1. Who is responsible for your information

Quartermile Interactive Ltd, Suite 4, Vault Business Centre, 27 Tower Road, Sliema SLM 1601, Malta, is the controller responsible for the personal information collected through dragworldusa.com. Our data protection contact is Miriam Ellul, reachable at privacy@dragworldusa.com, and is accountable for our compliance with this policy.

Because we are established in the European Union, our processing is subject to the EU General Data Protection Regulation (GDPR) and Maltese data protection law. Because we offer the Game to users in Canada, we also apply the Personal Information Protection and Electronic Documents Act (PIPEDA) to information about our Canadian users. Where the two regimes differ, we apply the standard more protective of you.

2. Scope

This policy explains what personal information we collect, why we collect it, what our legal basis is, who we share it with, how long we keep it, and the choices and rights you have. It applies to the website, the game frame embedded in it, and our advertising.

3. What we collect

• Age confirmation: a cookie recording that you confirmed you are 19 or older, stored on your device.
• Cookie choice: a cookie recording whether you allowed optional cookies. See section 8 and the Cookie Policy.
• Technical information: IP address, approximate location derived from it (country and region, not precise location), browser and device type, operating system, language, and referring page.
• Support correspondence: the name, email address, and message you send us through the contact form or by email, and our replies.

We do not operate user accounts, so we do not collect usernames or passwords. We do not collect payment card details, because the Game is free and we do not process payments. Gameplay inside the embedded title is handled by the studio that supplies it and is not reported back to us in a form that identifies you. We do not collect special categories of data, and we do not knowingly collect information from anyone under 19.

4. Why we collect it, and our legal basis

• To remember that you confirmed your age and to keep the site working — our legitimate interest in operating an adults-only service and complying with advertising rules (GDPR Art. 6(1)(f) and (c)).
• To answer your message — our legitimate interest in responding to enquiries, and the performance of any agreement we have with you (Art. 6(1)(f) and (b)).
• To keep the Service secure, prevent abuse and automated access, and investigate breaches of our Terms — our legitimate interest in the security of the Service (Art. 6(1)(f)).
• To understand how the site is used and improve it — your consent for analytics cookies (Art. 6(1)(a)).
• To measure and optimise our advertising, including ads served through Google Ads — your consent (Art. 6(1)(a)).
• To comply with legal obligations and respond to lawful requests — compliance with a legal obligation (Art. 6(1)(c)).

For our Canadian users, the same purposes are supported by your consent under PIPEDA, which may be express or implied depending on the purpose and the sensitivity of the information.

5. Withdrawing consent

Where we rely on consent, you may withdraw it at any time: through the cookie notice on the site for analytics and advertising cookies, by clearing cookies in your browser, or by writing to privacy@dragworldusa.com. Withdrawal does not affect processing carried out before it. The strictly necessary age-confirmation cookie cannot be switched off while you use the site, because the site may not lawfully be shown without it.

6. Who we share it with

We do not sell your personal information. We share it only with processors and partners acting on our behalf or supplying part of the Service, under contract and only for the purposes described above:

• hosting and infrastructure providers;
• the game studio whose title is embedded on the play page, which receives your technical connection data directly when the frame loads;
• analytics providers, to measure use of the site;
• advertising platforms, including Google, to measure and optimise our campaigns;
• email providers, for support correspondence;
• professional advisers, and law enforcement or regulators where required by law.

7. International transfers

We are based in Malta and store information within the European Economic Area where possible. Some of our providers process information in third countries, including the United States. For such transfers we rely on an adequacy decision where one applies, or otherwise on the European Commission’s Standard Contractual Clauses together with additional technical safeguards. Information about users in Canada is therefore processed outside Canada, and while it is in another country it may be accessible to the courts, law enforcement, and national security authorities of that country under its laws. You can ask us at privacy@dragworldusa.com for details of the safeguards in place and where your information is held.

8. Cookies

We use strictly necessary cookies to remember your age confirmation and your cookie choice; the site cannot be shown lawfully without them, and they are set without consent as the law permits. Analytics and advertising cookies are optional and are set only after you allow them through our cookie notice. You can change or withdraw your choice at any time, and you can block or delete cookies in your browser. The full list is in the Cookie Policy.

9. How long we keep it

The age-confirmation cookie expires 30 days after it is set. Support correspondence is kept for 24 months. Technical logs are kept for 12 months. Analytics data is retained in aggregated form for up to 14 months. We keep specific records longer only where we must to comply with a legal obligation or to establish, exercise, or defend a legal claim.

10. How we protect it, and breach notification

We use encryption in transit, access controls limiting staff access to what their role requires, and monitoring for unauthorised access. No system is completely secure. If a personal data breach occurs, we will notify the Information and Data Protection Commissioner in Malta within 72 hours where the breach is likely to result in a risk to your rights, and we will notify you directly where the risk is high. For our Canadian users we will also report to the Office of the Privacy Commissioner of Canada where the breach creates a real risk of significant harm.

11. Your rights

You may ask us to:

• confirm whether we hold personal information about you and give you access to it;
• correct information that is inaccurate or incomplete;
• delete the information associated with your correspondence;
• restrict our processing, or object to processing based on our legitimate interests;
• provide your information in a structured, commonly used, machine-readable format, or transmit it to another controller;
• withdraw your consent where we rely on it.

Write to privacy@dragworldusa.com. We will respond within one month, and within 30 days for requests from Canadian users, and we do not charge a fee for a routine request. We may ask you to verify your identity first. We do not make decisions about you based solely on automated processing that would produce legal effects or similarly significant effects for you.

12. Complaints

If you are not satisfied with our response, you may complain to the Information and Data Protection Commissioner in Malta at idpc.org.mt. If you are in Canada, you may instead complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca, or to the privacy regulator of your province where one exists.

13. Children

The Service is for adults aged 19 and over. We do not knowingly collect information from anyone below that age. If you believe a minor has used the site and sent us information, contact privacy@dragworldusa.com and we will delete it.

14. Changes to this policy

We may update this policy. The current version is always available at dragworldusa.com/privacy with its effective date. Where a change is material we will publish a notice on the site before it takes effect.

15. Contact

Miriam Ellul, Quartermile Interactive Ltd, Suite 4, Vault Business Centre, 27 Tower Road, Sliema SLM 1601, Malta · privacy@dragworldusa.com