PRIVACY POLICY
Last updated 10/8/2021
This privacy policy applies to all information collected through our website, games and applications, (“Apps“), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites“).
1. WHAT INFORMATION DO WE COLLECT?
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed for our internal analytics and reporting purposes. Your information will be aggregated when used for analytics; in no case will we identify you from this data.
In our games and Apps, we may collect game-specific information as necessary for multiplayer gameplay features. We may also collect personal information such as a username when necessary for multiplayer features.
2. HOW DO WE USE YOUR INFORMATION?
We use information collected via our Sites or Apps to analyze our audience and to run and improve our products. We do not use this information for advertising, nor do we sell your personal information.
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
In our games that are built with the Unity game engine, Unity Technologies SF may collect personal information as well. For more details, see their privacy policy here: https://unity3d.com/legal/privacy-policy?_ga=2.215862548.2042178572.1587670025-1426149600.1523380172
In our games that are built with the Photon Bolt multiplayer framework, your data may be shared with Exit Games Inc. for the purpose of facilitating multiplayer gameplay, but this data is not stored. For more details, see the Exit Games Data Processing Addendum: https://dashboard.photonengine.com/en-US/Account/DPA
5. HOW LONG DO WE KEEP YOUR INFORMATION? HOW CAN I REQUEST THAT MY DATA BE DELETED?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 3 years.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you wish to have your data deleted, you may email a request to that effect to e@emcneill.com. Within 30 days, we will subsequently delete any collected data and contact any relevant third parties to request that they delete any of your personal information as well.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To opt-out of interest-based advertising by advertisers on our Sites or Apps visit http://www.aboutads.info/choices/.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
9. DO WE MAKE UPDATES TO THIS POLICY?
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
10. HOW CAN I REPORT A SECURITY VULNERABILITY?
If you have discovered a security vulnerability in our Sites or Apps, please contact our DPO via the email address provided below with a description of the vulnerability.
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Edward McNeill, by email at e@emcneill.com, or by post to: