Data Protection by Design

We implement privacy protection measures including:

  • Data minimization principles
  • Privacy-friendly default settings
  • Regular privacy impact assessments
  • Staff training on data protection
  • Technical and organizational security measures

13. Contact Information

For any GDPR-related questions or to exercise your rights:

14. Updates to This Information

We may update this GDPR information to reflect changes in law or our practices. We will notify you of significant updates through:

  • Email notifications to registered users
  • Website announcements
  • In-game notifications

This GDPR rights information is effective as of January 1, 2025, and helps ensure your data protection rights are respected when using Base Commander.