Last Updated: 01 February 2021
This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our games for which we make this policy available (each a “Game”). This Policy also applies for our websites where we make this Policy available (each a “Website“). Our Games and Websites are together the “Services”. Please read the Policy carefully to understand our views and practices regarding your personal data.
We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including without limitation the Data Protection Act 2018 and the UK GDPR (as defined in the Data Protection Act 2018). Where we decide the purpose or means for the processing of the personal data that you provide when using our Services, we are the “data controller”.
You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
If you have any concerns over privacy, or this Policy, contact us at email@example.com.
1. how we collect and use your personal data
1. The table below explains what data we collect, how we use it, and which recipients it might be shared with.
How we use it
Third Party Recipients
Game support / enquiry information (information we receive when you get in touch with us for support through the Game or by email):
· Email address; and
· Other personal data you choose to send to us.
Website support / enquiry information (information we receive when you get in touch with us via our Website):
· Contact details (address, phone number, email); and
· Other personal data you may send to us.
In line with the legitimate interest we have in promoting our business, we will process your enquiries to provide you with information about the services we offer.
This might include replying to your enquiry. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services.
You are under no obligation to provide us with any details, but if you don't provide all relevant information, we may not be able to help.
Website analytics and usage information (collected automatically when you visit the Website):
When you visit our Website, we collect log and analytical information, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use (“Website Technical Data”)
We process this information to understand how visitors use our Website and to compile statistical reports regarding that activity (for example, your IP address is used to approximate the country from which you access our Website, and we aggregate this information together so we know that, for example, most of the visitors to our Website are in England). In many cases the data would be aggregated and/or anonymised so that it would not identify you.
To the extent this data includes your personal data, we rely upon our legitimate interests to process it, being our interests in promoting the success of our business.
We may receive data about you from Google, Inc. (based outside the EU) through their Google Analytics technologies. You can read more about their privacy practices here.
Game analytics and usage information (collected automatically when you play the Game, or which may be available to us from Game platforms / stores):
· IP address;
· Location (country and city);
· Country of install and language;
· Unique device ID, hardware manufacturer and model;
· Operating system and version;
· Relevant Game and version; and
· 'Events' related to Game usage, such as progress, achievement of a milestone and the occurrence of other particular events during your Game usage (such as Game installation/uninstallation, play session durations and choices/selections for different parts of the Game, interactions with Game content and timestamps),
(“Game Technical & Usage Data”).
We may collect this data so that we can understand usage of our Game, analyse and improve our Game and develop new services or new parts thereof. In some cases it may also help us to identify problems (e.g. bugs or problems preventing in-Game progression).
In many cases the data would be aggregated and/or anonymised so that it would not identify you.
To the extent this data includes your personal data, we rely upon our legitimate interests to process it, being our interests in promoting the success of our business.
For the purposes of our advertising attribution activities, we may process the following personal data:
· Website Technical Data;
· Game Technical & Usage Data, as defined above; and
· Information about the details of the advertising campaign and partner which resulted in your engagement with us (e.g. which Facebook ad you clicked through to then install the Game).
We may process this information so that we can understand which of our partners, and/or our marketing campaigns or adverts, directed you to us, such as to install our Game.
Attribution information enables us to promote the success of our company by better understanding the comparative successes of our marketing and our partners' efforts, so that we can be more efficient with our marketing and our arrangements with partners.
We process this information on the basis of our legitimate interests, being our interests to promote the success of our company.
For targeted advertising (for serving advertising to you which we think may be of greater interest) we may process the following data:
· Website Technical Data (as defined above, such as your IP address and technical analytics about your visit to our Website).
We may use Facebook’s services in order to understand which users visit our Website and then so that we can advertise our products and services to those users on Facebook platforms. We may do this as we perceive that these users may have a greater interest in our products or services.
To undertake this processing activity, we rely upon your express prior consent. You can withdraw your consent anytime by emailing us.
Competition and promotion related entry data (where you may enter a competition / prize promotion with us (such as over email or over social media)):
· your entry contact information (e.g. social media username or email);
· information submitted as part of your entry; and
· information submitted so we can process your entry (such as your address, if we need to send you a prize).
We may from time to time operate prize promotions and competitions (without any obligation to do so). If we do, your personal data processed in connection with that activity would be processed on the basis of performance of a contract (being the competition / prize promotion terms of entry).
Newsletters, updates and marketing messages (information provided by you when signing up to our newsletter or marketing emails, if you choose to sign-up):
· Email address.
Consent-based mailing lists
We may process your data to make suggestions and recommendations to you and other users of the Platform about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest.
'Soft opt-in' mailing lists
In some instances (such as with some of our existing customers) the law may permit us to process your personal information in order to send information to you by marketing messages that we think is of interest for you on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and the Platform, content, products and services. We may process your information for this purpose.
If the information is not of interest for you, you can opt-out at any time by emailing us.
We use vendor MailChimp (The Rocket Science Group LLC) to assist us with our email marketing activities. You can find out more about their processing activities here.
Device-level consents and push notifications.
Most smartphone and tablet devices compatible with the Games provide in-device privacy control mechanisms such as that the device may require your prior consent (to your device provider) in order for the Application to access certain device data and to provide you with certain Game functionality.
You can control your device-level consents by selecting your preferred option in the'pop-up' option your device presents to you at the relevant time. Also, you may be able to edit your preferences later in the ‘settings’ options available from your device provider.
Your editable consent preferences may include, for example, whether you would like the Game to send you ‘push notifications’ on your device or not.
2. Your Rights In Relation To Your Personal Data You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us: for a copy of personal data we are processing about you and/or to have inaccuracies corrected; to restrict, stop processing, or to delete your personal data; for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and to make a complaint to a data protection regulator. You may contact them at:https://ico.org.uk/concerns/. To make a request in relation to any of the aforementioned rights, please send your request to firstname.lastname@example.org. You may request deletion of your personal data by sending an e-mail to email@example.com. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally For data processing activities for which we rely upon your consent, you can withdraw your consent at any time by using the tools provided (if applicable, such as in-Game or through your device settings) or otherwise by contacting us at firstname.lastname@example.org.
2. DISCLOSURE OF YOUR Personal DATA
We will share your personal data with third parties only in the ways that are described in this Policy. Group, suppliers, subcontractors, service providers. We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. Government authorities. In addition, we may disclose your personal data 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 to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention). Potential acquirers or investors. If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your personal data, as well as any choices you may have. 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 us, our personnel or customers, or others. Stores. We may also disclose your personal data, to the extent necessary, to game / application stores or platforms (such as the Apple App Store and Google Play Store) if that is required, for example, for fulfilment of an order you make (e.g. if needed to fulfil a mobile game DLC order) or in order to investigate or prevent fraud. Such platforms and stores may also process your information in order to provide you with cross-device access to your current position in the Game and your in-Game progression, for example. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.
We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
3. Data Retention
Let's take a closer look at the Heroes Chained IGO information and GamFi holders' opportunity to buy $GF tokens before market listing through the IGO on the Launchpad on January 17.
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Service visitors and customers. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
to buy $GF tokens before market listing through the IGO on the Launchpad on January 17.
5. International Data Transfers
Where necessary, there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a national data protection regulator and/or those approved by the European Commission, such as the European Commission's standard contractual clauses, or other appropriate measures. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at email@example.com.
We do not use the Services to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at: firstname.lastname@example.org. We will delete such information within a reasonable time.
If you follow a link from the Service to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites. We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.
Cookies (and equivalent devices in the context of mobile devices) are small text files that are placed on your device by websites that you visit and mobile applications you use. They are widely used in order to make websites and applications work, or work more efficiently, as well as to provide information to the owners of the sites and apps. The below explains the main cookies we use in our Websites and Games and why:
Purpose/ Third Party Access
Google Analytics (on our Websites)
This Google cookie is placed on our Websites. It enables us to collect and understand analytics information about visitors to our website and how our Website is being used (such as which number of visitors are from which country).
You can find out more about Google's privacy practices here: https://policies.google.com/privacy?hl=en-US
To opt-out anytime, please see: https://tools.google.com/dlpage/gaoptout
Twitter Conversion Tracker (on our Websites)
This Twitter cookie is placed on our Websites. It enables us to learn how our users have interacted with our advertising served on Twitter. It also enables Emergent Games to identify users who have used their mobile device to view Emergent Games advertising on Twitter and later came to the Emergent Games Website on a desktop computer. In this way, it assists us with advertising attribution and to understand which of our marketing campaigns are successful.
You can find out more about Twitter's privacy practices here: https://twitter.com/en/privacy
To opt-out anytime, please see: http://optout.aboutads.info/#/
Facebook Pixel (on our Websites)
A Facebook Pixel is placed on our Websites. It enables us to measure, optimize and build audiences for advertising campaigns served on Facebook.
In particular it allows us to see how our users move between devices when accessing our Website and Facebook. This may allow us to 're-targe' users on Facebook with our advertising, who we perceive as having more interest in our products and services.
You can find out more about Facebook’s privacy practices here: https://m.facebook.com/policy.php
To opt-out anytime, please see: https://www.facebook.com/ads/preferences
cookieAccept (on our Websites)
This cookie is placed by us on your device when you visit our Website and is used to record when a user of our Website has accepted our cookie banner notice, to prevent it re-appearing on users' return visits when it has been accepted already.
Facebook SDK (in our Games)
This device enables us to collect data about when a click from our marketing on Facebook platforms results in an installation of our Game. This advertising attribution information allows us to better understand which of our advertising campaigns are successful. The data is shared with vendor Facebook for this purpose. You can find out more about Facebook's privacy practices here.
Unity Analytics (in our Games)
This device is used in order for Unity to provide us with analytics services. The data is shared with Unity, so that Unity can provide us with these services. You can find out more information about Unity's (Unity Technologies') privacy practices here.
Google Firebase (in our Games)
This device is used to collect analytics information about how players use our Game. We use the information to compile reports and to help us improve our Game. The data is shared with Google, for Google to provide us with these services. Google's privacy information is available here. You can also read Google’s overview of privacy and safeguarding data here.
As the above devices are contained within the Games (as may vary between each of our Games), the duration for which they are on your device will be the same as the duration for which the Game is installed on your device. Most of our Website cookies expire within 30 days, although our analytics cookies may persist for 1 year.
HOW DO I CHANGE MY COOKIE SETTINGS
For some of our Services, we may provide you with in-Service preference tools which you can use to edit your cookie preferences in-Game. Most web browsers and mobile devices allow some control of most cookies and similar devices through the browser and mobile device settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org. Your mobile or tablet device provider may also provide you with additional cookie and browser control options, which may be available to you in your device settings - please consult your device settings for such device-specific controls (if applicable).