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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Fri Aug 22, 2003 10:08 pm    Post subject:  Privacy Policy Reply with quote

Project Perfect Mod Privacy Policy
VERSION 0.5, LAST UPDATED: MAY 29TH, 2018

In this Privacy Policy, we describe the type of data, including personal data (collectively, "data"), that we and our associated companies collect from you when you use Project Perfect Mod Websites, software and services as described in this Privacy Policy, how we use and disclose that data, and your options to access or update your data.

This Privacy Policy may be amended from time to time. The data controllers are the Project Perfect Mod Administrators. They are responsible for compliance with data protection legislation and for exercising of rights of data subjects and providing information about data processing.


About Project Perfect Mod

Project Perfect Mod (PPM) is a voluntary association that is not-for-profit. Its community strives to help the development of user created content for games. This content can be an indie game, modifications of well known games, maps for games, user creation tools, among many other kind of projects. This community does not consist of a legal entity with a physical headquarters. It is run by natural persons and its economical activities exists solely for its own survival, since server maintenance and website domains do have financial costs. Project Perfect Mod does not do any kind of profiling activity and it does not verify the accuracy of the personal data that is voluntarily provided by its registered members, except for a valid email account at the moment the visitor creates a Project Perfect Mod account.


Definitions

The following definitions are used throughout this Privacy Policy:

Project Perfect Mod Website. Any website that is the property of Project Perfect Mod, including but not limited to everything hosted under the following domains or subdomains: ppmsite.com, ppmforums.com, svn.ppmsite.com.
Project Perfect Mod Forums. Everything hosted under the ppmforums.com domain.
Project Perfect Mod Downloadable Software. Any Software Product produced by Project Perfect Mod administrators, that can be downloaded and installed on a device.
Project Perfect Mod Account. An account you create at the Project Perfect Mod Forums and which contains your email and username. It is accessed via a username and password and can be used to manage your Personal Data that you may voluntary provide. Nobody expects the Personal Data of any Project Perfect Mod Account to be accurate at all and its accuracy will not be checked by the data controller.
Project Perfect Mod Non-Registered Visitors are all visitors who browse PPM Website without being identified by a Project Perfect Mod Account. Therefore, they are not logged in on Project Perfect Mod Forums.
Project Perfect Mod Registered Visitors are all visitors who browse PPM Website being identified by a Project Perfect Mod Account. Therefore, they are logged in on Project Perfect Mod Forums.
Project Perfect Mod Terms of Use means this privacy policy.
Personal Data means any data relating to an identified or identifiable natural person. It includes email address, IP (according to the EU regulation), password and forum posts.

Why We Collect Data and What We Collect

We collect data for various reasons, such as:

a) To provide you with services and information. We may collect data which are required to provide you with the content of the Project Perfect Mod Website. Our cookies temporarily stores the IDs of the forum topics that were visited in the current session, time of the last visit and IP. For Project Perfect Mod Registered Visitors, our database may also collect the data you voluntarily provide at the moment you sign up with a new account in the forums or change your profile data, your posts and private posts in the forum, your request to be notified by replies into topics or your participation of the surveys. Some Project Perfect Mod Downloadable Software may also access our servers for checking for updates when requested by the user or in the first install, to download the required files. We may use third-party service providers, acting as data processors, to assist us in provisioning additional content to you or in our operations, such as videos from YouTube or 3D models from Sketchfab. In this case, these and any other third-party service providers may act as separate data controllers, who provide products and services complementary to our services. Further data processing performed by these service providers is governed by their privacy policies. The legal basis for this data processing is performance of contract between you and us.

b) To protect us from unlawful use of our server or services. We may collect data which are required to protect us from any unlawful, unauthorized use of our services, or which are necessary to ensure security of our services, including both data provided by you (see above) and data collected in the course of use of the Project Perfect Mod Website. We may use third-party service providers, acting as data processors, to assist us in preventing the third party software to post unauthorized advertisement on our forums, prevent the creation of PPM Accounts by bots and to prevent non-humans from downloading huge files from our servers. Currently, we are using Google ReCaptcha, which may use cookies and collect data from Project Perfect Mod Non-Registered Visitors to ensure that the visitor is a human being according to their privacy policy. The legal basis for this data processing is Project Perfect Mod's legitimate interest in protection from unlawful and insecure use of Project Perfect Mod services.

c) For internal use of analytics and statistics about the usage of Project Perfect Mod Website. We may collect data based on your use of Project Perfect Mod Website and services, and we do not associate these data with your name. We use these data to better understand usage patterns of our services and behavior of our collective audience. The legal basis for this data processing is our legitimate interest in improving our services.

Categories of data involved in data processing include:

-- usernames,
-- email address,
-- password,
-- cookies,
-- IP address,
-- whatever information displayed on user profiles and posts.

By using this site, you give us your consent to process your IP and cookies (as long as you do not block ppmsite.com or ppmforums.com cookies on your browser. You also give consent to Google and its associated companies to process your IP address and cookies for their youtube.com service, pagead2.googlesyndication.com, googleads.g.doubleclick.net, cdn3.doubleverify.com, as well as services from Google Analytics and Sketchfab. If you block these cookies on your browser, your browsing experience on Project Perfect Mod may not work correctly, since these services were not designed to run without this information. By registering a Project Perfect Mod Account, you give us your consent to process your username, email address, password and every information that you voluntarily provide to your profile until the moment you request the account to be deleted. By posting on the forums, you also give us your consent to process the posts that you create. You can manage your data and opt-outs as described in the Transparency section below.

Usage Terms of User Submitted Content

By submitting any kind of content to Project Perfect Mod Website, you must be either the original author of the content or be authorized to submit it by its creator. The responsibility of proving the authorship of the submitted content (or the consent of the original author to distribute it) is solely from the person who submits it. We may interfere if we are informed of any violations to this rule by warning or even banning the user account related to whoever submitted it and removing the violating content. All publicly submitted material might be downloaded by every visitor and modified, as long as credits are given to the original authors, unless otherwise stated by the author itself or in the license attached into it.

Children

Consistent with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requesting parental consent.

Transparency

To respect your privacy, before usage of your personal data, we will inform you about the categories of data we collect and the purposes we use it for. We will also inform you about the data management options that you may have. This information will be presented in Terms of Use or Privacy Policy documents at the Project Perfect Mod Website or the Project Perfect Mod Downloadable Software, if applicable. Should you wish to access and manage your data, you can do so by checking the following cookies: ppmsite.com, ppmforums.com as well as any other cookie mentioned earlier. Project Perfect Mod Registered Visitors may manage their data here, which allows the user to update and manage its personal data and also provide us with an opt-out of certain personal data collection. Visitors may also use the search feature to find all posts created by their own Project Perfect Mod Account and edit them as long as they do not constitute unlawful use of our services and that they do not violate the forum rules. If the topics of your posts are locked, you may need to request a forum moderator or administrator to edit it.

Sharing

Project Perfect Mod uses the above-described information to tailor our content to suit your needs and help our advertisers better understand our audience's demographics. This is essential to keeping our service free. We will not share information about individual users with any third party, except to comply with applicable law or valid legal process or to protect the personal safety of our users or the public.

Security

To secure your personal data, our services are designed with security and privacy in mind.

We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by SSL encryption.

We review the processes of personal data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your personal data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your personal data in the datasets.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

Location of Your Information

The server that contain personal data are located within the EU (Frankfurt, Germany). The current data processor is Leaseweb.com, which provides a service for Revora Creative Network.

Data retention, withdrawal of approval, access to data and your rights

We may retain your data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of this Privacy Policy. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes. These backups will not be accessible as separately delineated information. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

If at any time you choose to cease using your Project Perfect Mod Account, you may ask for your data to be removed from our servers by sending a request to or via your Project Perfect Mod Account. We may comply with it as long as your account is not banned or suspended due to misuse or unlawful use of our services. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

You may manage your Personal Data in your Project Perfect Mod Account, including providing us with an opt-out for certain kinds of data collection. You are responsible for the correctness of the Personal Data you provide to us, if you really care about it.

As permitted by applicable law, EU residents may request a copy of the information that we hold about them as long as their Project Perfect Mod Account is not banned or suspended. To do so, please contact . We may take up to 30 days to comply with this request.

Moreover, as set out in locally applicable personal data protection law, if you have a non-banned and non-suspended Project Perfect Mod Account, you may have the right to: (i) request access to your personal data; (ii) request erasure of your personal data; (iii) request a restriction on the processing of your personal data; (iv) request personal data portability; or (v) object to the processing of your personal data.

-- Right of access. You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing.
-- Right to erasure (right to be forgotten). You may have the right to require us to delete your personal data as long as your Project Perfect Mod Account is not banned or suspended and  such personal data (mostly posts) do not violate the rules of the community and does not constitute of an unlawful use of our services. Note that, when your Project Perfect Mod Account gets deleted, its posts will not be deleted. They will be assigned to non-identified guests instead, for historical and research purposes. If is there any personal data that you consider to be critical, edit it or delete it before requesting us to be forgotten.
-- Right to a restriction on processing. EU users may have the right to require us to restrict the processing of your personal data under circumstances applicable by EU General Data Protection Regulation. In this case, the respective personal data will be marked and may only be processed by us for purposes that may not violate your restrictions.
-- Right to personal data portability. Under circumstances applicable by EU General Data Protection Regulation, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these personal data to another entity.
-- Right to object. Under circumstances applicable by EU General Data Protection Regulation, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

These rights can be exercised via the email address .
You may also contact Project Perfect Mod to get up-to-date information about your personal data processing and any personal data recipients.

Changes to this Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on Project Perfect Mod Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with an advance notice of such change by posting a reply highlighting the change on Project Perfect Mod Forums.

Reaching out

If you have any questions or concerns, or you feel that this Privacy Policy has been violated in any way, please let us know immediately by contacting .

Key Words: #ProjectPerfectMod #PPMForums #PrivacyPolicy 

Last edited by Banshee on Wed May 30, 2018 12:05 am; edited 24 times in total

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Fremen5
Commander


Joined: 10 Aug 2003
Location: Laughing at Donald Trump in a rather flat place

PostPosted: Thu Aug 28, 2003 9:06 pm    Post subject: Reply with quote

good set of rules, I like them
_________________
Tiberian Station
Image guy on the Dune Sun\
- Peace - Through - Wossname -

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Tue Feb 10, 2015 6:39 am    Post subject: Reply with quote

The text above has been updated with some grammar/spelling fixes and it also mentions Google Ads in the 3rd policy, which is something beyond our control.

The last rule was altered to allow me to post updates as replies in this topic. I don't think anyone will mind that change #Tongue.

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xanax
Vehicle Drone


Joined: 14 Nov 2013

PostPosted: Mon Dec 21, 2015 10:33 pm    Post subject: Reply with quote

I think the 2nd paragraph should clearly mention the use of the http://creativecommons.org/licenses/by-nc-sa/4.0/ license.
Of course, unless otherwise stated by the uploader.

... Just to make things even more clear, on a legal level.  Smile

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Tue Dec 22, 2015 12:43 am    Post subject: Reply with quote

No, I shouldn't. It's up to the user to determine its license. If the user does not determine the license, the terms stated above are more liberal than creative commons 4.0. I.e.: it does not prevent anyone from using these assets in commercial products as long as credits are given.

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xanax
Vehicle Drone


Joined: 14 Nov 2013

PostPosted: Tue Dec 22, 2015 6:29 am    Post subject: Reply with quote

Bah, I guess I should have also added http://creativecommons.org/licenses/by-sa/4.0/ when I typed my previous comment. This Creative Commons license is even more permissive (than the other I linked) since it allows commercial producs.

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Bittah Commander
Defense Minister


Joined: 21 May 2003
Location: The Netherlands

PostPosted: Tue Dec 22, 2015 12:29 pm    Post subject: Reply with quote

While this would cover public assets, the same license wouldn't suit most mods that were uploaded here, considering their assets can only be used with the mod creator's permission.
Most mod creators also won't want to allow others to create modifications of their mod ("mod mods") and when they do, it's going to be under certain conditions (such as that the "mod mod" can't be stand-alone).
_________________

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Tue Dec 22, 2015 2:08 pm    Post subject: Reply with quote

The other problem that I've implicitly mentioned in my reply above and I'll make it more explicit here, is that this kind of license enforces that those who use these assets also use this same license. As I said above, it is up to the user to determine the license.

Quote:
ShareAlike — If you remix, transform, or build upon the material, you must distribute your contributions under the same license as the original.

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xanax
Vehicle Drone


Joined: 14 Nov 2013

PostPosted: Tue Dec 22, 2015 2:46 pm    Post subject: Reply with quote

Alright. You made good points, guys Smile

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Thu May 24, 2018 9:44 pm    Post subject: Reply with quote

This is our previous Privacy Policy which was actually the target of the comments above:

Banshee wrote:
Here's our privacy policy:

1) PPM is no business.

- PPM is made for the fun of visitors and members. This means that we don't have any commercial objectives and we do not seek your money. We do not collect/sell/care about/distribute/ any kind of private information about you. You are not obligated to put any kind of true information about you and anything personal.

2) (File/documents/data/any sort of material) (uploaded/distributed/posted) by fans is from the one(s) who made it.

- Any files that you create and/or post here is from the person (or group) who created it, including files uploaded in tutorials, maps, 3d models, files submitted to mod projects, etc... By submitting a file here, you allow everyone to download it (unless otherwise stated by yourself) and modify it as long as the original creator is credited (also, unless the original author states another rule for the file he submits). Also, by submitting the file here, you must make sure that you have authorization by the creator of the file to distribute it/ see it/expose it to everyone.

3) We don't put any harmful cookies.

- Our site uses the cookies from phpBB forums. The information on this cookie is used exclusively by phpBB forums used in PPM. Nothing else will use this info unless someone hacks into your computer or some malicious site use some bug from your navigator to view it. The information contained in your cookies will NEVER be seen by any other visitor, member or site administrator. However, some places may contain advertisements from Google, who is responsible for their own cookies (they are beyond our control).

4) Forum passwords are top secret to everyone, members, guests, visitors and site administrators.

- No one can see your password, even if you hack into our MySQL, because it's encrypted and neither the forums knows how to decrypt it. So, do not reveal it to anyone if you want no one to use it.

5) IPs, hostnames are not of our business if you don't do anything wrong.

- We will not distribute your IP, hostname or any other online data around if you do not try to hack us or any network near us (currently: Revora, TiberiumWeb, etc...) . This kind of data is used only to detect the person who hacked and how to avoid it happening again.

6) If the rules above change, we will post the change in the announcements forum or in a reply here.



If you have any comments, ideas, suggestions on how to improve it, feel free to post comments about it.

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Fri May 25, 2018 7:28 am    Post subject: Reply with quote

Update: Version 0.41 just makes the text more clear for the end user. The essence behind all the sections doesn't change.

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G-E
General


Joined: 09 Feb 2015

PostPosted: Fri May 25, 2018 2:13 pm    Post subject: Reply with quote

You might also want to add that you will not remove generic information merely on request if that information is useful to the wider community. This would include your modified news posts or some other research that has valid information outside of the scope of personal information.

Basically you want to give yourself the ability to sanitize any posts  to comply with any right-to-be-forgotten, without necessarily removing the posts. In this way you preserve both the community interest and the privacy.
_________________
http://www.moddb.com/mods/scorched-earth-ra2-mod-with-smart-ai

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Fri May 25, 2018 7:54 pm    Post subject: Reply with quote

Yea, I'd really want it. However, I do not understand how GDPR's exceptions deals with it and there would be an inconsistence with the Usage Terms of User Submitted Content (since we would loose the consent to store this user submitted content).

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679

Quote:
Article 17

Right to erasure (‘right to be forgotten’)

1.   The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;

(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);

(d) the personal data have been unlawfully processed;

(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2.   Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3.   Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(e) for the establishment, exercise or defence of legal claims.



Quote:
Article 89

Safeguards and derogations relating to processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes

1.   Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, shall be subject to appropriate safeguards, in accordance with this Regulation, for the rights and freedoms of the data subject. Those safeguards shall ensure that technical and organisational measures are in place in particular in order to ensure respect for the principle of data minimisation. Those measures may include pseudonymisation provided that those purposes can be fulfilled in that manner. Where those purposes can be fulfilled by further processing which does not permit or no longer permits the identification of data subjects, those purposes shall be fulfilled in that manner.

2.   Where personal data are processed for scientific or historical research purposes or statistical purposes, Union or Member State law may provide for derogations from the rights referred to in Articles 15, 16, 18 and 21 subject to the conditions and safeguards referred to in paragraph 1 of this Article in so far as such rights are likely to render impossible or seriously impair the achievement of the specific purposes, and such derogations are necessary for the fulfilment of those purposes.

3.   Where personal data are processed for archiving purposes in the public interest, Union or Member State law may provide for derogations from the rights referred to in Articles 15, 16, 18, 19, 20 and 21 subject to the conditions and safeguards referred to in paragraph 1 of this Article in so far as such rights are likely to render impossible or seriously impair the achievement of the specific purposes, and such derogations are necessary for the fulfilment of those purposes.

4.   Where processing referred to in paragraphs 2 and 3 serves at the same time another purpose, the derogations shall apply only to processing for the purposes referred to in those paragraphs.

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G-E
General


Joined: 09 Feb 2015

PostPosted: Fri May 25, 2018 8:32 pm    Post subject: Reply with quote

The key word is "personal", as long as you are deleting anything that can identify the human you are ok. And even then, as long as their identity is in context, like say I talk about my business as part of an explanation, they will make exceptions for that being "personal" vs "research" purposes.

This part is like any other clause for data storage, like I mentioned the only thing they don't want is _no_ policy, the safeguards are basically up to you: "Those safeguards shall ensure that technical and organisational measures are in place in particular in order to ensure respect for the principle of data minimisation."
_________________
http://www.moddb.com/mods/scorched-earth-ra2-mod-with-smart-ai

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Wed May 30, 2018 12:56 am    Post subject: Reply with quote

Version 0.5 does some relevant changes on the way we deal with your data. For this reason, I am providing a copy of the previous version (0.41), for comparison purposes.

Quote:
Project Perfect Mod Privacy Policy
VERSION 0.41, LAST UPDATED: MAY 25TH, 2018

In this Privacy Policy, we describe the type of data, including personal data (collectively, "data"), that we and our associated companies collect from you when you use Project Perfect Mod Websites, software and services as described in this Privacy Policy, how we use and disclose that data, and your options to access or update your data.

This Privacy Policy may be amended from time to time. The data controllers are the Project Perfect Mod Administrators. They are responsible for compliance with data protection legislation and for exercising of rights of data subjects and providing information about data processing.


About Project Perfect Mod

Project Perfect Mod (PPM) is a voluntary association that is not-for-profit. Its community strives to help the development of user created content for games. This content can be an indie game, modifications of well known games, maps for games, user creation tools, among many other kind of projects. This community does not consist of a legal entity with a physical headquarters. It is run by natural persons and its economical activities exists solely for its own survival, since server maintenance and website domains do have financial costs. Project Perfect Mod does not do any kind of profiling activity and it does not verify the accuracy of the personal data that is voluntarily provided by its registered members, except for a valid email account at the moment the visitor creates a Project Perfect Mod account.


Definitions

The following definitions are used throughout this Privacy Policy:

Project Perfect Mod Website. Any website that is the property of Project Perfect Mod, including but not limited to everything hosted under the following domains or subdomains: ppmsite.com, ppmforums.com, svn.ppmsite.com.
Project Perfect Mod Forums. Everything hosted under the ppmforums.com domain.
Project Perfect Mod Downloadable Software. Any Software Product produced by Project Perfect Mod administrators, that can be downloaded and installed on a device.
Project Perfect Mod Account. An account you create at the Project Perfect Mod Forums and which contains your email and username. It is accessed via a username and password and can be used to manage your Personal Data that you may voluntary provide. Nobody expects the Personal Data of any Project Perfect Mod Account to be accurate at all and its accuracy will not be checked by the data controller.
Project Perfect Mod Terms of Use means this privacy policy.
Personal Data means any data relating to an identified or identifiable natural person. It includes email address, IP (according to the EU regulation), password and forum posts.

Why We Collect Data and What We Collect

We collect data for various reasons, such as:

a) To provide you with services and information. We may collect data which are required to provide you with the content of the Project Perfect Mod Website. Our cookies temporarily stores the IDs of the forum topics that were visited in the current session, time of the last visit and IP. For those who browse Project Perfect Mod Website with a Project Perfect Mod Account, our database may also collect the data you voluntarily provide at the moment you sign up with a new account in the forums or change your profile data, your posts and private posts in the forum, your request to be notified by replies into topics or your participation of the surveys. Some Project Perfect Mod Downloadable Software may also access our servers for checking for updates when requested by the user or in the first install, to download the required files. We may use third-party service providers, acting as data processors, to assist us in provisioning additional content to you or in our operations, such as videos from YouTube or 3D models from Sketchfab. In this case, these and any other third-party service providers may act as separate data controllers, who provide products and services complementary to our services. Further data processing performed by these service providers is governed by their privacy policies. The legal basis for this data processing is performance of contract between you and us.

b) To protect us from unlawful use of our server or services. We may collect data which are required to protect us from any unlawful, unauthorized use of our services, or which are necessary to ensure security of our services, including both data provided by you (see above) and data collected in the course of use of the Project Perfect Mod Website. The legal basis for this data processing is Project Perfect Mod's legitimate interest in protection from unlawful and insecure use of Project Perfect Mod services.

c) For internal use of analytics and statistics about the usage of Project Perfect Mod Website. We may collect data based on your use of Project Perfect Mod Website and services, and we do not associate these data with your name. We use these data to better understand usage patterns of our services and behavior of our collective audience. The legal basis for this data processing is our legitimate interest in improving our services.

Categories of data involved in data processing include:

-- usernames,
-- email address,
-- password,
-- cookies,
-- IP address,
-- whatever information displayed on user profiles and posts.

By using this site, you give us your consent to process your IP and cookies (as long as you do not block ppmsite.com or ppmforums.com cookies on your browser. You also give consent to Google and its associated companies to process your IP address and cookies for their youtube.com service, pagead2.googlesyndication.com, googleads.g.doubleclick.net, cdn3.doubleverify.com, as well as services from Google Analytics and Sketchfab. By registering a Project Perfect Mod Account, you give us your consent to process your username, email address, password and every information that you voluntarily provide to your profile until the moment you request the account to be deleted. By posting on the forums, you also give us your consent to process the posts that you create. You can manage your data and opt-outs as described in the Transparency section below.

Usage Terms of User Submitted Content

By submitting any kind of content to Project Perfect Mod Website, you must be either the original author of the content or be authorized to submit it by its creator. The responsibility of proving the authorship of the submitted content (or the consent of the original author to distribute it) is solely from the person who submits it. We may interfere if we are informed of any violations to this rule by warning or even banning the user account related to whoever submitted it and removing the violating content. All publicly submitted material might be downloaded by every visitor and modified, as long as credits are given to the original authors, unless otherwise stated by the author itself or in the license attached into it.

Children

Consistent with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requesting parental consent.

Transparency

To respect your privacy, before usage of your personal data, we will inform you about the categories of data we collect and the purposes we use it for. We will also inform you about the data management options that you may have. This information will be presented in Terms of Use or Privacy Policy documents at the Project Perfect Mod Website or the Project Perfect Mod Downloadable Software, if applicable. Should you wish to access and manage your data, you can do so by checking the following cookies: ppmsite.com, ppmforums.com as well as any other cookie mentioned earlier. For those who have a Project Perfect Mod Account, you can manage your data here, you can update and manage your data and also provide us with an opt-out of certain personal data collection. You may also use the search feature to find all posts created by your Project Perfect Mod Account and edit them as long as they do not constitute unlawful use of our services and that they do not violate the forum rules. If the topics of your posts are locked, you may need to request a forum moderator or administrator to edit it.

Sharing

Project Perfect Mod uses the above-described information to tailor our content to suit your needs and help our advertisers better understand our audience's demographics. This is essential to keeping our service free. We will not share information about individual users with any third party, except to comply with applicable law or valid legal process or to protect the personal safety of our users or the public.

Security

To secure your personal data, our services are designed with security and privacy in mind.

We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by SSL encryption.

We review the processes of personal data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your personal data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your personal data in the datasets.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

Location of Your Information

The server that contain personal data are located within the EU (Frankfurt, Germany). The current data processor is Leaseweb.com, which provides a service for Revora Creative Network.

Data retention, withdrawal of approval, access to data and your rights

We may retain your data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of this Privacy Policy. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes. These backups will not be accessible as separately delineated information. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

If at any time you choose to cease using your Project Perfect Mod Account, you may ask for your data to be removed from our servers by sending a request to or via your Project Perfect Mod Account. We may comply with it as long as your account is not banned or suspended due to misuse or unlawful use of our services. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

You may manage your Personal Data in your Project Perfect Mod Account, including providing us with an opt-out for certain kinds of data collection. You are responsible for the correctness of the Personal Data you provide to us, if you really care about it.

As permitted by applicable law, EU residents may request a copy of the information that we hold about them as long as their account is not banned or suspended. To do so, please contact . We may take up to 30 days to comply with this request.

Moreover, as set out in locally applicable personal data protection law, you may have the right to: (i) request access to your personal data; (ii) request erasure of your personal data; (iii) request a restriction on the processing of your personal data; (iv) request personal data portability; or (v) object to the processing of your personal data.

-- Right of access. You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing.
-- Right to erasure (right to be forgotten). You may have the right to require us to delete your personal data as long as your Project Perfect Mod Account is not banned or suspended and  such personal data (mostly posts) do not violate the rules of the community and does not constitute of an unlawful use of our services.
-- Right to a restriction on processing. EU users may have the right to require us to restrict the processing of your personal data under circumstances applicable by EU General Data Protection Regulation. In this case, the respective personal data will be marked and may only be processed by us for purposes that may not violate your restrictions.
-- Right to personal data portability. Under circumstances applicable by EU General Data Protection Regulation, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these personal data to another entity.
-- Right to object. Under circumstances applicable by EU General Data Protection Regulation, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

These rights can be exercised via the email address .
You may also contact Project Perfect Mod to get up-to-date information about your personal data processing and any personal data recipients.

Changes to this Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on Project Perfect Mod Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with an advance notice of such change by posting a reply highlighting the change on Project Perfect Mod Forums.

Reaching out

If you have any questions or concerns, or you feel that this Privacy Policy has been violated in any way, please let us know immediately by contacting .

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Wed May 30, 2018 1:09 am    Post subject: Reply with quote

Changes for version 0.5 includes:

- Definitions for Project Perfect Mod Non-Registered Visitors and Project Perfect Mod Registered Visitors.

- In the previous versions we forgot that write that we use ReCaptcha to distinguish humans from bots. We have added that piece of info at "Why We Collect Data and What We Collect" (b).

- "Why We Collect Data and What We Collect" (a) and "Transparency" section has made use of the new definitions.

- Based on GDPR's Article 11, Right of access, Right of Erasure, Right to a restriction on processing, right to personal data portability and right to object requires a Project Perfect Mod Account. For security reasons, this account must not be banned or suspended.

- Right to erasure (right to be forgotten) no longer delete all your posts by default. I'll post a further explanation about that in my next post in this topic in order to call more attention to that.

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Wed May 30, 2018 1:10 am    Post subject: Reply with quote

G-E wrote:
You might also want to add that you will not remove generic information merely on request if that information is useful to the wider community. This would include your modified news posts or some other research that has valid information outside of the scope of personal information.

Basically you want to give yourself the ability to sanitize any posts  to comply with any right-to-be-forgotten, without necessarily removing the posts. In this way you preserve both the community interest and the privacy.


Regarding version 0.5 changes on Right to erasure (right to be forgotten)


First of all, this isn't simply a response to G-E, although it takes in mind his feedback. When you create a post/topic here, your post may receive replies. These replies depends on your post in order to allow users to understand the context which they were posted. Therefore, when we remove posts from one user in a forum, other users may suffer the consequences as well.

For this reason, we need to act more responsibly to preserve the community's interest, without removing your rights regarding the way your personal data is treated here.

The change we've posted in the version 0.5 may work similarly to the way you treat your trash. Once you place something that belongs to you in the trash bin and move the contents of this trash bin to a common area of the building you live at (or straight to the street if you live in a house), you are transferring the ownership of your trash to whoever manages the location you brought your trash into. I.e.: if it is inside your building, then whoever is on the building may now take it for themselves. If you brought your trash into the street, anyone who passes by it make take it. It is no longer yours. This is why it is highly recommended to prune your documents and credit cards when you throw them in the trash can, so you can prevent third party from getting your personal data from these things.

In PPM and many other websites, it works in the same way. If you ask your account to be deleted, it will deleted your account and the author of your posts is changed into 'guest', anonymizing your posts. From another perspective, it means that when you do this procedure, you automatically consent the transfer of the ownership of your posts to PPM. It complies with GDPR, because these posts gets anonymized and whatever happens next to them falls into Article 11. This change does not prevent all your posts from being deleted before your account is deleted. And you can still request us to delete all your posts before deleting your account, but we'd like you to take into consideration that this attitude may harm other users.

It is important to note that, if another user quotes you and your post, we will not alter the post of that user, since it doesn't belong to you. You'll have to get the consent of whoever quoted you before we do that, unless that post violates the forum rules.

Last edited by Banshee on Wed May 30, 2018 5:57 am; edited 2 times in total

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G-E
General


Joined: 09 Feb 2015

PostPosted: Wed May 30, 2018 5:41 am    Post subject: Reply with quote

I'd still move the cookies/ads/analytics sharing stuff to a separate policy document, it's a technical matter and in a very broad sense it is anonymous data as far as they are concerned. The only time where a cookie can become a security issue is if you allow persistent login on a machine not owned by the user, and thus bypassing their credentials or revealing data they may not want to, however that's not something you as the webmaster can control, except by forcing a user to re-enter credentials upon ip address change from previous login.
_________________
http://www.moddb.com/mods/scorched-earth-ra2-mod-with-smart-ai

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Banshee
Supreme Banshee


Joined: 15 Aug 2002
Location: Brazil

PostPosted: Wed May 30, 2018 6:09 am    Post subject: Reply with quote

I don't feel comfortable with that either. However, GDPR seems to be quite strict with it.

Quote:
Article 13

Information to be provided where personal data are collected from the data subject

1.   Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information:

(a) the identity and the contact details of the controller and, where applicable, of the controller's representative;

(b) the contact details of the data protection officer, where applicable;

(c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;

(d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party;

(e) the recipients or categories of recipients of the personal data, if any;

(f) where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.

2.   In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing:

(a) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;

(b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;

(c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

(d) the right to lodge a complaint with a supervisory authority;

(e) whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;

(f) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

3.   Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph 2.

4.   Paragraphs 1, 2 and 3 shall not apply where and insofar as the data subject already has the information.

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