PRIVACY POLICY

Last modified: 9 July 2018

SUMMARY

Contact

Playsport Games Ltd is the data controller of data processed through your use of the Game Services.  If you have any questions about this Privacy Policy, wish to exercise any of your rights under it or have any concerns or complaints about how we use your personal data, please contact http://www.playsportgames.com, or alternatively you can send a letter to Data Protection, Playsport Games, Waltham House, 5-7 St Mary’s Terrace, Mill Lane, Guildford, Surrey.

What information do we collect about you?

As most of your information when you play one of our Games is stored on your device, or with the cloud service offered by IOS or Google Play, and is not passed back to us, we collect limited data from and about you.  We and our group company Miniclip collect analytics data about you, including device and advertising IDs and in-game event information.

How will we use this information?

Google Play and IOS use your information to provide the Games to you.  We use your information to support and improve the Games, and for our own limited analytics purposes.  We retain your data for as long as necessary for the purpose for which it was collected, in accordance with our retention policy.

Who do we share your information with?

We use third parties for analytics. We use these third party services solely to process or store your information for the purposes described in this policy. We also share your information with our related group companies and as required by law.

Where do we process your information?

Our servers are located in the United Kingdom. Our support, engineering and other teams are also located in the United Kingdom.  The third parties with whom we share your data will process the data outside of the EEA, including Switzerland and the US.

How can I exercise my rights over my information?

You may have rights to access, receive copy of, or delete, your data or restrict or object to our processing of, your data.  

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will post a notification of such change in the Game Services.

INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information of yours that we process. Your use of mobile games published by us (including Motorsport Manager) (the “Games”) and our website http://www.playsportgames.com (“Website”) involves the collection and use of your personal information.  It is important for you to understand how this happens and how you may control it. When you use the Games or use the Website (the “Game Services”), you accept our rules and policies regarding your personal information and you expressly agree to us collecting, processing, using and storing your personal information, as described in this policy.

You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

Playsport Games Ltd (“Playsport”, “we” or “us”) is a company registered in the United Kingdom with its office located at Westbury House, 15 Bury Street, Guildford, Surrey GU2 4YZ.  We are the data controller of your data when you use the Game Services. If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at privacy@playsportgames.net.

 

THE TYPES OF PERSONAL INFORMATION WE USE

During game play, all data that you provide (being just your nickname should this be an option in a Game, and should you choose to provide it) and all game play data generated (including scores) are stored on your device, and if you choose to sign in to Google Play Games services or the IOS Game Centre on the cloud provided by your Android or IOS operating system.  We will not have access to such data.

We collect limited information about you.  Our service provider Adjust automatically collects certain data from you when you use the Games and information regarding your use of the Games, such as device and advertising identifiers date and time stamps of game events. If you are using one of our Games on Android and make in-app purchases, Google may make available to us certain information about you including email address and details of your purchases, but we choose not to receive or access such data.

Cookies

We do not currently use cookies or any similar technologies (e.g. web beacons, log files, scripts and eTags) on our Website.

Children

Our Service is not intended for children. Children must not use the Service for any purpose.

Persons under the age of 16 are required to obtain parental/guardian consent prior to using the Game.

 

HOW WE USE YOUR PERSONAL INFORMATION

We will use the information in the following ways and in accordance with the following legal bases, and will retain your information as described below (except if otherwise required to be retained by applicable law):

Purpose

Personal Data

Legal Basis for Processing

Retention Policy

Marketing and promotion of our Games To track where our users come from and the success of our games. 

Device ID, device information, time stamps of interactions, advertising ID

It is in our legitimate interest to promote our games to appropriate audiences, ensure current users aren’t retargeted via suppression lists and to attribute activity to such promotional activities.

Stored for up to 5 years, or otherwise 30 days of a lawful request from you for the erasure of such data (see Erasure below).

Validation of analytics data to detect tech issues and fraud.

Device ID, device information, time stamps of interactions, advertising ID

It is in our legitimate interests to ensure the tracking of any campaigns is not subject to fraudulent activity.

Stored for up to 5 years, or otherwise within 30 days of a lawful request from you for the erasure of such data (see Erasure below).


Personal Information is kept in accordance with the Retention Policy above, and after that such data is destroyed.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

 

HOW WE STORE AND SHARE YOUR PERSONAL INFORMATION

In order to perform our contract with you, your personal information will be accessible from and will be processed by our employees and on our servers located in the United Kingdom.

We share your personal information with selected third parties in and outside your country, including:

Although we have in place security practices to maintain the privacy and integrity of your personal information, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

 

YOUR RIGHTS

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at http://www.playsportgames.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold personal information about you, please email us at http://www.playsportgames.com with details of what information you believe we hold and would like access to.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at http://www.playsportgames.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please email us at http://www.playsportgames.com.

You may request that we erase the personal information we hold about you in the following circumstances:

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

We will need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You may request we stop processing and just store the personal information we hold about you where:

Objection

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at http://www.playsportgames.com.

Contact & Complaints

Questions, comments and requests regarding this policy are welcomed and should be addressed to http://www.playsportgames.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance http://www.playsportgames.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority – this may be the Information Commissioner which is the authority where we operate by calling +44 (0)303 123 1113, or alternatively in the country in which you live or work - where you think we have infringed data protection laws. 

Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users within the Game. Please check this page frequently to see any updates or changes to this policy.