Last updated: 18 March 2021
I. DATA COLLECTION
We may collect information from or about you when you download or use the Game. We only receive very limited data about you. In order to play or use the Game, we collect (i) your Apple Game Center ID, (ii) your progress in the Game, and (iii) information about your play activity. On its own, the Apple Game Center ID cannot identify you, nor can it be used to identify you if coupled with any other data we hold about you. If you do not want us to collect this information, then you must delete the Game from your device and, if you have enabled saving information in iCloud, from iCloud.
In addition to the Game Center ID, a unique token (“User ID”) may also be created about you which is held and controlled by us. We process this token in order to provide multiplayer functionality and other online functionality within the Game, such as level creation and communicating with our backend services. We cannot identify you from the information we hold.
You can turn off tracking of this information in the Game’s settings menu; however, if you turn tracking off, certain features of the Game will not work. For example, you will not be able to upload content you create for other users to use, and you will not be able to play the Game with other users.
Apple provides us with non-identifiable data provided to help us understand usage of our game (e.g., App Analytics and audience engagement).
A. KIDS’ DATA COLLECTION
We handle data from children under 13 years of age, or the equivalent minimum age in the child’s relevant jurisdiction, in the same way as other users and as described in this Policy. We limit our data collection and use persistent identifiers to support the internal operations of the game only. If you are a parent, you can decline to have that data collected from your child by turning off data collection for our Game and signing your child out of Game Center. If you wish to request deletion of the data we have collected as described in this Policy, send your solicitation to email@example.com.
II. DATA USE
We use the information collected about you for the following purposes:
- Providing, administering, and facilitating your use of the Game, including:
- User/Gamer ID (in our Services): used for identifying each player in our databases to facilitate interaction with our backend services;
- User Data Secret: a unique, randomized string assigned for each user in order to secure private user data in the Game;
- Game Center User ID: for player identification and support (e.g., account recovery);
- Game Center Username: displayed during multiplayer gameplay and associated with any content you create for the Game (e.g., home base or game levels);
- Information required for storing your player progression, preferences and user content creation;
- Information for helping other players identify and locate any content you create; and
- Anonymized non-identifiable data (for example: averaging the time it takes for players to finish each adventure for the purposes of calculating the XP value of each adventure and letting you know how long it takes, on average, to complete those adventures).
- Data purging: deleting your data after a period of inactivity or for any other reason at our sole discretion (for example, upon a user’s request, we may remove a user’s individual data, game progress, created content, or online play modes); and
- Trouble-shooting errors or issues with the Game.
III. DISCLOSURES TO THIRD PARTIES
We will not share data about you to third parties for those third parties’ own purposes. We will only share your information (including personal information, if any) with the following third parties or under the circumstances described below.
- We will also share your information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners like Apple. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).
- Where we, in our sole discretion, have a good faith belief that disclosure is necessary in order to:
- to satisfy any laws or regulations that apply;
- when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
- when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
- Business transfers, sales or mergers or divestitures.
IV. DATA RETENTION
Please note that if you store information locally on your wireless device and/or in the iCloud then information may remain there. If you would like to delete your information from your wireless device or iCloud, please follow the instructions provided by your wireless device provider or Apple.
V. DECLINING OR WITHDRAWING PERMISSION FOR DATA AND DATA SUBJECT RIGHTS
You have rights to request access to, modification of, and deletion of any information we have collected about you or from you. To make a request, please contact us as described below in the Contact Information section.
We also receive information from Apple and from your device. To manage the information we receive about you from Apple or your device, please follow the instructions provided by Apple or your device provider for updating your information and changing your privacy settings. Once we receive your information from Apple or your device, that information is stored and used by us in accordance with this Policy.
If you are a California resident and we have collected personal information (as defined in the California Consumer Privacy Act) about you, then, starting January 1, 2020, you may also request that we:
- Provide you the categories of personal information we collect and disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Policy.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.
If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us as described in the “Contact Us” section below. We will consider all requests and respond within the time period stated by applicable law. Please note your rights and choices vary depending upon your location, and that we may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Game to you or to comply with a legal obligation. And if you ask us to delete certain information, you may no longer be able to access or use the Game.
B. NEVADA CONSUMERS
VI. HOW WE PROTECT INFORMATION
We implement commercially reasonable security measures to protect your information from unauthorized access. We further protect your information from potential security breaches by implementing certain technological security measures including encryption and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. By using our Game, you acknowledge that you understand and agree to assume these risks.
Any login credentials to your wireless device or Apple Arcade subscription, such as a username or password, are important security features. As such, it is your responsibility to protect such credentials. Do not share your password with any third parties. If your password has been compromised for any reason, you should change it immediately.
VIII. CONTACT INFORMATION