1. Overview and Data Controller Identity

CyberMind Co. Ltd ("CyberMindCo", "we", "us", or "our") operates as the data controller responsible for the processing of personal data collected through our digital portal domain CyberMindCo.com. Our company is incorporated and registered under UK commercial laws, with our principal operating headquarters located at Lower Rd, London SE16 2XB, United Kingdom. Designated company representative: Jean Anderson. Official data privacy inquiry contact: cybermind@atomicmail.io.

We are dedicated to safeguarding the privacy rights of users visiting our platform from all geographic regions ("Multi-Geo"), adhering strictly to applicable data protection frameworks including the UK Data Protection Act 2018, General Data Protection Regulation (GDPR - EU 2016/679), and international data privacy statutes.

2. Scope and Information We Collect

We process personal and technical data to deliver optimized game distribution services, account verification, and analytics. The categories of information collected include:

  • Directly Provided Information: When you register for access or submit a lead request, we collect your designated commander nickname, contact email address, country of residence, and age verification confirmation.
  • Automated Interaction Data: During website navigation, our servers log technical data such as your IP address, browser architecture, operating system, language preferences, referring domain, and timestamp.
  • Analytics & Event Click Telemetry: When users interact with promotional CTA elements such as "Play for Free on PC", specific event data points (including the offer_click event object) are dispatched to our analytical layer (window.dataLayer) to monitor campaign conversion rates without identifying individual users.

3. Legal Bases for Processing Data

Under European and UK data protection frameworks, we process your personal data based on legitimate legal grounds:

  1. Consent: Where you have explicitly opted into receiving promotional communications or allowed non-essential performance tracking cookies.
  2. Contractual Performance: Processing required to grant starter pack access, account creation, or service fulfillment upon clicking offer registration links.
  3. Legitimate Interests: Securing our web infrastructure against fraudulent traffic, bot activity, and network attacks while analyzing user engagement to enhance gameplay delivery.

4. Data Sharing and Third-Party Disclosures

CyberMind Co. Ltd strictly refrains from selling or renting personal user records to third-party data brokers. Data disclosures are restricted to authorized operational partners under legal binding contracts:

  • Game Publishers & Franchise Partners: Official game client distributors (e.g. Wargaming.net) receive technical registration leads to generate player accounts and award starter bonuses.
  • Cloud Infrastructure Providers: Secure hosting environments located within accredited datacenters in the UK and European Economic Area.
  • Regulatory & Legal Authorities: Disclosures mandated by law enforcement mandates or statutory compliance orders.

5. International Data Transfers

As a multi-geo operational platform, information collected may be processed or stored outside your country of residence. When transferring data from the EEA or UK to third jurisdictions, CyberMind Co. Ltd enforces approved transfer mechanisms, including Standard Contractual Clauses (SCCs) and robust encryption standards, ensuring protection equivalent to European standards.

6. Retention Period and Data Security

We maintain technical and organizational security measures (256-bit TLS encryption, strict access controls, isolated database clusters) to protect personal records against unauthorized access, destruction, or disclosure. User lead records are stored for a maximum period of 24 months, after which they are securely scrubbed or anonymized.

7. Your Statutory Privacy Rights

Subject to local legislation, you possess comprehensive statutory rights regarding your personal records:

  • Right to Access: Request a complete copy of personal records held by CyberMind Co. Ltd.
  • Right to Erasure ("Right to be Forgotten"): Request immediate deletion of your registration profile.
  • Right to Rectification: Request correction of inaccuracies in your contact records.
  • Right to Data Portability: Obtain your data in a structured, standard machine-readable format.
  • Right to Object: Withdraw consent or object to automated profiling activities.

To exercise any statutory privacy right, direct your written request to Jean Anderson, Data Governance Lead, CyberMind Co. Ltd, Lower Rd, London SE16 2XB or via email at cybermind@atomicmail.io.