INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products and services developed and/or published. ( / “we” / “us”). Our registered office is at 64 Southwark Bridge Road, London, SE1 0AS.
Together, the Games, Websites and Communities are referred to herein as the “Online Services”.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal data you have provided to us.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
- INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following personal data from you when you use our Online Services (together, the “Submitted Information”):
|Information provided by you when using a Game(“Game Information”)
§ Your mobile device’s unique device ID (“Device ID“) (for our mobile Games only);
§ Your user avatar (where applicable in Games and Communities only);
§ Your user ID (where applicable); and
§ ‘Events’ related to your gameplay in our Games, such as your achievement of a milestone, the occurrence of other particular events during your gameplay (such as completing a tutorial, game level, making a purchase or viewing an advertisement).
|Information provided by you when using the Communities or that may be provided by you when you contact us for support(“Contact Information”)
§ Your name;
§ Your email address; and
§ Your password (for Communities and where applicable only).
|User-generated content hosted and displayed in our Communities (for example, posted by you in our forums)(“User Content”)
When using our Communities, you may decide to post information that may or may not contain personal data, in accordance with the rules applicable to our Communities (such as the relevant forum rules). We cannot control the wider dissemination via the public internet of such personal data that you may choose to post.
|Information about your activities(“Analytics”)
We may collect technical information about your use of our Websites or Communities through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
§ your IP address and MAC address;
§ device information (e.g. device identifier and browser)
§ game results, progress and timings; and
§ page usage (e.g. buttons clicked, screens viewed).
This also includes the use of ‘cookies’.
The following cookies are used on the Websites:
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. To opt out of being tracked by advertising providers you can access a general opt out at http://www.networkadvertising.org/managing/opt_out.asp
|Information about you collected from third parties (“Third Party Account Information”)
If you choose to access or log into our Online Services (including without limitation our Games) via a third party social media platform such as Facebook, we may collect and store personal data and other information made available by that third party platform, such as your profile username, profile picture, user ID and public information about your friends.
We may also collect technical information in order to ensure that our Online Service connects correctly with your social media user account. This information may be obtained via a Facebook cookie or other similar device in our Online Service. The third party platform is responsible for obtaining your consent before sharing such data with us.
- WHY WE COLLECT INFORMATION ABOUT YOU
To enable in-Game purchases
If you make purchases through the Online Services, your order and Game Information may be processed so that you can access these features within the Games.
For the above purposes, we rely upon the legal basis of performance of a contract.
|To provide the Communities and Preventing SpamCertain Game Information and User Content which you supply through our Online Service may be shared with other users of the Online Service. In some cases you may be able to select specific recipients (for example, if you are sending a forum post, or a private message, to a particular forum or individual) then only those recipients will receive it, however in all other cases, your information may be made publically available.
We may make your Game Information and User Content available to forum moderators. Moderators are crucial to the Communities and help make them the place that they are. Moderators are directed to only act in accordance with our instructions and to adhere to the moderator rules.
Spam is a problem for many forums and websites. In order to minimise this we use Stop Forum Spam to check that any new registration is not spam. In order to do this certain information is provided to Stop Forum Spam for the sole purpose of checking that it is not spam. You can find out more about how Stop Forum Spam use this information on their website available here: https://stopforumspam.com/privacy
For the above purposes, we rely upon the legal basis of performance of a contract and our legitimate interests, being our commercial interests to moderate the services and to prevent spam.
As part of this we may also share this Submitted Information with the developers of the Games that we publish.
For the above purposes, we rely upon the legal basis of performance of a contract and our legitimate interests, being our commercial interests to respond to your queries and requests for support.
|For advertising purposesFor some of our Online Services, we may process Submitted Information to show you advertisements for third party services. Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not. For advertising on our Online Services your personal data is processed for this purpose on the basis of our legitimate interests, being our commercial interests for advertisement-supported services.
For some of our Online Services, Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data.
Some of our Online Services integrate with AdSense, Google Analytics and GG Software. Analytics data will be processed and tracked by those third party services, and you can find out more about the way they use this information at the following locations:
· Google Analytics and AdSense https://support.google.com/analytics/answer/6004245?hl=en
|To prevent fraudulent or illegal activityWe may process your Submitted Information for our legitimate interests of ensuring that your use of our Online Services is lawful, to prevent disruption to our Online Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.|
|To help us to improve the Online Services and help us fix any problems We may process information about you (being the Submitted Information or any part thereof) so that we can analyse and improve our Online Services.
This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Games and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Online Services.
|To help us to understand your usage of the Online ServicesWe may process information (being the Submitted Information or any part thereof) to understand how users use our Online Services, and to compile statistical reports regarding that activity, as well as understanding how users progress within a particular Online Service such as a Game. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems (such as when users may frequently be ‘stuck’ in a particular Game level) and to improve our future products and services.|
|To keep you up to dateWhere you have consented to receive such news and products, we use your Submitted Information to send you emails in order to keep you informed of news and products. To do these we use our internal process and may use Mailchimp. You can find out more about how they process personal data here:|
- DATA SHARING
Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal data to third parties (e.g. mobile network operators, gaming platform operators, game console manufacturers or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety, our customers or others.
Digital Content Stores: Where our Game is downloaded through a third party store service such as Google Play or Apple’s App Store, we may disclose your personal data to Google and/or Apple respectively for the purposes of facilitating any in-Game payments made through these platforms.
- AUTOMATED DECISION MAKING
- CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act.
We therefore will not distribute your personal data to outside parties without your consent.
As part of the California Online Privacy Protection Act, all users of our Websites may make any changes to their information at any time by logging into their control panel and going to the ‘Edit Profile’ page.
- CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly. If you are using an iOS device, you can opt out of personalised adverts by visiting https://oo.apple.com
We will obtain your consent to collect your information to be used for marketing purposes that require consent. If you prefer that we do not use your data in this way, let us know or on the relevant forms or check-boxes that we may use to collect your data.
- YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply to requests without undue delay and within one month at the latest.
To make a request, please let our Data Protection Officer know
|Ask for a copy of data we are processing about you and have inaccuracies correctedYou have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.
You can download a copy of your Game account information by following the instructions in your account settings.
We will use reasonable efforts, to the extent required by law, to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).
|Objecting to us processing data about youYou can ask us to restrict, stop processing or delete your personal data if:
· you consented to our processing the personal data and have withdrawn that consent;
· we no longer need to process that personal data for the reason it was collected;
· we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
· the personal data was unlawfully processed;
· you need the personal data to be deleted in order to comply with legal obligations; and/or
· the personal data is processed in relation to the offer of a service to a child.
You can delete your accounts by following the instructions in your account settings.
|Obtain a machine-readable copy of your personal data, which you can use with another service provider
· If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
· If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
|Make a complaint to a Supervisory Authority
· If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
· If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
- DATA RETENTION
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Online Services; any transmission is at your own risk
- INTERNATIONAL DATA TRANSFERS
Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data. If you require more information about these safeguards, you can contact us