Privacy Notice

We at Voidu B.V. (“Voidu”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you purchase digital items and visit www.voidu.com (“Website”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing. 

This Privacy Notice applies whenever you purchase digital items, visit our Website or use any of our other services, all of which together we refer to as “Services”.

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes within our Services. 

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

1. Who is responsible for the processing of your Personal Data

Voidu B.V. Boeing Avenue 30, 1119 PE Schiphol-Rijk, Netherlands is responsible (“the data controller”) for the processing of your Personal Data.

2. What types of Personal Data do we process and how do we collect it?

When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation. The data we use depends on the purpose for which we process the data. We will only use your data for the purposes as described below in the next section and in the Service Specific Information section of this Privacy Notice.

The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:

                      2.1. Personal Data provided by you

When you use our Services, you provide or are asked to give us certain information, including:

• Your account information: On our Website, you have the option to register. If you choose to create an account, we collect your log-in data (your email address, First name, Last name, date of birth, password and and your authentication token generated by Azerion Connect).
  • For registration, we use Azerion Connect which offers a single sign-on platform from where users can obtain the necessary login data for all participating. After registration, the SSO authentications service is available to the participating portals and to users as a single tool for logging in to the various participating specialist portals. 
• Information provided in relation to our customer service: When you contact support by submitting a request, we collect information about your request (subject and content of your request) and attachment (optional) and your email address.
• Information Provided in relation to transaction and payment: When you make a transaction on Voidu (e.g. purchased products or game keys, we collect your address information in order to fulfill our obligations. We do not collect any card data as you will be redirected to an external payment provider for the transaction of your payment, we receive payment confirmation details from our payment provider. In some countries we use external partners to verify the country that your resident via collecting your mobile phone number. For more information please see the service specific information below.
• Date of Birth: Voidu’s services offered are addressed to persons over 16 years of age. In the case of persons who are under the age of 16, the consent of the legal guardian for the processing of the User's personal data is required. Voidu will not knowingly collect and process Personal Data of children under 16.

                      2.2. Personal Data we receive or generate from your use of our Services

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

• Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), device IDs, geolocation data (country based on your IP address), url visited, browser settings, screen resolution and other technical information.
• Cookie data: A "cookie" is a file of information placed on your device when you visit a website. As further described in our Cookie Notice (“Cookie Notice”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice.
• Your usage: We collect information about how you use our Services. This information includes your preferences, such as your interests in certain categories of games, the actions you take, the time and duration of your activity. Based on the products you purchased, you may earn Voidu Cash (it is a digital currency that can be used to purchase PC games at the Voidu store.) Furthermore, we collect information about the websites that led you to our Website.

                      2.3. Personal Data we collect from other third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:

• Social Networks and connected third-party platforms: If you choose to connect our Services with your account at third-party platforms (such as Facebook or Google) by using your credentials with our log-in process, Azerion Connect receives certain information about you from Social Networks such as your public profile, first and last name, your email address, and your authentication token.
  As stated above, our registration partner, Azerion Connect, offers a single sign-on platform from where users can obtain the necessary login data for all participating. After registration, the SSO authentications service is available to the participating portals and to users as a single tool for logging in to the various participating specialist portals. We receive your name, surname, your e-mail address, date of birth and your authentication token generated by Azerion Connect.
• Payment Providers: If you make a purchase, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any complete financial information (such as your full credit card information) but receive non-financial information related to your transaction, for example the payment method, status and date.
• User Acquisition Companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), your country and language, and technical identifiers (Advertisement ID, Device ID) from our user acquisition partners.
• Keyless Activation Partners: If you purchase game keys via Keyless Activation Partners, we receive your User ID.
• Other third parties: We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or security purposes.

To learn more about which data is processed, please see the section with service specific information below.

3. Do we collect data from minors?

The Services are not targeted towards, nor intended for use by anyone under the age of 16. Our terms of use prohibit users aged under 16 years from accessing Voidu. In the event that we learn that we have collected personal data from a user under 16 years of age, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team at Voidu.

4. For What Purpose we process your data?

Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

Provision and improvement of our Services

• to allow you to use our Services
• to notify you about changes in our Services
• to create and manage your account
• to restore your account if you ever lose access
• to communicate with you in context of account activation, password management
• to simplify the registration process
• to provide technical support and respond to your requests
• to provide payment processing services
• to provide product delivery services
• to identify and correct any bugs/errors
• to indicate the popularity of our Services
• to assess the quality of our Services
• to understand and improve your online experience
• to aggregate financial reports to pay our business partners
• to pay our business partners for the promotion of our Services

Personalization of your user experience

• to remind you of products in your basket
• to recommend games and products you may like based on your purchases
• to personalize advertising for you
• to remember you next time you visit our Services

Marketing and analytics

• to deliver (targeted and non-targeted) advertising
• to pay our business partners for the promotion of our Services
• to measure the effectiveness of advertising
• to send you marketing communications, informing your about new content and in-game offers
• to acquire new users on social media platforms

Prevention of fraud and illegal activity

• to investigate fraud and deal with fraud.
• to ensure security of our Website
• to enforce our policies and terms of use

Compliance with our legal or regulatory obligations

• to determine the legal requirements for processing of your Personal Data (based on your location such as your country)
• to maintain records related to purchases
• to respond to your requests related to your data subject rights
• to comply with our legal obligations (e.g. tax and accounting obligations)
• to inform you about any changes to this Privacy Notice

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. Do we engage in profiling activities?

If you consent to this via the cookie consent pop-up (by turning on targeting cookies), We use tracking mechanisms to track your Personal Data for profiling purposes. This allows us to serve relevant content to you and adjust our services and ads to your interests. You have the right to object to this type of processing. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.

6. On Which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

• Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in context of sending newsletters, personalized advertising, analytics, profiling. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent. 
• Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are party, for example, in context of customer service, where it is necessary for the creation and administration of your account, to support the operation of our Services or to facilitate the delivery of requested Services.
• Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age, for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities.
• Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience and we transfer your personal data across all our group companies for administrative transfers as well as to identify/determine the size of the user base of our Services. We may also disclose your Personal Data to legal authorities for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Services. We kindly remind you that you have the right to object to processing.

Please see for additional information the section with service specific information below.

7. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the development team and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

• External service providers: We share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services, web/social analytics services, video hosting service. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
• Payment providers: If you make website payments, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment providers’ privacy policies.
• Connected third-party platforms: We have included buttons and pixels from third party platforms on our website to enable users to integrate with their social media profiles as and when they see fit to do so. Such parties may capture some of your personal data that way. These parties are controllers of the data for their own purposes. Learn more about our marketing activities in the service specific section below.
• User acquisition companies: We provide advertisements for our Services to user acquisition companies which show these advertisements on their websites or in their networks. If you click on advertisements shown to you on a third-party website or in a third-party network, you will be redirected to our Website where you can use our Services. The information about the usage of our Service, your country and language, the campaign ID, your user ID, and post acquisition events (such as your purchases and account creation), will be shared with the user acquisition company.
• Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
• Azerion affiliates and subsidiaries: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
• Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with by clicking on the following link: Voidu Third Party Partners List

8. Where will my Personal Data be processed?

In general, If you are accessing our Website from the European Union (EU) / the European Economic Area (EEA) then your data is stored on servers within the European Union (EU) / the European Economic Area (EEA). However, your data may also be shared with outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

9. How do we protect your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

10. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. Please see below for information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

11. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
• Request the update or correction of your Personal Data so that it is always accurate.
• Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
• Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
• Restrict the processing of your Personal Data, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
• Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.

Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support at support@voidu.com or our via e-mail to dpo@azerion.com.

How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.

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Version	Last Updated
1.0	Friday, 9 September 2022

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Additional Information for California Residents

This section for California residents supplements the information provided in this Notice and applies solely to visitors, users, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D – Commercial information (such as purchase history)

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to opt out of any sale of your personal data by us to third parties. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting and content delivery

Voidu is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Creation/administration of your account

In our Website, you have an option to create an account. We store your log-in data (your username, email address, date of birth and password, account ID, account creation technical details (e.g. time of account creation) ) to allow you to log in on different devices, based on the performance of a contract.

If you choose to register using your third party platform account (e.g. Facebook or Google) account, or enter our Website from a third-party platform (e.g. Facebook or Google), we receive certain information about you from the respective third-party provider like e.g. your name, your profile picture, your email address, and the authorization token. This information will be stored in your Azerion Connect account.

Your account data will be stored for as long as your account exists, based on the performance of a contract. You can delete your Voidu account at any time, for example by submitting a deletion request to our support team using the contact feature within the Website, or through Privacy section in your Azerion Connect account page and click delete account button or by contacting our Data Protection Officer through sending an email to dpo@azerion.com. Voidu may retain your account data after a deletion request due to legal or regulatory requirements or for the reasons stated in this Privacy Notice.

Age gating

When you create an Voidu account, we will ask you to fill in your age. Only if you indicate being at least 16 years of age, you will able to proceed with your registration. We use your age data to ensure that only users of at least 16 years of age create an Voidu account and that no personal data belonging to minors is processed except for those data that is strictly necessary to make the website work. This data is not shared with other parties. Only the information whether you are at least 16 years of age will be processed based on our legitimate interest.

Login

Our Website transmits the data you have provided in your registration form (normally your email address and password) and a service URL to the authentication server. The authentication server then uses these data to verify the login request. If the login request is accepted on that basis, the user ID assigned to you will be transmitted to the server of Voidu. We process this data on the basis of performance of contract.

Azerion Connect:

We use Azerion Connect services, which offers a single platform from where users can obtain the necessary login data for all participating portals, to provide our registration services. After registration, the SSO authentications service is available to the participating portals and to users as a single tool for logging in to the various participating specialist portals. In order to create an account through Azerion Connect you will be directed to the Voidu account creation page and after you filled out required information following data to be transmitted to us and/or retrieved by us: email address, name, surname, date of birth and authentication token.

Customer service:

If you contact us for customer support, an external customer service company will process your email address, subject and/or your attachments (optional), and the content of your request. In order to provide you with support, this information will be processed together with your device information (model, OS, Browser language,), the user ID, The request history is stored for your account’s lifetime to enable handling of newer requests based on your previous request and to improve our services.

We process this data on the basis of the performance of a contract as far as the information is required to answer your request. The continued storage of your request history is based on our legitimate interest, in order to improve our services.

Payments (billing and invoicing):

If you make a payment transaction, you will be redirected to an external payment provider for the transaction of your payment.

The transactions will be processed by the third-party payment provider. While we do not collect and do not receive any financial data (such as your bank account data), we collect or may receive from third-party payment providers the following information related to your transaction: the purchased amount and item, the price and currency, your country, your IP address, device information (user agent), time stamp, url visited, payment method, expiration date and last four digits of your credit card (credit card purchases only), payment/transaction id, and the status of your payment.

• For SMS verification we may receive your phone number.
• For PayPal purchases we may receive your PayPal account info: name, email address and PayPal ID. 
• For Credit Card purchases we may receive the type, holder name, first six and last four digits and expiry date of the card. 

We store this information for at least 7 years or your account’s lifetime in the event that your account continues to exist after the expiration of 7 years.

We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your purchase.

Voidu Cash

We process the amount of money that you spend on purchase transactions for our Loyalty program where Voidu Member receives loyalty points to spend and discount further purchases based on performance of contract.

Newsletter Marketing

We process your email address to deliver advertisement content to Voidu Member's emails based on your consent.

Analytics

We use analytics services to understand which features you like in our Services following changes to the website. For this purpose, we process information about your device, request data (including the URL of the current webpage and the website visited before) and special event data (for example if you purchase gamekeys). We also process your full IP address to allow us to better understand how you use our Services and to improve our websites.

By activating IP anonymisation on Voidu , the IP address is shortened prior to transmission within the EEA or in other states party to the Agreement on the EEA.

We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access Voidu for the first time.

Marketing and User Acquisition

We provide advertisements for our Services to user acquisition companies which show these advertisements on their websites or in their networks. If you click on advertisements shown to you on a third-party website or in a third-party network, you will be redirected to our Website where you can use our Services. The information about the usage of our Service, your country and language, the campaign ID, your user ID, and post acquisition events (such as your purchases and account creation), will be shared with the user acquisition company. We will process this personal data based on consent.

Game Key Distributors

We have agreements with various Game Key Distributors (retailers) and game owners to purchase game keys or to provide keyless solutions to users. Our Website enables us to communicate with such partners through API calls. Once you purchase a game key from a our Website, we share the below mentioned personal data with our Partners:

• Full Name
• E-mail Address
• Billing Address
• IP Address
• Order Data (Order Total, Discount Amount, Coupon Code, Tax Ratio, Revenue)
• Product name
• Detected Country Code
• User ID of related Publisher (for instant activation, exp. Epic User ID)

We process this data based on performance of the contract in order to provide you services.

Voidu Browser Extension

We offer the use of Google Chrome and Firefox browser extensions that show users when a game you are viewing is available or even on sale in Voidu. If you add extension and provide your permission to the browser that your using, This extension process data on your browser. Our extension only collects your website content for example text, images, sounds, videos or hyperlinks to show you whether the game your viewing is available or even on sale in Voidu.

Third parties: If you click here, you will see an overview of the third parties we may share your Personal Data with, or that may share your Personal Data with us.