PRIVACY AND DATA POLICY
ISSUED BY KWALEE LIMITED
Last Updated: August 2022
These terms apply to the use of games and other products developed by Kwalee Limited (‘Kwalee’ / ‘we’ / ‘us’). Our registered office is at Kwalee Ltd (c/o Ricardo), Midlands Technical Centre, Southam Road, Radford Semele, Leamington Spa CV31 1FQ. We are a company registered in England, with company number 07648078.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
We collect and process the following information which may include your personal data.
Information provided by you when using the Games
We will collect the following information from you when you play our Games:
For early access to Games this may also include:
Information used for the purposes of serving advertisements
Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:
Information collected for the purposes of providing analytics
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
Information about you collected from third parties
(“Third Party Log In Information”)
When you access the Games via a third party social media provider such as Facebook, Twitter or Game Center, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook or Twitter name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook cookies within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.
Information about you collected from third parties
To provide our Games to you
To help us improve the Online Services and fix any problems
We may process non identifiable Analytics so that we can analyse and improve our Games and Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Online Services and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.
We use third party providers Fabric (for crash analytics), AppsFlyer and Tenjin (user attribution and analytics), Game Analytics and AppOnboard (for analytics). Fabric, AppsFlyer, Tenjin, AppOnboard and Game Analytics may collect analytics on our behalf and in accordance with our instructions, and their applicable privacy notices.
If you would like to find out more about the way Fabric, Tenjin, AppsFlyer, Game Analytics and AppOnboard collects and processes this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://docs.fabric.io/android/fabric/data-privacy.html, https://www.appsflyer.com/privacy-policy, https://apponboard.com/legal/privacy-policy/, https://www.tenjin.io/privacy/, https://gameanalytics.com/privacy
To improve the monetisation via in-app purchases
Skillz may process information (including Skillz Information) to understand how users use our TENS Tournament, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within the game. This processing is necessary for us and Skillz to pursue our legitimate interests of improving the game and increasing the amount of revenue generated via in-app purchases.
For advertising purposes
We may process Advertising Data to show you advertisements for third party services.
The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements.
We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may with Looper! at any time. We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks :
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
To prevent fraud and illegal activity
We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Kwalee, our customers, or others.
Skillz: where you play TENS tournament game, the Skillz Information may be shared with our partner Skillz for the purposes described in section 3.
We process your personal information via automated decision making methods in order to identify users who are cheating in the Games. We may block users from the Games and/or the Online Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Games and/or the Online Services.
If you do not wish to receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly.
You can withdraw your consent by changing your advertising settings on your device or by deleting the Game at any time.
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let us know by sending an email to email@example.com.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
Obtain a machine readable copy of your personal data, which you can use with another service provider
Make a complaint to a Supervisory Authority
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases contain encrypted and anonymised information only, are password protected and limited to essential employees only (such as Kwalee management or employees whose main role requires system access).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
It is possible that your personal information may be transferred outside of the EEA by Ad Networks or to Skillz. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.
Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to firstname.lastname@example.org.
All questions, comments or enquiries should be directed to Kwalee at email@example.com. We will endeavour to respond to any query or questions within three business days.
© 2022 Kwalee Limited. All trade marks are the property of the relevant owners. All rights reserved.