Legal Note and Privacy

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PRIVACY AND DATA PROCESSING POLICY ISSUED BY MILESTONE S.r.L.

Last update: 20 February 2025

  1. INTRODUCTION AND GENERAL CONDITIONS

These conditions apply to the use of games and other products developed by Milestone S.r.L. (“Milestone”/”Us”), with head offices in Via Olona 2, 20123 Milan, Italy. Our company is registered in Italy, with VAT number IT10851750967.

This privacy and data processing policy (“Privacy Policy”) applies to and has effect to all games, their respective online services, and other software and products supplied by Milestone (collectively referred to as the “Game/Games”).

For any queries or comments regarding this Privacy Policy, users can contact us via the Game’s assistance page at the following link: https://milestone.it/contact/ (“Support Services”).

Milestone undertakes to protect and safeguard the privacy of its users. The Privacy Policy sets out the basis for processing personal information gathered from users. Given that it is our company that decides the means or purpose adopted for processing personal data supplied by users through these online services, we are the “Data Controllers”. All applicable data protection laws will be respected, including the European General Data Protection Regulation (GDPR) 2016/679.

Please read this Privacy Policy carefully, as it contains important information about the following issues:

  • What information we can gather from users;
  • How we gather user information;
  • Legal basis;
  • How the gathered information will be used;
  • Whether user data will be transferred to third parties;
  • Where we store user information;
  • How long we keep user information;
  • How we protect user information;
  • Minors;
  • International data transfer
  • The choices and Rights of users regarding any personal information provided.

This privacy policy is a part of, and must be read in conjunction with, our terms of use, which can be consulted at this link: https://milestone.it/it/eula/.

By accessing a Game, users confirm that they have read this Privacy Policy and that they authorise us to gather, store, access, transfer and use their data as described in this privacy policy.

This document may be altered at a future time, in which case any changes made will be published on this page. We recommend consulting this page at periodic intervals, in order to keep up-to-date with any changes. Where appropriate, we may notify you of any such changes via e-mail or through the Games themselves.

  1. TYPES OF DATA GATHERED

We gather and process the following types of information, which might include the personal data of users:

Information provided by users while using the Game or online Service (“Information transmitted”)

We may ask users to provide, or the users may send personal and non-personal information and data via the online Service when contacting Milestone or sending contents generated by the users of the online Service. Within the context of the Game, Milestone shall not, however, ask the users to transmit/send any information and/or personal data, and shall not record and store any personal information/data exchanged between users.

As regards the Online Services, the following might be included:

  • e-mail address and/or Name and Surname (where access is made via the customer support service);

As regards the Games, the following may be gathered:

  • username and account of users in relation to the platform the Game is being used on (such as the Online ID for PlayStation®).

Information on social media: we have pages on social media channels such as Twitter, YouTube and LinkedIn. When you interact with our social media pages, we gather the personal information you choose to provide us, such as your contact details (collectively referred to as “Social Information”). The companies that host our pages on social media may also provide us with aggregate information and analyses about our activities on social media.

Further data gathered when the user makes use of our Services (“Technical Information”)
we may gather technical information about how the Game and/or online Service is utilised by users.

By way of example, data that may be gathered include:

Log Data: information the browser automatically sends whenever our Website is used (“log data”). Recorded data include the Internet protocol address, the type and settings of the browser, the date and time of the request, and how you interacted with our Website.

Usage data: we may automatically gather information about how you use the Services, such as the type of game content you see or interact with, the functions you use and the actions you take, as well as the time zone, country, dates and times of access, user agent and version, type of computer or mobile device, connection to the computer, IP address and suchlike.

Device Information: includes the name of the device, the operating system and the browser being used. The information gathered may depend on the type of device used, and on its settings.

Cookies: we use cookies for managing our Services and associated administration purposes, and for enhancing your user experience. A “cookie” is information sent to your browser by a website which you visit. You can set your browser to accept all cookies, refuse all cookies or notify whenever a cookie is offered, so you can decide on an as-and-when basis whether to accept them or not. Rejecting a cookie may, however, prevent you from using a website under certain circumstances. Alternatively, it may have a negative bearing on how the site is displayed, or how given areas or functions of a website function. For more details about cookies, please read our Web Cookie Policy.

Analytics: we may use online analysis products that harness cookies to help us understand how users make use of our Services, and to enhance your experience when you use the Services. When installing, uninstalling or updating the Game, users may send a unique application number and information about the installation including, by way of example, the type of operating system used.

We use the following third-party suppliers to analyse Web and social media data (“Third-party suppliers”):

  • Social media: we have pages on social media channels such as Twitter, YouTube and LinkedIn. When you interact with our social media pages, we gather personal information you choose to provide us, including your contact details (collectively referred to as “Social Information”). The companies that host our social media pages may also provide us with aggregate information and analyses about our activities on social media.

The above third-party suppliers gather data on our behalf, in keeping with our instructions and their own applicable privacy statement.

For more details about how this information is gathered and processed, please visit the links to the privacy statement and/or the terms and conditions for each third-party supplier concerned.

Milestone will NOT retain technical information about how the Game and/or online Service are used by the users (known as “Analytics”) for ANY activity involving advertising, marketing or commercial profiling of the persons concerned.

Information gathered from the device or from third parties (“Information regarding contents”)
We may gather information made available by users and stored in the console, device, Facebook profile or other social media. This might include virtual images which are not real (virtual game photographs which are not real /screenshots), videos or other digital contents such as recordings of game sessions, outcomes of challenges within games and the resulting leaderboards. Only the outcomes of challenges held within games and resulting leaderboards can be shared with some of Milestone games’ content and trademark partners (e.g. Motorcycle factories, etc.).

When using an online ID, Xbox gamertag, PlayStation®, Name and/or username, an Epic Games account for buying and/or accessing our Games and/or connecting the PlayStation™Network account, Xbox Live, Steam and Epic Games accounts to our Games, further information is shared by the above Web-based platforms. It will be used in accordance with the policies of the individual firms, and with this privacy policy. Please refer to the Privacy Policies and EULAs of the individual Web platforms for more details:

Access to the Amazon LUNA cloud game service does not require account linking of any user information, online ID or other such data by Milestone. For more details about how Amazon uses information, please visit:

It should be noted that – with reference to the above external cloud game services – Milestone does not carry out any checks on the Privacy Policies and security measures adopted, nor indeed how said websites function. Milestone is in no way responsible for the functioning of these websites, nor for any breaches of the law which occur through said websites, and accordingly rejects any liability for damages suffered by the User in utilising the websites. As a result, navigating on the websites of third-party cloud game service platforms is solely at the risk and peril of the User. The latter must refer solely to the Owner of the third-party website, and to the Privacy Policy and/or Conditions of Use, for any disputes that arise.

  1. LEGAL BASIS

Legal basis:

  • Consent for leaving cookies on the user’s Web device (via our cookie consent management platform);
  • Contractual requirement to process data when the user makes use of Milestone Games/Services in order to enable Milestone to provide its services.
  • Our legitimate interests: to process the user’s data when providing customer support services; for security purposes; for fraud prevention; to carry out analysis, research and development activities for the purpose of improving, refining and enhancing our Games.
  1. USE OF GATHERED INFORMATION

All the information gathered from users, including personal data, will be used for the purposes described when the information is gathered, and for the following ends:

Information transmitted

  • To help us identify users and create, run and monitor any account used with us;
  • For administrative purposes;
  • To analyse technical information about how the Game and/or online Service are utilized by users, organised solely in aggregate and non-personalised form;
  • To remember users and their player profiles, including avatars and any data saved;
  • If the cookies are accepted, to send information and updates regarding the Game and/or online Service;
  • If the cookies are accepted, to give users information about other games and services we offer which are similar to the ones purchased;
  • If the cookies are accepted, to give users of the Game suggestions and advice regarding goods and services they might be interested in;
  • To allow users to participate in interactive features of the Game, if they choose to do so;
  • To manage the parental control process (for Games in which it is provided);
  • To manage any issues flagged by Users regarding improper behaviour (ref. Par. 5.11 EULA) by other gamers;
  • To inform users of any changes made to the Game or services provided.

 

Technical Information (organised solely in aggregate and non-personalised form)

  • To understand how users make user of the Game and online Service, and how frequently;
  • To manage the Game and for inhouse operations, including problem solving, data analysis, testing, research, statistics and surveys;
  • To help us improve the Game and the online Service to ensure the content is presented in the most effective way for users and their devices; and
  • As part of our own efforts to keep all the multiplayer elements of the Game safe.

Content Information

  • To allow users to share gaming sessions with other users of the Game and with their friends;
  • To allow users to participate in interactive features of the Game, if they choose to do so;
  • To enable us to carry out analysis, research and development activities for the purpose of improving, refining and enhancing our Games;
  • If the cookies are accepted, to give users of the Game suggestions and advice regarding goods and services they might be interested in; and
  • If the cookies are accepted, to give users information about other games and services we offer which are similar to the ones purchased.
  1. WHY WE GATHER INFORMATION ABOUT USERS

To deliver our Games and online Service
Depending on the circumstances, we will use information about users (including Transmitted Information, Content Information and Web data analysis) to supply our Games and online Service to users in keeping with the agreed Terms of Use, as well as to:

  • Answer user requests; and
  • Contact users about any issues involving the game or similar situations.

The processing of Transmitted Information, Content Information and Technical Information is required for contractual aspects, and in order to pursue our legitimate interest of rendering our Games and online Service available for users. It is also required to ensure our Games ensure users receive the best possible experience when using any of our Games and the online Service.

Understanding how the Game and online Service are used
The information (including Transmitted Information, Content Information and Technical Information) is processed to allow us to understand how gamers use our Games and our online Service, and to compile statistical and analytical reports about these activities, organised solely in aggregate, non-personalised form.

This processing is necessary to allow us to pursue our legitimate interests to (i) ensure our Games run in a way that gives our users and others the best possible experience when using any of our Games and online Service, and (ii) improve the quality of our games and services, and offer our users a better experience.

To improve, refine and enhance the Game
This may be done by studying the best performances of the highest-performing users, which may include the use of our proprietary internal generative AI system, with the aim of developing new improvements and refinements to the Game. The AI is a proprietary and internal system of Milestone, it does NOT share information with third parties and will exclusively use game information collected directly by Milestone. The information used by the AI does NOT contain directly identifying information about users (e.g. nickname, IP address, connection data, etc.).

Web/Social – Marketing and Advertising
Subject to consent given by accepting Cookies, tracking tools may be used on Milestone Websites and/or on Social Media platforms (Twitter, YouTube and LinkedIn) in order to:

  • Offer a personalised user experience that enables better management of personal settings and interaction with external networks and platforms (Consent for Experience Improvement Cookies)
  • Measure traffic and analyse the behaviour of Users, with an end to improving the Service (Consent for Measurement Cookies)
  • Provide sales contents which are tailored to suit the User’s behaviour, and to manage, distribute and track adverts (Consent for Targeting and Advertising Cookies).

 

Advertising communicated via our Online Services involves products or services which are similar or connected to the Games and Online Services which you have expressed an interest in, or already purchased.

 

Managing preferences and granting or revoking consent for Cookies:

Users can manage their Tracking Tool preferences directly through their device settings – for example, they can prevent the use or storage of Tracking Tools.

 

In addition, whenever the use of Tracking Tools is based on consent, the User can grant or revoke the consent by setting preferences in the cookie policy, or by updating preferences using the tracking settings widget, if there is one.

 

Purposely-designed features of the browser or device also make it possible to remove previously saved Tracking Tools.

 

Other Tracking Tools in the browser’s local memory can be removed by cancelling the browser history.

 

For third-party Tracking Tools, Users can manage preferences and revoke consent by visiting the relevant opt-out link (if available), using the tools described in the third party’s privacy policy, or by contacting them directly.

 

Identifying Tracking Tool settings

By way of example, Users may find information about how to manage Cookies in some of the most common browsers via these links:

 

Google Chrome

Mozilla Firefox

Apple Safari

Microsoft Internet Explorer

Microsoft Edge

Brave

Opera

 

Users can also manage some Tracking Tools for mobile applications by disabling them via the device settings. These include mobile advertising settings or general tracking settings (users must check the device settings to identify the tools concerned).

 

How to disable advertising based on interests:

Notwithstanding the above, we wish to inform Users that they are free to use the information available on YourOnlineChoices (EU), Network Advertising Initiative (USA), Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or others. These services make it possible to manage tracking preferences for most advertising tools. As a result, the Data Controller recommends using these resources in addition to the information provided in this document.

 

The Digital Advertising Alliance also offers an application called AppChoices, which helps Users control behavioural advertising on mobile applications.

 

Consequences of not granting consent:

Users are free to decide whether or not to grant consent. Tracking tools allow this Application to give Users a better experience and more advanced features (in keeping with the purposes described in this document). So if the User does not give consent, the Data Controller may not be able to provide these features.

 

  1. SHARING DATA

6.1 We will only share user information with third parties, including the third-party Web data analytics providers described in section 2, in the ways described in this Privacy Policy. For more details about how the third-parties listed in this policy use information, please check their respective privacy policies.
6.2 We safeguard the confidentiality of our Users’ information, but we may disclose it to any member of our group (including our subsidiaries, our parent company and its subsidiaries), our staff, suppliers or subcontractors to am extent deemed reasonably necessary for the purposes set out in this Privacy Policy. However, this is based on the understanding that they will not make independent use of the information, and have agreed to protect it.
6.3 We may also divulge Users’ information insofar as we are required to do so by law (which may include to governing bodies and the police force); in relation to any legal proceedings, or potential legal proceedings; and to establish, exercise or defend our legal rights (including divulging information to others for the purposes of preventing fraud).
6.4 If we should be involved in a merger, acquisition or sale of part or all our assets, Users will be notified of any change in ownership or use of their information, as well as any choices they may have regarding the information, via e-mail, account message and/or notice which will be clearly posted on our website.
6.5 We may also disclose the Users’ personal information to third parties, to enforce or apply the agreed contractual terms, conduct investigations into potential breaches or protect the rights, property or security of Milestone, our customers or others. This may include sharing information with other companies and organisations for fraud protection and credit risk reduction purposes.

6.6 In the context of studying the best performances of the highest-performing users, our proprietary internal generative AI system may be used, with the aim of developing new improvements and refinements to the Game. The AI is a proprietary and internal system of Milestone, it does NOT share information with third parties and will exclusively use game information collected directly by Milestone. The information used by the AI does NOT contain directly identifying information about users (e.g. nickname, IP address, connection data, etc.).

  1. USER RIGHTS REGARDING PERSONAL DATA PROCESSED

Users have the following rights over how we process their personal data, as set out in the table below. Our aim is to comply without undue delay, within one month at the latest.
To submit a request, please contact our Data Protection Officer using the Contact/Support service:

Request a copy of processed data and have any inaccuracies corrected
Users are entitled to ask for a copy of any personal information in our possession, and to have any inaccuracies corrected.
We will make all reasonable efforts as required by law to provide, correct or eliminate any personal information regarding users in our possession which is stored in our archives (and with any third parties to whom the information has been disclosed).

Objecting to the processing of user data
Users may ask us to restrict, stop processing or cancel their personal data if:

  • They have agreed to allow us to process their personal data and have subsequently withdrawn this consent;
  • We no longer need to process the personal data due to the reasons they were originally gathered for;
  • We are processing their personal data because it is in the public interest to do so, or to pursue a legitimate interest of Milestone but the users do not agree with the processing and there is no high-priority, legitimate interest for pursuing the processing on our part;
  • The personal data have been processed illegally;
  • The users need the personal data to be eliminated to fulfil legal requirements;
  • The personal data are being processed in relation to a service being offered to a minor.

Obtaining a legible copy of one’s personal data from a calculator in order to use it with another service provider

  • If we are processing data to fulfil our obligations, or because users have given us their permission to do so, when the processing is carried out using automated means, we will help users move, copy or transfer their personal data to other computerised systems.
  • If asked to do so, we will give users the relevant personal data in CSV format. Where technically feasible, if users prefer, they may ask for said information to be sent directly to another computerised systems supplier.

Filing a complaint with a supervisory authority

  • If users should be dissatisfied with the means used to process their personal data, they can let us know by contacting Support.
  • If users do not agree with the way we have processed their data or answered their concerns, they can file a complaint with a supervisory data protection authority.
  1. DATA RETENTION
TYPE OF INFORMATION PLACE OF STORAGE RETENTION PERIOD
Information provided by users while using the Game or online Service (“Information transmitted”) Amazon Web Services Server (“AWS”): North Virginia and Ireland.

The contractual clauses as per article 46, par. 1, and par. 2, lett. c) of EU Regulation 2016/679 (GDPR) have been signed with AWS.

Gathered and aggregated promptly in generic, non-identifying reports.

The original data are only kept as back-up for preventing fraud, or for fulfilling legal requests.

Further data gathered when the user makes use of our Services

(“Technical Information”)

Information gathered from the device or from third parties (“Information regarding contents”)
Cookies Please refer to the Cookie Policy of milestone.it Please refer to the Cookie Policy of milestone.it

 

  1. MINORS

We do not use our Games and/or online Service to knowingly solicit data or sell to minors under the age of 16. In addition, for those aged less than 13, features of some Services that might allow a minor to share data that can identify him/her directly are disabled.

  1. PARENTAL CONTROL

Within the Games in which it is active, our Parental Control enables you to choose how Minors play and interact with others in the games and gaming experiences. These tools allow those with parental responsibility to take informed decisions about what is in the best interests of Minors, and to manage access to social features such as voice and text chat, amongst others.

After accessing the Minor’s Milestone account using the Parental Control Portal, it is possible to set or make changes to the Parental Control of the young player under the parent’s responsibility. For more details, please follow the link to our partner Kids Web Services Ltd., which provides our parental control service:

  1. SECURITY

11.1 We will take all reasonable technical and organisational precautions to prevent the loss, abuse or alteration of the personal information of users. By way of example, our databases are protected by password and encrypted with Transport Layer Security (TLS) and Secure Sockets Layer (SSL).
11.2 Please bear in mind that whilst we undertake to ensure the information we process and store is reasonably safe, no security system can prevent all potential breaches.

  1. INTERNATIONAL DATA TRANSFER

12.1 The information we gather from users will be kept outside the European Economic Space (“SEE”) in a protected server located in North Virginia, USA, and in Ireland (EES).
12.2 At the time of publishing this privacy policy, the servers belong to and are managed by Amazon Web Services (“AWS”). AWS has been approved by the European data protection authorities to enable data to be transferred outside the EES using an Appendix on data processing approved by the EU and model Clauses whereby AWS undertakes to provide suitable protection for the personal data of EES citizens processed and stored in AWS servers. Milestone has been included in the Appendix on data processing approved by the EU, and in the model Clauses with AWS to assure this protection.

 

  1. CONTACT INFORMATION

Questions, comments or requests should be sent to Milestone via Support, which can be accessed at https://milestone.it/it/contact/. We will do our utmost to answer any requests or queries within two working days.

The Milestone DPO can be contacted using Support via the link https://milestone.it/it/contact/. He or she will analyse any requests received and provide answers, also through the Data Controller, no later than the amount of time stipulated by the rules governing personal data protection, EU Regulation 679/2016.