PRIVACY POLICY
Last modified: 29/03/2020
OVERVIEW About
us and how to contact us Playsport provides
mobile and online games and will process your personal information when you
play our Games. If you have any questions about our data practices,
your rights or have any concerns or complaints, you can contact us at privacy@playsportgames.net, or send a letter to the
address provided in the Policy. Personal
information we collect We
collect personal information from you directly, e.g. when you play the Games
or register for an account, and also generate
information about your use of the Game, including game play and log data. If
you log in to the Game with Facebook, we will receive information about you
including your profile picture. We also receive information from other third
parties, such as transaction information. How
we use your personal information We
use your information to provide you with, support and analyse
your use of, and improve, the Game. We will also use your information to
respond to your questions. If you consent, we will send you push
notifications and show you ads in our Game that may be of interest to you.
You can choose to stop receiving these at any time, by opting out or
changing your browser or device settings. Who
we share your personal information with We
rely on third parties for the purposes set out in the Policy, such as the
provision of game servers and game analytics. We also work with certain
advertising partners to show you ads. Additionally, we share some of your
information with Miniclip SA, and other entities of our group, and as
required by law. Where
we process your personal information We are located in the United Kingdom. Some of our
providers and servers are located outside of the EEA, such as the United
States. Your
rights You
may have rights to access, receive a copy of, or delete, your information or
restrict processing of your Information, and you also have the right to
object to our use of your information for certain purposes, including
tailored marketing and advertising. You can exercise some of these rights
through the Game. Changes
to the Privacy Policy If
there are any significant changes to this Policy, we will notify you through
the Game. |
INTRODUCTION
This
privacy policy (�Policy�) informs you of your choices and our practices
in relation to your Information (as defined below). In this Policy, �Playsport�,
�we� or �us� refers to Playsport Games Ltd, a company registered
in the United Kingdom with its office located at Tempus
Court, Onslow Street, Guildford GU1 4SS. We are the data controller
under the applicable privacy laws.
For the
purpose of this Policy, �Information� means any information relating to
an identified or identifiable individual. This includes Information
relating to your use of our mobile and online games (the �Game�), and any information you may additionally provide to us,
e.g. when reaching out to us with a question. When you use the Game, you accept
our rules and policies which set out how we handle your Information, and you
understand we collect, process, use and store your Information as described in
this Policy. If you do not agree with this Policy, you must not play
the Game. If you change your mind in the future, you must stop playing the Game
and you may exercise your rights in relation to your Information as set out in
this Policy.
1. PERSONAL
INFORMATION WE COLLECT
We will
collect and use the following Information about you:
� Information you provide to us
� Information you
provide when using the Game: when
you play the Game, we may ask you to choose a username.
� Information collected when you seek support: for example, when you contact us by email, we will receive
information you provide to us such as (a) your full name and, and (b) any
information you choose to provide to allow us to assist you.
� Information
collected through surveys: we
may ask you to complete surveys about your experience. The Information we
collect from you varies depending on the survey, but we typically ask you
questions about your interests and habits, your opinion about different
products and services and what you�d like to be offered in the future. We also
collect your ratings, opinions, preferences, questions, pictures, and responses
associated with that survey.
Please make sure you have permission
from your friends before sharing Information referring to your friends with us.
� Information we automatically collect or is generated about
you when you play the Game
� Identifiers, such
as your IP address, device and app ID, unique Game ID and device information
(such as model, brand and operating system).
� Information you
generate and display when playing the Game, such as profile photos.
� Information
regarding your use of the Game, such
as date and time stamps of game events, interactions with other players
(including Facebook friends) our teams and ad engagement, and transaction
records, or evidence of you using cheating software or using of modified
versions of the Game.
� Information received from third parties.
� Information we
receive from third party platforms: when you register through Facebook, we receive your Facebook ID,
Avatar and city level location;
� Information from payment processors: when you make payments in
our Game, we receive information from our payment processors about your transactions, including your Apple ID
number for Apple, your postcode and state for Google.�
� Analytics information: we integrate certain analytics software of Playfab Inc, and Unity Technologies
(a US and Finnish company), third party
analytics providers. They provide reports that help us optimise
our in-game features and events to each user of our Game, which include your
user ID and information on your in-game activity.
� Information collected from advertising partners: we receive information from Unity Technologies.
This includes user ID and information on your interactions with advertising
shown in on our Game.
� Information from mobile measurement partners: we receive information
from third parties to allow us to track performance of our marketing campaigns
and to detect fraud in such campaigns. This includes advertising ID, IP
address, location and transaction information.
Children
Our
Game is not intended for children. �Where
children under 16 use our Game, we advise that they obtain the permission of a
parent or guardian prior to using the Game.
2. HOW WE
USE YOUR PERSONAL INFORMATION
We use
your Information to:
� Provide you with the Game. In particular, we will use your Information to perform our
contractual obligation towards you to allow you to create an account, play the
Game (including as a guest) and remember your progress, allowing you to play
the Game with others and to allow you to make purchases via Google Play or IOS
App Store and maintain a record of such purchases. The Information we process
when doing so includes your registration information, information you provide
to us when playing the Game, identifiers, information you generate and display
when playing the Game, and information regarding your use of the Game such as
transaction records.
� Improve and monitor Game use. It is in our legitimate interests to improve our Game for our
customers. When doing so, we may collect information we automatically collect
or is generated about you when you play the Game.
� Provide you with support and to respond to your requests or
complaints. If you
reach out to us for support, we will use your Information to respond to and
resolve your queries and complaints. When doing so, we perform our contractual
obligation towards you. The Information we process when doing so includes your
registration information, your identifiers, non-personal information about your
device such as model, brand and operating system, and any other information
about you collected via our customer support channels.
� Conduct analytics. It is in our legitimate interests to analyse
the use of, and any other interaction or interest in our Game or advertising
campaigns. When doing so we will process information we automatically collect
or is generated about you when you play the Game to create anonymised and aggregated data.
� Provide you with advertising. We will present you with ads and suggestions in our Game and
elsewhere. These may be ads relating to our own games or other services you may
be interested in. Depending on your consent, or device or browser settings,
these ads and suggestions may be tailored. If you no longer want to
receive targeted advertising in the Game you can
opt-out in the Game. To stop receiving ads about our products and services
elsewhere you can change your device and browser settings. To tailor ads and to
allow our advertising partners to tailor ads, we process information we
automatically collect or is generated about you when you play the Game and
information received from third parties.
� Prevent fraud, defend Playsport against legal claims or disputes,
enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our users against
online abuse and other anti-social or illegal activity. Furthermore, it is also
in our legitimate interest to protect our interests by (1) monitoring Game use
to detect fraud or any other user behaviour which
prejudices the integrity of our Game, (2) taking steps to remedy aforementioned
fraud and behaviour, (3) defending ourselves against
legal claims or disputes, and (4) enforcing our terms and policies. When doing
so, we will process the Information relevant in such a case, including
information you provide us, information we automatically collect about you, and
information which is provided to us by third parties.
� Conduct surveys. From time to time, we may ask you to participate in surveys we
conduct which are in our legitimate interest because they help us understand
our userbase and improve the Games. If you participate, we process your registration
information and any other information collected through the survey questions.
3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We
share your Information with selected third parties, including:
� Cloud service providers who rely on for data
storage, including Playfab who are based in the U.S.
and store our data in a number of locations including within the EEA and in the
US;
� Analytics providers. We
work with a number of analytics and mobile measurement
service providers who help us understand our userbase. This includes Adjust
GmbH, who are based in Germany, Game Analytics ApS,
based in Denmark, and Miniclip SA, based in Switzerland..
� Social media.
we integrate certain Facebook software to enhance social media features in the
game such as accessing your friends list and displaying your profile picture.
Third
Party Privacy Practices
If you
access the Game through a third-party platform such as Facebook (�Third
Party Services�), you must understand that those Third Party Services may
collect other information about you (including information you share with them
directly or about your use of the Game) in accordance with their own terms and
privacy policies. The privacy practices described in this Policy do not
apply to Third Party Services. Any links in the Game to Third Party Services do
not imply that we endorse or have reviewed the Third Party
Services.
Security
Although
we have in place security measures to maintain the privacy and integrity of
your Information, unfortunately, the transmission of Information via the
internet is not completely secure. Although we will do our best to protect your
Information, we cannot guarantee the security of the Information transmitted to
us through the Game or otherwise. Any transmission of your Information is at
your own risk. We may also take extra steps to protect your Information and minimise the Information we process.
4. WHERE WE PROCESS YOUR PERSONAL INFORMATION
Your
Information will be processed by our employees and service providers in the
European Economic Area (�EEA�) and the United Kingdom. Because
countries outside of the EEA may have different data protection laws, we take
steps to ensure that where your Information is transferred outside of the EEA,
such transfers are protected by adequate safeguards, including the standard
contractual clauses approved by the European Commission, and the
EU-U.S. Privacy Shield scheme for transfers from the EEA and
the UK to the U.S.
5. HOW LONG WE STORE YOUR PERSONAL INFORMATION
Your
Information is kept for as long as you are registered and using our Game, and
then for up to three years from the date you stop interacting with the Game. Some
information we collect will be stored for longer where we have an overriding
legitimate interest to retain such information (for example, information on
suspicious behaviour of certain users of our Game,
about users which are banned from using the Game, and transaction records).
When
deleting Information, we will take measures to make the Information
irrecoverable or irreproducible, and electronic files which contain Information
will be deleted permanently.
6. YOUR RIGHTS
If you
are based in the EEA, Switzerland or are a legal resident of California in the U.S.,you have certain rights in
relation to your Information. For Californian residents, please refer to
Addendum 1 � California Privacy Rights [link]. For EEA and Switzerland based
players, you will find more information below on when which rights can apply.
To
exercise your rights, please follow the procedure set out below or email us at privacy@playsportgames.net.
Note that where the Information is
held by a third party data controller, such as an advertising partner or a
payment processor, we will use reasonable steps to inform them of your request,
but we recommend you contact them directly in accordance with their own privacy
policies to ensure your personal data is erased.
� To stop
receiving targeted advertising:
withdraw your consent through the Game Settings.
� To stop
receiving push notifications:
please change your device or browser settings.
� To object
to all other processing based on our legitimate interests, please email privacy@playsportgames.net. Please note that we may have an
overriding legitimate interest to keep processing your Information, but we will
let you know where this is the case.
�
Portability. You
have the right to receive a copy of Information we process on
the basis of consent or contract in a structured, commonly used and
machine-readable format, or to request that such Information is transferred to
a third party.
7. CONTACT & COMPLAINTS
We
welcome questions, comments and requests regarding this Policy. These should be
addressed to privacy@playsportgames.net. You can also send a letter to Data Protection at Tempus
Court, Onslow Street, Guildford GU1 4SS
If you
wish to make a complaint about how we process your Information, please contact
us at privacy@playsportgames.net and we will endeavour
to deal with your complaint as soon as possible. This is without prejudice to
your right to launch a claim with a data protection authority.
8. CHANGES
If we
make any material changes to this Policy, we will post the updated Policy here
and notify our users through the Game. Please check this page frequently to see
any updates or changes to this Policy.
ADDENDUM 1 � CALIFORNIA PRIVACY RIGHTS
The
terms of this Addendum apply to residents of California under the California Consumer
Privacy Act (�CCPA�) and related applicable laws.
Collection and Disclosure of
Personal Information
Over
the past 12 months, through your use of the Games, we may have collected and
disclosed the following categories of personal information, as defined in the
CCPA, from or about you:
�
Identifiers,
including name, email address, IP address, device identifiers, advertising ID, Playsport
ID, and profile photos. This information is collected directly from you or your
device.� If you have registered through a
third party account (e.g. Facebook or Apple), we may
have also collected from those third party services your third party ID, name,
and avatar.
�
Internet
or other electronic network activity information, including your use of in-game features and
events and information on your in-game activity, and information
on your interactions with advertising shown in on our Games. This information is collected from our selected third
party analytics providers and advertising partners.
�
Geolocation
data, including city level location data. This information is collected
directly from you or your device and from third party services when you
register through them.
�
Commercial
information, including records of products or services purchased, obtained, or
considered, your Apple ID number for Apple, your
postcode and state, user ID and email address for Google transactions. This information is collected directly from you or
your device, and from our payment processors.
We
collect personal information for the following purposes:
For
additional information about what each type of personal information is used
for, see �How We Use Your Personal Information� in the main portion of
the Privacy Policy.
We
may disclose personal information to the following types of entities:
SALES OF PERSONAL INFORMATION
Over the past 12
months, we have used third party advertising and other tracking technologies on
our Games to collect information about you, your device(s), and your use of our
Games.� We share that information with selected
third parties such as advertising partners who use it to target advertisements
to you online.� To opt-out of the �sale�
of personal information, (�Do Not Sell My Personal Information) you can use the
in-app settings.
Rights under the CCPA
The CCPA provides California
residents with certain legal rights; these rights are not absolute and are
subject to certain exemptions. If
you are a California resident, and the CCPA does not recognize an exemption
that applies to you or your personal information, you have the right to:
We aim to fulfill all verified requests within
45 days pursuant to the CCPA.� If
necessary, extensions for an additional 45 days will be accompanied by an
explanation for the delay.
How
to Exercise Your Rights
You can exercise your rights by using the in-app settings or by
emailing us at privacy@playsportgames.net