Last modified: 29/03/2020
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 email@example.com, 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.
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.
If there are any significant changes to this Policy, we will notify you through the Game.
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
ü Information you provide when using the Game: when you play the Game, we may ask you to choose a username.
ü 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.
ü 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
ü Identifiers, such as your IP address, device and app ID, unique Game ID and device information (such as model, brand and operating system).
ü Information you generate and display when playing the Game, such as profile photos.
ü 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.
ü Information we receive from third party platforms: when you register through Facebook, we receive your Facebook ID, Avatar and city level location;
ü 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.
ü 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.
ü 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.
ü 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.
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:
ü 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;
ü 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..
ü 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.
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 firstname.lastname@example.org.
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.
ü To stop receiving targeted advertising: withdraw your consent through the Game Settings.
ü To stop receiving push notifications: please change your device or browser settings.
ü To object to all other processing based on our legitimate interests, please email email@example.com. 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 firstname.lastname@example.org. 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 email@example.com 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.
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:
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 firstname.lastname@example.org