Table of Contents:
1. Introduction, who we are and how to contact us
Thank you for visiting our website and even bigger thanks if you are going to download or have downloaded one of our games!
Who we are
Why you need to read this
It’s a bit like telling you to eat your vegetables. We want to do what’s best for you. When you visit our websites, download or use our games, engage with our social channels, choose to receive our marketing, take part in a promotion or otherwise talk to us, you will be giving us your information that personally identifies you in a variety of ways as described in this policy (your ‘personal data’). This isn’t about giving you the small print. It is our commitment to you that we want to protect and respect your privacy. We want to try and make it as clear as possible to you what you are agreeing to when you visit our site and when you download our games. If you have any questions, just email us at firstname.lastname@example.org and we will try and answer them!
Where we ask for your permission to process your data, please remember you can decline to give it and you can change your mind later and withdraw it. When we ask for your permission, we will always explain the consequences of withdrawing it (e.g. if it affects gameplay).
Changes to this Policy
We may need to update this Policy at any time to reflect changes in our business. All changes will be flagged in the app and on our website and if we consider it appropriate, we will notify users of important changes by email or in-app too.
Generally our App terms require users to be 18 or over to create an account with us – unless a lower age requirement (with accompanying parental consent) has been expressly stated to be acceptable for a particular App (though this will never be under 13).
Our research shows that users of our Apps tend to be over 18. We do take precautions to ensure that risks to any unauthorised users being minors are limited.
If we discover any users not meeting our age requirements, we may take all such action as we deem appropriate as explained in our terms including the termination of your account and deletion of your data. If you are a parent and have discovered your child is using one of our Apps, please contact us at email@example.com and we will help you.
2. What information will you collect about me and why do you need to use it?
What information do you collect?
We collect and use obvious information you give us. This is information about you that you give us directly when you:
- create accounts for our mobile apps
- fill in forms on our websites such as a ‘contact us’ form
- sign up to receiving our newsletters and promotions
- fill in your user profile
- enter one of our competitions or surveys
- provide any user generated content (where this feature is enabled in-app) or
- talk with us by phone, e-mail or otherwise (for example if you report a problem with our website or one of our games).
You know what information you are giving us and why we need the information as you are filling in the forms and requesting us to do things for you! But as a gentle reminder, this may include:
- Identity Data – data we need to know who you are (your name, title, date of birth and gender)
- Contact Data (the information you give us to contact you like your billing address, e-mail address and phone number)
- Marketing Preferences Data (the options you have chosen to receive marketing and communications from us)
- Profile Data (your username and password, promotions you enter, your interests, preferences, in-game friends, feedback and survey responses and other information you give us such as the contents of any correspondence you have with our customer support or technical teams in-app, through our website, social channels or by contacting us in other ways (e.g. phone or email)
- UGC Data – some of our apps also allow you to upload your own content. Please refer to our Acceptable Use Policy for how we process this. We may link UGC Data to your Profile Data.
- Location Data – Our apps generally do not use Location Data – if this is ever used, this will be flagged to you when you download the app along with an explanation of our use of that data.
Why do you use this obvious information?
We mostly use the obvious information you give us to perform our contract with you. Basically to do what you are asking of us. We need this data to administer your account registration, your entries to any promotions and to provide services that you have asked us to provide to you. It also allows us to create in-App gameplay.
We also use some of your obvious information where we need to and we have assessed there are good business reasons for us to use it which do not unfairly compromise your rights. In data protection terms, this is called being in our ‘legitimate interests’. For example, we may manage your Profile Data to gain insight into how you use our games and your gaming preferences (for example by analysing the promotions/features you like or engage with so we can show you more of those and less of the ones you weren’t interested in). Wins all round!
We may combine the obvious information with other less obvious technical types of data we collect about you such as data about your device and how you use our apps (we’ve explained this a bit more below) and together this data helps us personalise your experience with us. This is for good business reasons to ensure our apps are meeting your needs – our ‘legitimate business interests’ again.
We also collect less obvious information about you and here’s why
- Each time you visit our website or download or play one of our games, there is some clever stuff going on in the background telling us about your use of our services and this includes some automatic data capture. Some of this happens when you download and open our apps even if you have not set up an account or signed in.
- We call this clever information we learn about you ‘Technical Data’ and ‘Usage Data’. We’ve set out in full the different types of technical data we collect about you here. We only collect and use this type of data where we need to and have assessed again that there are good business purposes for doing so – for example that we need this information to improve our games and how the games appear to you, track how you played our games and used our apps so we can improve the player experience, provide you with the service as you want it, and to ensure you don’t receive irrelevant marketing stuff.
- We also use your Technical Data and your Usage Data for ads. See Marketing below.
- We may also use your Technical Data to administer our apps and for internal operations, including: troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our apps safe and secure. Finally we may use it to send you ‘push notifications’ which are pop up messages on your device to let you know of updates affecting your service (e.g. that you are the highest scorer). You can turn these off on your device.
In case you are interested (you’re probably not), your Technical Data boils down to: the IP address used to connect your device to the Internet, device unique ID, log in data (e.g. dates and times you interact with our app), your in-app actions, such as features and products you viewed or searched for in-app, response times, errors, , app interaction information (such as scrolling or taps,), the operating system, platform and device model you are using, other technology/apps on the device you are using including SDK version, timestamp, API key, application version, device identifier, iOS/Google Identifier for Advertising, locale (specific location where a given language is spoken), time zone, mobile network and network status (WiFi, etc.), general location information (not sufficient to derive city and street names), connection type (e.g. mobile data or WiFi), access status/HTTP status code, browser information (language, type and version and plug ins) and cookies, pixels, beacons, scripts and tags (see below). Technical Data may also be linked to your Usage Data – which is data about how you use the apps and our website (for example how long you spend playing a particular part of a game). Usage Data also includes data captured from you about your interaction with our communications (e.g. whether you have opened a message we have sent to you or clicked a link we have sent to you).
What about my social media?
We also collect and use Social Media Data which is data that is captured via social media channels such as Facebook and Instagram.
For example, if you use social media log ins to access your account or you use social media buttons ‘liking’ our app or you follow us on our social media channels or engage with our social media posts then depending on your privacy settings and terms of those platforms, they may share certain data with us (such as your interests) and please note we may share your email address with them. The capture of this data entirely depends on what your privacy settings are with those social networks and what they allow us to see. Please review their privacy policies carefully. It can include Technical and Usage Data (e.g. how long you were active on the social network), Location Data (what area you are based in according to your social media profile) and Profile Data (such as your general interests). We are not always able to control the type of data provided to us by the social networks but we only use what we need and think our users reasonably expect and which we assess as being in our good business interests of understanding our customers without unfairly compromising their privacy (legitimate interests).
Please remember when engaging with social media in the above ways that you are linking the information you are giving us with the information made available to us by those social channels – so please read their privacy policies and review your privacy settings.
If we offer you the opportunity to invite a friend to play a game by using the contacts from a social network service (e.g. your Facebook friends or Gmail contacts) then we will only use those contacts to send them that invitation.
We may use your Social Media Data to update your Profile Data and to target our advertising to you effectively on that social platform (e.g. so you see an ad about one of our games on your social media feed).
We use analytics providers to find out more about our digital community (for example by using unique identifiers to analyse the in-game behaviour of our players and to find out who downloaded a game after seeing our ad or to provide Aggregated Data reports such as 75% of users spent over an hour playing this part of the game.
A list of all our service providers is here. For more information please visit https://deltadna.com/privacy/ and https://www.appsflyer.com/privacy-policy/.
When you access our website, Google Analytics, a web analytics service provided by Google, Inc. (“Google“) places cookies on your device, to enable Google to provide us with activity reports relating to the website. Google uses this data only to provide us with information on how users use the website and does not associate your IP address with any other data held by Google. The information generated by Google cookies (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these analytics cookies by selecting the appropriate settings on your browser or on our cookies banner or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Sometimes, we also collect, use and share your data in a non-identifiable, anonymous way where it is grouped together with other people’s information – e.g. ‘Men aged 25-35 liked this app’. We call this Aggregated Data and although it may be created using your personal data, it is not considered personal data in law as this data itself does not directly or indirectly reveal your identity.
We may share Aggregated Data (e.g. by telling an advertiser that 500 people aged under 30 have clicked on their advertisement on any given day or use that aggregated information to help advertisers reach a particular demographic in our audience).
We do not collect any sensitive categories of personal data about you.
Camera and Photos
Occasionally our apps need to access your camera if the game relies on augmented reality (AR) but where this occurs we do not access your photos or store any images you take with your camera and we will flag this to you.
3. Data Sources and Data Sharing – Do you exchange my personal information with any third parties?
As a reminder, we share certain Social Media Data, Analytics Data and Aggregated Data as described above. There is also the following data sharing:
Appstores: We receive payment confirmations from the platforms you used to download our app which tell us if you have paid for our products (e.g. virtual currency) – We call this “Transaction Data”. We never receive or process your bank card or bank account data. We may also receive limited data about you from these platforms regarding your account or registration and this will vary according to their service so please review their privacy terms.
Service Providers: We also share your data with our service providers who need to process it in order for us to provide you with our services and the App. For a list of these please click here. These third parties are our ‘data processors’ and we will always oblige them to protect your data in accordance with the law whenever they process it.
Group Companies: In addition, we have some corporate stuff to tell you about. We hope we will grow big. So eventually, we may have a number of different group companies (we will all be ultimately owned by the same company though). If this happens, we may want to share your information around our group so they can use it for the same internal purposes as we do described above (for example we might want to store our data on one server). We will only do this where we have assessed this as being for our good business reasons and where this does not unfairly compromise your privacy (legitimate interests). This might be to ensure our content is as appropriate for you as possible, to improve our services, to ensure that our records are accurate and because some of our internal support services are shared across the group. It is also possible we could sell our business to a third party or re-organise our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business and so we would need to share it with the third party buyer and their advisers. This is in the legitimate interests of selling our business.
A full list of our group companies and their locations is here .
Law enforcement: We will cooperate with all third parties to enforce their intellectual property or other rights as appropriate. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. Our legal basis for using this data is to comply with a legal or regulatory obligation or where it is in the legitimate interests of protecting our or others’ rights.
4. Marketing and Ads
Are you going to try and flog me something I don’t want or sell my data to random third parties?
Marketing emails: If you have already downloaded our games and registered an account with us (or requested information from us about our games or entered into a promotion), the law allows us to send you marketing emails and texts about similar games we offer and it implies you have opted into this but you will always have the right to opt out of receiving these at the time you signed up with us and in every marketing message we send you. You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in the email message or by contacting us at firstname.lastname@example.org to request this at any time. We also require your express permission to send you our newsletter.
We use your Marketing Preferences Data to manage these opt ins and outs.
Occasionally, we enter partnerships with third parties to exchange information about you where we think it will give you an opportunity to get a great product or service but we will ALWAYS ask for your express permission to do this.
Are you going to hound me everywhere with ads?
We advertise our games in-app and on third party platforms such as social media. We may serve ads and promotions to you outside the App. This may or may not use your personal data. For example:
- Some of our advertising is not aimed at you specifically (e.g. an ad visible to all visitors to a social media page). This does not constitute direct marketing and does not use your personal data.
- Some of our ads may be more targeted to you if we assess this to be in our legitimate interests and not to unfairly compromise you. We use:
- profiling to identify what kinds of games, promotions or platforms you might be interested in from reviewing the data we already hold about you such as your Profile Data, Technical and Usage Data and your Social Media Data. This will not be intrusive. I.e. ‘username downloaded this app and liked our post about our other game and so we might show them an ad for it when they next log in’. Or we might want to show an ad to women age 20-30 and use the demographic data we have for this purpose to target the advertising.
- social media audiences – We use custom and look-a-like audiences provided by the social media networks we work with to target our advertising to people we think will like our games. This can involve social media platforms providing us with a general audience of users within our chosen demographic or it can be more targeted to individuals by using their email address registered across both platforms. Please review their privacy policies.
- online identifiers – We use Google Ad ID, IDFA and Advertising ID as online identifiers when permitted by those platforms. Please review their privacy policies.
Our apps may also contain third party static advertising. We don’t always include ads. Sometimes they can be annoying. But sometimes they can be quite cool and we think they can add to the player experience. And let’s be honest, we do get some revenue from the ads you click on and we use that cash to make newer more sleek versions of our games and then everyone’s happy. We might share your Aggregated Data with third party advertisers for this purpose (e.g. 75% of men who liked this game were under 30). These ads will not be targeted to you personally but will be visible to all users of the app or as part of a general demographic.
If we offer you the opportunity to invite a friend to play the app by using an in-game invitation, we will only use your contacts for that purpose but you must check with your friends they are happy to be contacted in this way.
We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5. Overseas transfers
Where do we store your personal data and for how long?
Our backend servers are located in Ireland, Germany and the United Kingdom. We will ensure that adequate safeguards are in place to protect these transfers. For a list of our group companies and their office locations, please click here.
We use third party providers to collect, export, process and store personal data on our behalf and some of these are located outside the UK and/or the EU. We only use data processors which we consider meet the minimum legal requirements required to protect your data and we ensure that applicable safeguards are in place to protect your data whenever it is sent overseas or shared with those processors. For a list of third party processors and service providers: click here. This list is updated from time to time. If you require further information about these data processors, please contact email@example.com.
Our social media partners and App Stores may have locations outside the UK and/or the EU. Please check their terms for details of their locations.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the applicable regulators or where there are adequate safeguards in place. For certain data transfers, we may use specific contracts approved by the applicable regulators which give personal data additional protections.
Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data overseas.
6. How long do you retain my personal data?
We only store your data for as long we need it for the purposes for which we collected it in the first place. Storing data costs us money! Examples of timeframes that we may use to assess when we will delete your data are when you have been an inactive customer for two years or when we consider that the risk of any legal claim is negligible. If we regard you as an inactive user, we will delete your personal data except where retention is necessary to enable us to enforce our legal rights, to comply with any laws or regulation or to protect the rights, property or safety of our employees. Generally, we will not regard you as an inactive user, if:
- you remain a registered subscriber to our mailing list;
- you remain a registered user of the app; or
- you have entered a promotion in-app or via our website in the last 3 months.
However, we will regard you as an inactive user, if you have not opened any email communication from us or interacted in any way with the app or website for 24 months.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We will also delete your data on your request though we may hold a list of the ‘opt out’ requests to administer your request. Please contact us at firstname.lastname@example.org for details of our data retention policy.
7. Security – Being safe and how we protect your data
We have put in place appropriate technical and organizational security measures that are designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. These measures include data encryption for communications between device and data centres, hardened security zones and restricted access policies. Where we keep your personal data files on local devices these devices are protected by various security measures including app packaging security requirements for publishing to App Stores, and the hardware security native to the device. We regularly review our security systems to ensure that your personal data remains safe and secure.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach.
Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee that data breaches will never occur. Please keep your password safe at all times and log out of inactive sessions.
For safety purposes, we may require players to verify their identity such as their age or email address. Don’t worry! This is only to make sure you are not a robot and that you stay safe online. We won’t use this information for unexpected reasons.
We also do not recommend that you put email addresses, URLs, phone numbers, full names or addresses, credit card details or other identifying or sensitive information in any online chat function or profile.
8. Your legal rights
Your device settings will allow you to view and adjust your privacy settings for our apps and depending on your device software, may ask you to confirm privacy choices when you first download our apps. In addition, please note you have the following legal rights:
- Right to be informed and of access. You have the right to be informed what data we hold about you and you can ask us for a copy of your personal data. To do this please contact us at email@example.com . Please note that we may ask you to specify what you wish to see in order to focus our search.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at firstname.lastname@example.org and we will correct it as soon as we can.
- Data deletion/Right to be forgotten. In some circumstances you have a right to have some of the personal information that we hold about you deleted where this is no good reason for us continuing to process it or where you successfully objected to our processing or where we have processed your data unlawfully or are required to erase it to comply with local law. Should you wish to have any information about you deleted, please let us know at email@example.com . Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. We may not always be able to comply with your erasure request for specific legal reasons which will be notified to you if applicable at the time we respond to your request. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a Wi-Fi network.
- Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller in a machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the automated information to perform a contract with you.
- Restriction of processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (if you do not feel they are legitimate) or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to still process your information which override your rights and freedoms. But we will only rarely rely on that option if we absolutely need to because we respect it is your data after all!
- Right to withdraw consent. Consent isn’t a one-off thing. If you give it to us you can have it back! If you want to withdraw your consent for any use of your data just email us at firstname.lastname@example.org. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you do withdraw your consent, this may impact your experience of our apps and we will advise you if this is the case at the time you withdraw your consent.
- Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
These rights may not always apply, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping. If this is the case, then we’ll let you know when we respond to your request.
If you wish to exercise any of the rights set out above, please contact our data privacy manager.
We may charge a reasonable administration fee if allowed by applicable law.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.
We will respond to all legitimate requests within one month.
You may complain to your local supervisory data protection authority about us depending on where you are located. In the UK, please read: ico.org.uk/make-a-complaint for details of how to do this.
10. Contacting us
If you need to get in touch you can do so either by email to: email@example.com, or in writing to Data Compliance Officer, Playstack Ltd, 56A Poland Street, London, W1F7NN, United Kingdom; and please ensure you include specific details on your request and the best way for us to get back in touch.
Well done! You’ve read the whole thing, or just skipped to the end. Remember that this document is here to help you understand our commitment to protect your data and privacy, and to ensure you know how we are using any information we collect or need to store. If you have any questions or need more information, please do get in touch.
Last Update: August 2022