Dutch crypto currency game platform startup fraud

November 13, 2019
News

It’s odd news to publish on our website, but we thought it wise to give it some attention to prevent any misunderstandings.

Yesterday we were surprised to read that there was someone arrested in a crypto currency fraud concerning a game platform called Komodore64. We were not aware of this project nor are we interested in crypto currency, but it turned out the man that ran this operation (whom we have never heard of) is from our own city of the Hague!

So then you get to thinking: if people type in ‘the Hague’ and ‘Video Game’ in a search engine, maybe this news comes up. That’s just great for a video game project like ourselves looking for investment!

So let us share the happy news with you that this (alleged) crook is arrested! At least that shows that the police in our country is actively hunting fraudsters, that bolsters ones confidence! Here’s the link to an article about it:

https://cointelegraph.com/news/netherlands-police-arrest-founder-of-blockchain-startup-that-raised-over-80m

The only positive thing about it, we suppose, is that people were willing to invest in a Dutch game related project! Their big mistake was to invest in some kind of shady crypo currency scheme, instead of a straight up game project like us.

If you would ever doubt who we are and what our intentions are: we share all our real identities on www.deadeye-games.com. You can check us, our careers, our company, our previous employers, it’s all public record. We put our own reputations on the line for this project and we are fully transparent about the finances and will always be willing to share proof of that with anyone that invests in our project.

Although we are building a game inside of which corruption might be a big factor, in real life we despise it. You can hold us to that.

Always check carefully before you invest in anything! Check us too. And if you want to know more, let us know! We have nothing to hide.

TERMS AND CONDITIONS OF ADMINISTRATION
DEADEYE GAMES FOUNDATION TRUST OFFICE

March 1, 2020

DEFINITIONS

The following definitions apply to these Terms and Conditions of Administration:

a) “STAK DG”: Stichting Administratiekantoor Deadeye Games (being Deadeye Games Foundation Trust Office), with its registered office in The Hague, the Netherlands and registered with the Chamber of Commerce under number 76228029;

b) “Company” or “DG BV”: the private limited liability company: Deadeye Games B.V., having its registered office in Amsterdam, the Netherlands and registered with the Chamber of Commerce under number 75214474;

c) “Board” or “Directors”: the Board of Directors of STAK DG;

d) “Share” or “Shares”: a share or shares in DG BV;

e) “Share Certificate” or “Share Certificates”: the rights that are granted after transfer of ownership under title of management of a share of DG BV to STAK DG or after issue of a share by DG BV to STAK DG under STAK DG administered shares;

f) “Share Certificate holder” or “Share Certificate holders”: a holder or holders of one or more share certificates;

g) “Written”: by mail, electronic mail (email) or by any other means of communication capable of transferring written text and signatures;

h) “Gamer Shares”: the share certificates issued by STAK DG; and

i) These Terms and Conditions of Administration (hereafter also to be named: TCA) apply to the so-called Gamer Shares / share certificates.

SHARE CERTIFICATES

Article 1

STAK DG is the sole beneficiary of the shares it acquired and is, with the exclusion of everyone else, entitled to exercise all rights associated to those shares, such as voting rights, rights to claims and rights to dividends, all subject to the provisions of the Articles of Incorporation of DG BV and/or the Articles of Incorporation of STAK DG, as they read now or in the future, and with due observance of these TCA.

Article 2

STAK DG will issue one share certificate for each share acquired.
The share certificates are registered and have the same nominal value and numbers as the underlying shares for which they have been issued.
No (physical) proof of certificate will be issued.
In the event of a reduction of the nominal value of the shares, the nominal value of the share certificates will be reduced accordingly.
There is no right to participate in meetings attached to certificates. However, we, STAK DG, have the intention to hold at least one meeting for share certificate holders each year.
A share certificate holder cannot encumber his or her share certificates.
A share certificate holder is obliged to fully comply with these TCA.

Article 3

STAK DG collects the dividends and all other distributions (such as repayment on shares) on the shares. After receipt of the dividend (or other distribution), STAK DG will transfer the amount due to the relevant share certificate holder within two (2) working days.
The rights of share certificate holders for the payment of dividends (or other distributions) will expire after five (5) years.
If a choice has to be made between a cash payment or other values (such as stock dividend), STAK DG will inform the share certificate holders in advance (at least two (2) weeks before the day on which the choice has be made). STAK DG will give the share certificate holders the possibility to make their own choice as much as possible. The choice needs to be made no later than the fifth (5th) working day before the distribution. If the choice of the certificate holder has not been made known to STAK DG five (5) working days before the day on which the choice needs to be made, STAK DG will decide as it deems in the best interest of the share certificate holder.
If the distribution as referred to in paragraph 1 of this article consists of shares of DG BV (for example stock dividends), the share certificate holder is not entitled to receive these shares. These shares will remain with STAK DG for the administration, against which the share certificate holder is entitled to an equal nominal amount of share certificates.
If, pursuant to Article 2: 216 (3) of the Dutch Civil Code, STAK DG is obliged to compensate for the deficit that has arisen due to a single distribution on shares, plus the statutory interest, the share certificate holders that are entitled to the corresponding share certificate receipts and have received a corresponding payment, have to repay an equal amount on the share certificates, corresponding to the relevant shares, to STAK DG. The above also applies to compensation for a shortfall in the sale of shares by STAK DG pursuant to Article 2: 207 paragraph 3 of the Dutch Civil Code.
Final payments on shares relating to the share certificates in the event of liquidation of DG BV, will be paid by STAK DG (no later than two (2) working days) to the share certificate holders against cancellation of the share certificates.

Article 4

If DG BV issues (new) shares, the Board of Directors decides whether the share certificate holders may utilize a pre-emptive right, if such a right is granted to the shareholders. The Board will make such decision as it deems in the best interest of all share certificate holders. If the Board decides that the share certificate holders may exercise the pre-emptive right, STAK DG will invite the share certificate holders to inform STAK DG, within the period set by STAK DG, whether STAK DG should use this pre-emptive right with regard to the shares that are administered for the share certificate holder concerned. At the same time, the share certificate holder needs to provide resources to STAK DG to pay the amount due to DG BV at registration (this concerns the issue price of the shares plus one percent (1%) of administration costs). The shares acquired are held by STAK DG for management, against which the share certificate holder is entitled to an equal nominal amount of share certificates.
In the event that STAK DG as a shareholder has a right to purchase shares pursuant to the Articles of Incorporation of DG BV, the Board of STAK DG decides whether the share certificate holders may use any right to purchase shares granted to the shareholders. The Board will decide as it deems in the best interest of the share certificate holders. If the Board of STAK DG decides that the share certificate holders may exercise the right to purchase shares, STAK DG will invite the share certificate holders accordingly and to inform STAK DG within a period set by STAK DG whether STAK DG must exercise this right with regard to the share certificates that are administered for the share certificate holder concerned. The holder of share certificates then simultaneously needs to make an amount, to be determined by STAK DG, available to STAK DG, which is sufficient to pay for the shares to be acquired (including one percent (1%) of administration costs). If the amount made available proves to be insufficient when the purchase price is determined, the share certificate holder will immediately complete the deficit. Any amount deposited in access will be returned to the share certificate holder without delay.
The provisions of paragraph 1 of this article apply mutatis mutandis to the granting of rights to subscribe for shares.

REGISTER OF SHARE CERTIFICATE HOLDERS

Article 5

The Board of Directors of STAK DG maintains a register that contains at least the names and (email) addresses of the share certificate holders and the numbers of the share certificates held.
The register is regularly kept up to date.
The share certificate holders are obliged to immediately notify STAK DG in writing of any change to the data entered in the register. STAK DG is obliged to register any changes to the register that it has been notified of.
Every entry in the register is done under a recorded date.
STAK DG is authorized at all times to renumber the certificates (and such).
All notifications and invitations to share certificate holders are done by using the registered (email) addresses.
The Board makes the register available at the STAK DG office for review by share certificate holders.
At the request of a share certificate holder, the Board will provide him/her with a free extract from the register insofar as his/her share certificates are concerned.

CERTIFICATES UNDIVIDEDLY

Article 6

If share certificates belong to a community (and/or undivided estate), each member is entitled to exercise the rights attached to the share certificates in proportion to his/her share in the community of certificates. The members can only be represented vis-à-vis STAK DG by one person to be designated in writing.

DISPOSAL AND ENCUMBERMENT OF SHARES (Tag-Along Right)

Article 7

STAK DG cannot pledge or otherwise encumber the shares it administers.
STAK DG is not authorized to dispose of one or more shares it administers, unless it concerns:
1. Disposal with the consent of the holder of the share certificate issued, against withdrawal of the share certificate and immediate payment (within two (2) working days) to the certificate holder of the proceeds received by STAK DG.
STAK DG is authorized (without the consent of the holders of share certificates) to dispose of all the shares it holds under title to management, if:
1. It is obliged to do so on the basis of the shareholder agreement concluded between the shareholders of DG BV (hereinafter also to be named: Shareholder Agreement); and/or
2. All other shareholders of the company simultaneously dispose of the shares they hold, provided that the proceeds received by STAK DG immediately or later (including payment of an escrow amount), will be transferred immediately (within two (2) working days) after receipt to the share certificate holders, in which case the share certificates will be cancelled.
In the event that, under the Shareholder Agreement, STAK DG has a Tag-Along Right, as defined below, STAK DG informs the share certificate holders within one (1) week after notification of the Tag-Along Right in writing, together with the opportunity to make use of the Tag-along Right, to dispose share certificates in a similar manner as described in the following paragraphs, and confirm this ultimately five (5) working days before the day on which STAK DG must have made use of its Tag-Along Right. STAK DG will indicate the number of shares for which the Tag-Along Right can be exercised and the further conditions on the basis which the underlying shares can be disposed of.
A Tag-Along Right means: if one shareholder (or group of shareholders) of DG BV wishes to dispose of shares in the capital of DG BV and sell to a third party, then according to the Shareholder Agreement, any of the other shareholders of DG BV will be able to dispose of a proportional share of the shares he/she holds and sell to that third party (that is, each shareholder is entitled to dispose the same percentage of shares he/she holds in the capital of DG BV, against the same price and under the same conditions).
If share certificate holders have timely confirmed in writing that they want to make use of their Tag-Along Right as referred to in paragraph 5, then STAK DG will, to the extent possible, make use of its Tag-Along Right for the benefit of the relevant share certificate holders.

TRANSFER AND CONDITIONS REGARDING CERTIFICATES

Article 8

The share certificates are freely transferable unless additional conditions have been imposed by the Board to the share certificate holder when acquiring the share certificates, with regard to the transfer of the share certificates (including, but not limited to, transfer restrictions, mandatory offering arrangements, lock-up arrangements and valuation arrangements).
The conditions as referred to in the previous paragraph:
- Can differ per share certificate and/or per share certificate holder;
- Form an integral part of these TCA insofar as it concerns the share certificates concerned; and
- Can be cancelled, changed and/or adjusted in accordance with the relevant applicable conditions.
The transfer of share certificates can be effected either by notarial deed or by private/authentic deed. The transfer must always be communicated to STAK DG by the transferor and/or the transferee.
The provisions of paragraph 1 also apply with regard to the allocation of share certificates upon division of a community.
The transfer will only have an impact on STAK DG after STAK DG has been notified thereof.

COSTS

Article 9

STAK DG will charge costs for the certification, management and administration of shares to DG BV. STAK DG does not charge share certificate holders (additional) costs other than the one percent (1%) costs upon both buying and selling the share certificates.

EXERCISE OF VOTING RIGHTS AND OTHER SHAREHOLDERS RIGHTS

Article 10

The voting rights and all other controlling rights attached to the shares are exercised by STAK DG at its own discretion, taking into account the provisions of the Law, the Articles of Incorporation of STAK DG and these TCA.

NON-CANCELLATION OF CERTIFICATES

Article 11

Except in the situations provided for in Article 12 of the TCA, share certificate holders cannot claim the administered shares. The cancellation of the share certificates can only be done against the cancellation of the underlying shares.

END OF ADMINISTRATION

Article 12

The administration ends:

As a result of a decision of the Board; or
In the situation that STAK DG will be dissolved.

At the end of the administration, the share certificates are de-certified (converted into shares) and the corresponding shares will be transferred to the share certificate holders.

FINANCIAL STATEMENTS

Article 13

STAK DG will immediately (within five (5) working days after the publication of the annual report of DG BV) give the share certificate holders the opportunity to become acquainted with these documents.

LIQUIDATION

Article 14

In the event of liquidation of DG BV, the surplus will be paid immediately (within five (5) working days) to the share certificate holders while simultaneously canceling the share certificates.

ARTICELS OF INCORPORATION STAK DG

Article 15

In addition to the provisions in these CTA, the administration of share certificates is also subject to the provisions of the Articles of Incorporation of STAK DG.

CHANGE OF ADMINISTRATION TERMS AND CONDITIONS

Article 16

The Board is authorized to change these TCA. When a change is made, the Board will immediately notify all the share certificate holders accordingly. The same applies to a change to the Articles of Incorporation of STAK DG. In both case, the Board will inform all share certificate holders in writing, to the (e-mail) addresses referred to in Article 5. For the sake of completeness, a change in the TCA can only be made by unanimous vote in a meeting of the STAK DG Board of Directors, in which all Board Members are present or represented. If not all Members of the Board are present or represented in a Board Meeting in which a proposal to change the TCA is on the agenda, then a second meeting will be convened, to be held within fourteen (14) days after the first, in which, regardless of the number of Board Members present, a valid decision will be made by unanimous vote. Similarly, it can be decided to fully or partially cancel share certificates issued by STAK DG or to dissolve STAK DG. Upon dissolution of STAK DG, all underlying shares will be transferred to the holders of the corresponding share certificates.

TAX IMPACT

Article 17

Each holder of share certificates is deemed, by obtaining these share certificates (whether or not upon issue), to declare towards STAK DG, the Board and DG BV to be aware of the possible tax consequences of his/her participation in the capital of DG BV through the share certificates and/or exercising his/her rights therefrom. STAK DG and the Board bear no responsibility towards the share certificate holders in this regard.
Insofar as taxes and/or social security contributions are due by STAK DG with regard to acquiring the share certificates by share certificate holders, STAK DG can recover these taxes and/or premiums from the share certificate holder concerned.

CHOICE OF LAW

Article 18

Dutch law is applicable to the TCA.

MISCELANEOUS

Article 19

In case of a dispute the Dutch version of the TCA shall prevail.

Forum Policy – Support Community Guidelines

Welcome to the Rulers of the Sea (hereinafter referred to as “RotS”) Support Community (the ”Community”), a place for discussions and exchange of information related to RotS services. By using the Community you agree to follow these RotS Support Community Guidelines (the “Guidelines”), our Support Community Terms of Services (the “Terms of Services”) and the Privacy Policy (as defined in the Terms of Services).
Deadeye Games B.V. is a private company with limited liability and incorporated under the laws of the Netherlands, having its registered office in The Hague and its principal place of business at XX . Deadeye Games is the developer of the RotS game. Deadeye Games B.V. is sometimes also referred to as “Deadeye Games”; “we”, “us” or “our”.

1. No official support from RotS

Keep in mind that most of the information or other material posted in the Community is user generated and not official support provided by us. As with any information or advice, obtained through any medium, you should use your judgment and exercise caution where appropriate, regardless of from whom such material originates. For official support with account related and payment related questions, please submit a ticket to our customer service department using the contact button.

2. Use of the Community

In order to protect the integrity of our users and to maintain the Community as efficient and helpful as possible for the users, we expect you to observe the following rules:

• Before searching for a thread related to your topic or posting a question regarding a problem, try reinstalling the RotS application or check the FAQ.

• Before posting or creating a new thread, make sure the issue you’re experiencing or the question you have is not already posted somewhere in the Community. Multiple threads on the same issue create clutter.

• Avoid double posting. We will delete duplicate threads or posts on the same questions created by a user.

• Make sure that the thread you are posting on is relevant for your issue). Also, make sure that the thread is not outdated or relates to issues that have already been fixed or dealt with by us.

• Please only post information relevant for the thread and avoid discussing personal matters or topics unrelated to our Services.

• Create a new thread or find another related thread if you have multiple queries. Do not add further queries to an existing thread.

• Be careful about the information that you post. Keep in mind that your posts will be available for all users of the Community. We will only remove posts upon your request, as outlined in Section 4 below.

• Always use an appropriate and respectful language when you post information in the Community. Avoid racist, sexist, or otherwise offensive language that could be considered detrimental to other users, or Deadeye Games’ employees or moderators.

• Do not post information or create threads for the promotion or advertisement of commercial products or services.

• In the spirit of integrity, please do not post information such as name, address, personal identification number, social security number, email address, credit card information, or other personal information of other persons. Also make sure that you have all legal rights and/or consents to post any information or other material that you provide or link to through the Community.

• For obvious reasons, do not post links to malware, Trojan viruses, or otherwise malicious content.

• Deadeye Games employees and moderators will identify themselves in the Community by using the Deadeye Games logo as avatars. Do not use any Deadeye Games and/or RotS logo or trade name as your avatar or user name, or otherwise pose as a Deadeye Games employee or moderator when posting in the Community.

3. Reward program

Our customer champion and rewards program is based on the amount of “Medals” received and quality of responses by a user. No posting of artificial responses or other manipulation of the reward program is allowed. Please remember that Rots’ decisions relating to rewards will be final and binding.

4. Moderation and reporting

RotS moderators may remove or edit user posts that, in our sole discretion, violate the Guidelines or the Terms of Services without prior notification to the author. Remember that use of the Community in conflict with the Guidelines or the Terms of Services also may result in immediate termination or suspension of your support account. Please help us to protect integrity and to maintain the Community as helpful as possible by reporting any inappropriate activity or user posts in the Community. Inappropriate content or activity may be reported by using the abuse button under the thread options.

5. Miscellaneous

Forum Policy – Support Community Terms

Welcome to the Rulers of the Sea (hereinafter referred to as “RotS”) Support Community Terms and Guidelines (the “Community Terms”).

Thanks for choosing the RotS Support Community (the “Community”). The Community is a place for discussions and exchange of information, tips, and other materials related to the RotS Service.
By using the Community, you agree to these Community Terms, our Terms of Services and our Privacy Policy and the Guidelines (the “Terms”).

These Terms constitute a legally binding agreement between you and Deadeye Games B.V, so please read them carefully. If you do not agree to the Terms, please do not use the Community. Some of the terms, such as “RotS Service” used in these Community Terms are defined in our Terms of Services.

Deadeye Games B.V. is a private company with limited liability and incorporated under the laws of the Netherlands, having its registered office in The Hague and its principal place of business at XX. Deadeye Games is the developer of the RotS game. Deadeye Games B.V. is sometimes also referred to as “Deadeye Games”; “we”, “us” or “our”.

1. Community Account.

In order to use the Community, you must (1) have an existing RotS account; and (2) create a “Community Account” by following the instructions on the Community registration page. You must ensure that your registration information is true, accurate and complete, and that you keep it up to date. We may reclaim or amend your username at any time. It is strictly prohibited to include any information in your profile that suggests you are a Deadeye Games B.V. employee or moderator, or to otherwise pose as such an employee or moderator when using the Community.

2. No official support

Information, advice or other material of any kind posted on the Community (“Content”) is not official support provided by Deadeye Games. For official support with account related and payment related questions, please submit a ticket to our customer service department using the contact button. You acknowledge that opinions expressed in Content on the Community are those of contributors of such Content only and does not reflect the opinions or policies of Deadeye Games or its affiliates or group companies.

3. Content, moderation and reporting

You are responsible for all Content that you post on the Community. We do not control and assumes no responsibility for such Content or any Content posted by other users. We reserve the right to moderate the activity on the Community and may remove or edit any Content for any or no reason, including, but not limited to, Content that, in our sole discretion, violates these Community Terms. We may remove or edit such Content without prior notification to the responsible user. Remember that use of the Community in conflict with any of the Terms may result in immediate termination or suspension of your accounts (see the Term and Termination section below). Please help us to protect the integrity of the Community and to ensure that the Community remains as helpful as possible by reporting any inappropriate activity or user posts in the Community.

4. Guidelines

The integrity and safety of our Community and our users means a lot to us. In order to keep the Community as efficient and helpful as possible, we expect you to observe our Guidelines.

5. Reward Program

The Community features a reward system whereby RotS, in its sole discretion, may reward users based on their overall contribution to the Community. You acknowledge that our decision in respect of any reward shall be final and binding. We may change or remove the reward system at its discretion from time to time.

6. Limited license

You grant us a non-exclusive, royalty-free, perpetual, worldwide license to use, reproduce, modify, make available to the public, publish, translate, create derivative works from and distribute any Content or feedback that you post on or otherwise provide through the Community and to exercise all copyright and publicity rights with respect to such Content or feedback, without any attribution to you.

7. Term and termination

These Community Terms will become effective in relation to you when you create a RotS Community Account and will remain in effect until you terminate your RotS Community Account or the earlier termination by us thereof. You may terminate your RotS Community Account at any time by contacting us. Without limiting its other rights to terminate access to the Community, we reserves the right to terminate or suspend your RotS Community Account at any time if, in our sole discretion, you are in contravention of any of the Terms. If we terminates or suspends your RotS Community Account for any reason whatsoever, we or other companies of the Deadeye Games Group, shall have no liability or responsibility to you. Please note that if your RotS Community Account is terminated by you or us for any reason, Content that you have posted may be kept in the Community in an anonymized form.

8. No warranty

The use of the Community is at your own risk. The Community is provided on an “as is” and “as available” basis. To the fullest extent possible under applicable law, we give no warranty, express or implied, as to the quality, content and availability or fitness for a specific purpose of the Community. In addition, we do not warrant, endorse, guarantee or assume responsibility for any Content posted on the Community or any hyperlinked website. As with any information or advice, obtained through any medium or in any environment, you should use your judgment and exercise caution where appropriate. No advice or information whether oral or in writing obtained by you from us or any other company of the Deadeye Games Group shall create any warranty on behalf of Deadeye Games in this regard.

9. Limitation of liability

In no event shall Deadeye Games, its group companies officers, directors, employees, licensors of RotS or any third parties be liable for any direct, indirect, incidental, special or consequential damages (including but not limited to any loss of data, service interruption, computer failure or pecuniary loss) arising out of the use of or inability to use the Community, even if you have advised us about the possibility of such loss, and including any damages resulting therefrom. Your only right with respect to any problems or dissatisfaction with the Community is to terminate your account as set out in Section 9 above and to stop using the Community. Nothing in these Community Terms removes or limits our liability for fraudulent misrepresentation, death or personal injury caused by its negligence.

10. Indemnity

You agree to indemnify and hold Deadeye Games, the Deadeye Games Group and its officers, directors, employees and licensors harmless from any claim or demand (including but not limited to reasonable legal fees) made by a third party due to or arising out of or related to your violation of these Community Terms or the Guidelines, or your violation of any laws, regulations or third party rights.

11. Intellectual property

We respect intellectual property rights, and expect you to do the same. Please note therefore that the Community is the property of Deadeye Games, its group companies or its licensors and is protected by intellectual property rights (including but not limited to copyright) and that you do not have a right to use the Community in any manner not covered by these Community Terms.

12. Technology limitations and modifications

We will make reasonable efforts to keep the Community operational. However, certain technical difficulties or maintenance may, from time to time, result in temporary interruptions. We reserve the right at any time and from time to time to modify or discontinue, temporarily or permanently, the Community or any of its functions and features with or without notice. If we modifies or discontinues the Community for any of the reasons set out above in this Section 14, we or any other company of the Deadeye Games Group, shall have no liability or responsibility to you.

13. Privacy

When you sign up for a use the Community, Deadeye Games and its hosting providers may gather, store, share and use your personal data. The privacy and security of your user data is – and will remain – our highest priority. You can read more about our privacy practices in the Privacy Policy, which includes information about your privacy, your rights and how to exercise them.

14. Miscellaneous

We may change the Guidelines at any time, at its sole discretion. Any material changes will be communicated to you and your acceptance of and/or continued use of the Community after such notification of change will constitute your acceptance of such changes. Please do not use the Community if you do not agree to the new Terms.
In the event that the Community Terms and Guidelines are translated into other languages and there is a discrepancy between the two language versions, the English language version shall prevail.
We may assign its rights and obligations in connection these Community Terms without restrictions. You may not assign your rights or obligations in connection these Community or your Community Account, or any part thereof, to any third party.

The Community Terms and Guidelines shall be governed and construed in accordance with the laws of applicable to you pursuant to the our Terms of Use. Any dispute, controversy or claim arising out of or in connection with the Community Terms and Guidelines will be subject to the jurisdiction of the court in The Hague.

Privacy Policy

Thank you for reading our Data Privacy policy carefully. By accepting them you acknowledge that you have read, understood, and agree to be bound by this Data Privacy policy.

Introduction
About this Policy
What is Personal and Non-Personal Data
Your rights and your preferences: Giving you choices and control
How do we process your personal Data?
What Personal Data do we collect from you?
What do we use your Personal Data for?
Sharing your Personal Data
Personal Data retention and deletion
Transfer to other countries
Links
Keeping your Personal Data safe
Children
Updates of this Privacy Policy
How to contact us

1. INTRODUCTION

Thank you for using Rulers of the Sea. At Rulers of the Sea, we want to give you the best possible gaming experience to ensure that you enjoy our service today, tomorrow, and in the future. To do this we need to understand your gaming habits so we can deliver an exceptional service specifically for you. That said, your privacy and the security of your Personal Data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your Personal Data – as well as outline the controls and choices you have around when and how you choose to share your Personal Data.

This is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.

2. ABOUT THIS POLICY

This Policy sets out the essential details relating to your Personal Data relationship with Deadeye Games B.V., a private company with limited liability and existing under the laws of the Netherlands, having its registered office in The Hague and its principal place of business at XX and developer of the Rulers of the Sea game. The Policy applies to all Rulers of the Sea Services and any associated Services. The terms governing your use of the Rulers of the Sea Services are defined in our Terms of Services (the “Terms of Services”).

From time to time, we may develop new or offer additional Services. If the introduction of these new or additional Services results in any change to the way we collect or process your Personal Data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

The aim of this Policy is to:

Ensure that you understand what Personal Data we process about you, the reasons why we collect and use it, and who we share it with;
Explain the way we use an process the Personal Data that you share with us and we collect about you in order to give you the best gaming experience when you are using the Rulers of the Sea Services; and
Explain your rights and choices in relation to the Personal Data we process and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 15 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Rulers of the Sea Services.

3. WHAT IS PERSONAL AND NON-PERSONAL DATA

“Personal Data” is Data that we have collected from you that identifies you, or which, in conjunction with other data that is in our possession, or is likely to come into our possession, may be used to identify you.

“Non-Personal Data”, is information that we have collected from you which cannot be used to identify you.

4. YOUR RIGHTS AND YOUR PREFERENCES: GIVING YOU CHOICES AND CONTROL

You may be aware that European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their Personal Data. Accordingly, we have implemented additional transparency and access controls in our Privacy Center to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

Right of Access – the right to be informed of and request access to the Personal Data we process about you;
Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete;
Right to Erasure – the right to request that we delete your Personal Data;
Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your Personal Data;
Right to Object – the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation, or the right to object to your personal data being processed for direct marketing purposes;
Right to Data Portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s (gaming) service; and
Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

In order to enable you to exercise these rights with ease and to record your preferences in relation to how Deadeye Games BV uses your Personal Data, we provide you with access to the following settings via your Account Settings page:

Privacy Settings – allows you to control some of the categories of Personal Data we process about you, enables you to access your Personal Data via a “Download my Data” button, and includes a link to the Privacy Center on RulersoftheSea.com where you can find out more information about how Rulers of the Sea process your personal data and what your rights are; and,
Notification Settings – allows you to choose which communications you receive from Rulers of the Sea, manage your publicly available Personal Data, and set your sharing preferences.

The Privacy Center puts you in control of how Rulers of the Sea processes your Personal Data. It provides you with information about what happens if you adjust your settings on your Account Settings page and how to opt out of receiving certain messages from Deadeye Games BV and/or Rulers of the Sea. If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from Deadeye Games BV and/or Rulers of the Sea (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).

If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the ‘Contact Us’ form on the Privacy Center. We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your Personal Data you can also contact and are free to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoongegevens) or your local Data Protection Authority.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

We process your Personal Data in the following ways:

If you access or use our Website – when you access or use our website, we may collect certain personal data such as IP address, cookie data, requested file, browser type/version, browser language, operating system, screen resolution, JavaScript active, Java on/off, cookies on/off, colour settings, referral URL, time of access and clicks;

Through your use of the Rulers of the Sea Services – when you use the Rulers of the Sea Services, we collect Personal Data about your use of the Rulers of the Sea Services such as your email address, date of birth, gender and country;

Personal Data collected that enables us to provide you with additional features/functionalities – from time to time, you also may provide us with additional Personal Data or give us your permission to collect additional Personal Data e.g. to provide you with more features or functionalities. As described further below (see Voluntary Data), we will not collect photos, precise mobile device location, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.

In general, we use log files to monitor traffic on our Website and to troubleshoot technical problems. In the event of user abuse of our Website, we may block certain IP addresses.

We (will) use anonymised and aggregated information to optimize your experience of the Rulers of the Sea Services but also for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Rulers of the Sea Services, and developing new features and functionality within the Rulers of the Sea Services.

5.1 Cookies

We use cookies to ensure that you get the most out of the Rulers of the Sea Services. Cookies are small text files that are applied to your Internet enabled device by websites. Cookies allow us to store and then retrieve information on your computer about your visit to our Website (e.g. when you accessed the Website). We may use cookies to deliver content specific to your interest and to monitor Website usage or to simplify your visits to the Rulers of the Sea Services (for example, by remembering your login details).

Please note that the collection of information in this Section 5.1 is not mandatory. Most browsers are automatically set to accept cookies whenever you visit a website. You can disable cookies or set your browser to alert you when cookies are being sent. However, your web experience may be less satisfying without the use of cookies.

The first time you visit our Website you will be presented with a notification that we use cookies. By proceeding to use the Website you are consenting to our use of cookies as described in the Cookie Policy and this Privacy Policy.

For further information, please read our Cookie Policy.

5.2 Analytic Metrics Tools and other technology

Deadeye Games B.V. may also use its own or third-party proprietary analytic metrics tools and other analytics technologies to collect the data referred to in this Privacy Policy. We may use such technology to deliver content specific to your interest and to monitor usage of the Rulers of the Sea Services.

5.3 Misuse

In addition to Sections 5.1 and 5.2, if we reasonably suspect that any of the Rulers of the Sea Services or your Account is being or has been misused, including without limitation, by virtue of any:

DoS attacks;
Hacking;
Cheating;
Fraud;
Distribution of spam and/or viruses;
Gold farming;
Defamation, racism, hate speech etc.;
Other violations of our Terms of Services;

Deadeye Games B.V. may collect further Personal Data and Non-Personal Data to verify or refute such suspicions within the limits of applicable law and taking into account your reasonable data protection interests. We will use this Data to comply with applicable law and enforce our rights under civil and penal law against the respective users.

5.4 Customer Support

Optionally you may choose to send crash reports or contact Customer Support for any technical and commercial issues.

In addition to the data collected in Sections 5.1 to 5.3 above, the data provided by you may include:

Crash reports;
Further machine specifications;
Screenshots;
Any other data you may choose to provide.

The collection of the data set out in this Section 5.4 is not mandatory. However, we might not be able to fix bugs or handle the technical and commercial issues you have without this data. For legal reasons this information will be stored as long as your account remains open and for the applicable statues of limitations thereafter.

6.WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We have set out in the tables below the categories of Personal Data we collect and process about you:

Personal Data collected when you sign up for the Rulers of the Sea Services

Categories of Personal Data	Description of category
Account Registration Data and Commercial transaction	This is the Personal Data that is provided by you or collected by us to enable you to sign up for and use the Rulers of the Sea Services. This includes your email address, date of birth, gender and country. Some of the Personal Data we will ask you to provide is required in order to create your account such as account ID, login ID, display name, password, community moniker, user handle, and referral code. You also have the option to provide us with some additional Personal Data in order to make your account more personalized such as birth date. The exact Personal Data we will collect depends on the type of Rulers of the Sea Services you sign up for (paid or non-paid).

Categories of Personal Data

Description of category

Account Registration Data and Commercial transaction

This is the Personal Data that is provided by you or collected by us to enable you to sign up for and use the Rulers of the Sea Services. This includes your email address, date of birth, gender and country.

Some of the Personal Data we will ask you to provide is required in order to create your account such as account ID, login ID, display name, password, community moniker, user handle, and referral code. You also have the option to provide us with some additional Personal Data in order to make your account more personalized such as birth date.

The exact Personal Data we will collect depends on the type of Rulers of the Sea Services you sign up for (paid or non-paid).

Personal data collected through your use of the Rulers of the Sea Services

Categories of Personal Data	Description of category
Rulers of the Sea Service Usage Data	This is the Personal Data that is collected about you when you are using the Rulers of the Sea Services – this may include: Information about your type of Rulers of the Sea Services subscription. Information about your interactions with the Rulers of the Sea Services which includes the date and time of gaming, video content you’ve watched, and your interactions with other Rulers of the Sea users. User Content (as defined in the Terms of Services) your post to Rulers of the Sea including messages you send and/or receive via Rulers of the Sea and your interactions with the Rulers of the Sea Customer Service team. Technical Data which may include URL information, cookie data, your IP address, unique device IDs, device attributes, network connection type (e.g. Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, information enabling digital rights management, operating system, and Rulers of the Sea application version. Further details about the technical data that is processed by us can be found in our Cookies Policy.

Categories of Personal Data

Description of category

Rulers of the Sea Service Usage Data

This is the Personal Data that is collected about you when you are using the Rulers of the Sea Services – this may include:

Information about your type of Rulers of the Sea Services subscription.
Information about your interactions with the Rulers of the Sea Services which includes the date and time of gaming, video content you’ve watched, and your interactions with other Rulers of the Sea users.
User Content (as defined in the Terms of Services) your post to Rulers of the Sea including messages you send and/or receive via Rulers of the Sea and your interactions with the Rulers of the Sea Customer Service team.
Technical Data which may include URL information, cookie data, your IP address, unique device IDs, device attributes, network connection type (e.g. Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, information enabling digital rights management, operating system, and Rulers of the Sea application version. Further details about the technical data that is processed by us can be found in our Cookies Policy.

Personal Data collected with your permission that enables us to provide you with additional features/functionalities

Categories of Personal Data	Description of category
Voluntary Mobile Data	In addition to the mobile data we collect to provide you with the Rulers of the Sea Services (outlined above), you also have the option to give us your consent to collect additional Personal Data from your (mobile) device to provide you with features/functionalities that will enhance your Rulers of the Sea Services experiences. We will not access any of the Personal Data listed below without first obtaining your consent: Your photos – If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll; Your precise mobile device location – If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Rulers of the Sea Services. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements; Your voice data – If you give us permission to access your voice data, this enables us to access the voice commands captured via your device microphone to enable you to interact with the Rulers of the Sea Services with your voice. Please note you will always have the ability to turn off the microphone feature; and, Your contacts – If you give us permission to access your contacts, this enables us to access individual contacts stored on your device to help you find friends who use Rulers of the Sea.
Payment Data	We may collect such Personal Data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms of Services) or make other purchases through the Rulers of the Sea Services. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as: Full name; Billing address (including street, ZIP code and country); Credit or debit card type, expiration date, and certain digits of your card number; Mobile phone number; Details of your transaction history; Object acquired; Pledge value; Confirmation email address.
Marketing Data	This Personal Data is used to enable Deadeye Games B.V. (and our partners / service providers) to send you marketing communications either: Via email; Whilst using the Rulers of the Sea Services; and/or Direct from a third party. You can find out more about the Personal Data collected and the controls you have in relation to the marketing communications you receive via the Privacy Center.

7. WHAT DO WE USE YOUR PERSONAL DATA FOR?

When you use or interact with the Rulers of the Sea Services, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 6 ‘What personal data do we collect from you?’) used for these purposes:

Description of why Rulers of the Sea processes your Personal Data (‘processing purpose’)	Legal Basis for the processing purpose	Categories of Personal Data used by Rulers of the Sea for the processing purpose
To provide, personalize, and improve your experience with the Rulers of the Sea Service and other services and products provided by Deadeye Games B.V., for example by providing customized, personalized, or localized content, features, and advertising on or outside of the Rulers of the Sea Services (including for third party products and services).	Performance of a Contract Legitimate Interest	Account Registration Data Service Usage Data
To understand how you access and use the Rulers of the Sea Services to ensure technical functionality of the Rulers of the Sea Services, develop new products and services, and analyse your use of the Rulers of the Sea Services, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Rulers of the Sea Services.	Performance of a Contract Legitimate Interest	Account Registration Data Service Usage Data
To communicate with you for Rulers of the Sea Services-related purposes.	Performance of a Contract Legitimate Interest	Account Registration Data Service Usage Data
To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Rulers of the Sea Service.	Performance of a Contract Compliance with legal obligations Legitimate Interest	Payment Data
To communicate with you, either directly or through one of our partners, for: Marketing; Research; via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your Account Settings page).	Consent Legitimate Interest	Marketing Data
To provide you with features, information, advertising, or other content which is based on your specific location.	Consent	Voluntary Mobile Data

If you require further information about the balancing test that Rulers of the Sea has undertaken to justify its reliance on the legitimate interest legal basis under GDPR, please see Section 15 ‘How to contact us’ for further details on how to contact us.

8. SHARING YOUR PERSONAL DATA#

We have set out the categories of recipients of the Personal Data collected or generated through your use of the Rulers of the Sea Services. Please note that other than explicitly set out in this Privacy Policy, Deadeye Games B.V. will never share your Personal Information with third parties without your consent.

Publicly available information

The following Personal Data will always be publicly available on the Rulers of the Sea Services: your ID and/or username and potentially a profile picture.

Personal Data you may choose to share

The following personal data will only be shared with the categories of recipients outlined in the table below if:

you choose to make use of a specific Rulers of the Sea Service feature where sharing of particular Personal Data is required for the proper use of the Rulers of the Sea Services feature; or
you grant us your permission to share the Personal Data, e.g. by selecting the appropriate setting in the Rulers of the Sea Services.

Categories of Recipients	Reason for sharing
Support Community	When you register for Rulers of the Sea Support Account on the Rulers of the Sea Support Community, we will ask you to create a specific Rulers of the Sea Support Community username. This will be publicly displayed to anyone who accesses the Rulers of the Sea Support Community along with any questions or comments you post.
Your Rulers of the Sea Followers	There also may be times when you want us to share certain Service Usage Data, specifically information about your use of Rulers of the Sea, with other Rulers of the Sea users known as ‘Your Rulers of the Sea Followers’.

Learn more about how to manage notifications, your publicly available information, and what you share with others in the ‘Your rights and your preferences: Giving you choice and control’ Section 4 of this Policy and on the Privacy Center.

Information we may share

Categories of Recipients	Reason for sharing
Service Providers and Others	We may use technical service providers which operate the technical infrastructure that we need to provide the Rulers of the Sea Services; in particular providers which host, store, manage, and maintain the Rulers of the Sea application. We may use technical service providers to help us communicate with you, as described in Section 7 of this Policy. We use marketing (and advertising partners) to show you more tailored content, or to help us understand your use of the Rulers of the Sea Services, to provide you with a better experience. We also may share Personal Data with certain marketing and advertising partners to send you promotional communications about Rulers of the Sea.
Rulers of the Sea Partners	We might share your Personal Data in a pseudonymised format with marketing partners who help us with promotional efforts and with advertisers that allow us to offer a free service.
Academic Researchers	We may share your Personal Data for activities such as statistical analysis and academic study but only in a pseudonymised format.
Other Rulers of the Sea Group Companies	We might share your Personal Data with other Deadeye Games B.V. Group Companies to carry out our daily business operations and to enable us to maintain and provide the Rulers of the Sea Services to you.
Law Enforcement and Data Protection Authorities	We will share your Personal Data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also will share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your Personal Data.
Purchasers of our business	We will share your Personal Data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Deadeye Games B.V. will continue to ensure the confidentiality of your Personal Data and give you notice before your Personal Data is transferred to the buyer or becomes subject to a different Privacy Policy.

9. DATA RETENTION AND DELETION

We keep your Personal Data only as long as necessary to provide you with the Rulers of the Sea Service and for legitimate and essential business purposes, such as maintaining the performance of the Deadeye Games Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your Personal Data for as long as you are a user of the game.

If you request, we will delete or anonymise your Personal Data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain Personal Data, including situations such as the following:

If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
Where we are required to retain the Personal Data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

10. TRANSFER TO OTHER COUNTRIES

Deadeye Games B.V. might share your Personal Data globally with other companies in the Deadeye Games B.V. Group in order to carry out the activities specified in this Policy. Deadeye Games B.V. may also subcontract processing to, or share your Personal Data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.

Personal Data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Deadeye Games B.V. will ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

For further details of the security measures we use to protect your Personal Data, please see the ‘Keeping your personal data safe’ Section 12 of this Policy.

11. LINKS

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Rulers of the Sea Service and any Personal Data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect process and protect your Personal Data.

12. KEEPING YOUR PERSONAL DATA SAFE

We are committed to protecting our users’ Personal Data. We implement appropriate technical and organisational measures to help protect the security of your Personal Data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of Personal Data in our systems.

Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Rulers of the Sea Services.

13. CHILDREN

The Rulers of the Sea Services are not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law. Please see our Terms of Services for further details.

We do not knowingly collect Personal Data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Rulers of the Sea Services, and do not provide any Personal Data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided Personal Data to Rulers of the Sea, please contact us using the form on the Privacy Center, and you may request exercise of your applicable rights detailed in the ‘Your rights and your preferences: Giving you choice and control’ Section 4 of this Policy.

If we learn that we have collected the Personal Data of a child under the age of 13 years, we will take reasonable steps to delete the Personal Data. This may require us to delete the Rulers of the Sea account for that child.

14. UPDATES OF THIS PRIVACY POLICY

We will occasionally update this Policy. When we make material updates to this Policy, we will provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Rulers of the Sea Services or by sending you an email.

Please, therefore, make sure you read any such notice carefully. Annually this Policy will be reviewed for accuracy and changes in GDPR. If no material changes are made, you will not be notified.

If you want to find out more about this Policy and how Deadeye Games B.V. uses your Personal Data, please visit the Privacy Center on RulersoftheSea.com to find out more.

15. HOW TO CONTACT US

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by using the form on the Privacy Center or by writing to us at address listed in the footer.

Deadeye Games BV is the data processor for the purposes of the personal data processed under this Policy.