INTRO
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Welcome to our Privacy Policy.
We take privacy very seriously, and are committed to protecting the privacy of our users.
This policy describes how we collect, uses, process and shares information about you.
This Privacy Policy applies to your download, access and/or use of DO119 LightCode, whether on your computer, on a mobile device, on our website www.do119-lightcode.com (the “Website”) or any other website, device or platform (each a “Game” and together the “Games”). It also applies to our Marketing and Advertising activities on all platforms and other Services that we will provide to you from time to time including campaigns with influencers. This Privacy Policy also applies to any other Services that we may provide in relation to our Games or our Website, such as customer support, social media, community channels and other websites that we may operate from time to time such as candycrushsaga.com (we refer to all our Games and other services collectively as our “Services”).
When you download, access and/or play our Games, or interact with our Websites or other Services you acknowledge the collection and use of your information in accordance with this Privacy Policy, including our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can opt in or out of the use of your personal information for targeted advertising purposes. If you have any concerns about providing information to us, or it being used as described in this Privacy Policy, you should not use our Games or other Services.
This Privacy Policy was last updated on 01/03/2024
Playing our Games
When you download, access and/or play our Games or use our other Services, we collect information about you. Most of this information comes directly from you or your device, such as device information, country, region, and game-play information. We use this information to provide our Games and Services to you, including for the purposes of optimisation, preventing fraud, customising in-game offers and verifying purchases. We will also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.
Most of the information that we collect about you comes directly from you when you play our Games, or interact with our Websites, advertising or other Services. Broadly, the information we collect about you relates to the type of device you are using, how you play our Games (such as levels attempted and purchases made) and will include information that you submit when creating an account with us or which you allow us to access when you connect to your Social Network accounts through our Games or other Services. We will also collect information from advertising platforms and partners and other third parties such as information about your purchases and interests.
In more detail, depending on which of our Services you interact with, we will collect and process the following types of information:
information about how you use and interact with our Games, advertising and other Services (for example, information about how and when you play our Games or visit our Websites, what device you use to access our Services or details as further set out in playing socially below);
information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us, including your email address or if you invite your friends to use our Services;
in certain jurisdictions, we collect your date of birth and/or your age to comply with applicable local regulations;
location information of your device;
the content of messages sent using our chat and messaging systems;
if you contact us, for instance through our customer service channels, or respond to messages and communications that we send to you, we will keep a record of that correspondence;
your interactions with us on our social media channels;
information we collect via cookies and other similar technologies, as explained further below;
information as further set out in this Privacy Policy, including playing socially, Marketing, and Advertising;
information we collect about you from our other Group Companies or other third party companies who have obtained your consent or have another legal basis to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregators). This will include attributes about you and your interests, as well as other Games and Services you use, demographic and general location information.
We will collect device level identifiers and other information associated with those identifiers including:
the type of device(s) you are using to play our Games or access our other Services, identifiers such as IP address, device identifiers, ad identifiers, a specific player ID, and the country or region that you are playing in; and
how you play our Games and interact with our Websites or other Services (such as which of our Games you are playing, your progress through the Games, session time and duration, number of attempts at each level and purchases made).
In some instances, when you make purchases on or through our Websites, we will collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by us. Unless otherwise stated we do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.
When you purchase items in our mobile apps through the App Store, on Facebook or on Google Play or purchase and redeem gift vouchers for our Games, we do not collect or store any payment information from you.
We will from time to time ask you for your consent to collect other information from you or your device. For instance, we will invite you to allow us to access your contacts to enable us to invite them to play our Games with you. If we do this or something similar, we will tell you what information we would like to collect, why we need it and what we’ll use it for.
We, our partners and Group Companies, will use this information:
to enable us to provide our Games and other Services to you, to ensure that any purchases you make are verified on our servers and activated in the Games, and to provide you with player support if you need it;
to enable us to optimise our Games for you and for the device that you are using, as well as to deliver customised in-game events, offers and promotions; for the other purposes as set out in this Privacy Policy, including for Marketing and Advertising purposes; and
to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Use or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Use (https://do119-lightcode.com/TermsAndConditions).
We will also share your information with third party publishers who develop and provide Games and other Services to you on our behalf.
We analyse and use the information that we collect on a de-identified or aggregated basis for product development, to analyse the performance of our Games, to troubleshoot and to improve and optimise our Games to ensure the best player experience for our players as a whole.
A more detailed description of some of the ways that we use your information is set out below and in the other sections of this Privacy Policy.
Providing and optimising our Services
We use your information to enable us to provide our Websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our Websites work properly on all devices and are as enjoyable as they can be for all our players.
Chat
Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, or to customer service. Your messages will be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to monitor and review the content of your messages, in accordance with applicable laws and regulations, including by using automatic filters and/or AI tools, to prevent toxic and abusive behaviours and to ensure that you are complying with our Terms of Use. We also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
Customer Services
We use your information, including information that you provide directly to us in communications, to provide you with support through our customer service channels at your request when you need it. We will also use this information to contact you, for example as part of customer service or to send you updates about our Services. Finally, we will use your information to manage your account and relationship with us and improve your experience when you use our Services.
Analytics and Research
We use analytics tools, which will include third party analytics tools, to collect information about how you play our Games or use our other Services. Those tools will use cookies or other similar tracking technologies. We will use your information to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We will also create reports, analysis, or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.
Social and Community
We have several social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you. We will also republish your posts to those channels and these will be available to those with access to those channels, which may be public.
Promotions and Competitions
From time to time we will run promotions or competitions during which we will collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We will also publish the names and entries of competition entrants. That information will also be combined with your Profile and other account information and will be processed, stored, and shared in accordance with this Privacy Policy.
QR codes: When you scan a QR code either to invite friends to download any of our Games, or to participate in promotions and similar activities, we will collect information from you, such as your device ID, your location, your unique visitor ID, the device used, IP address, time and date of the scanning. If a third party provides the QR code they will collect this information from you and we encourage you to read their privacy policy to know how they will process your personal information.
Cheating, crime toxic and abusive behaviour, and fraud prevention
We will use personal information that we hold to prevent cheating, crime, toxic and abusive behaviour, or fraud. We monitor our Games and other Services, using different tools, including AI tools, to detect such activities. We will process your personal information to monitor your account for anomalous player behaviour, this will help us to ensure the Game is fair between players.
We will also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police or other public bodies or entities where we are required to do so.
Legal uses
We will use your information as required or permitted by any applicable law.
Website Usage
When you visit our Websites, and other Websites operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We will use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis.
The information we collect and process about you when you visit our Websites includes:
information that you provide us with when you fill in forms or create posts on our Websites, or when you create an account with us on our Websites;
details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
if you contact us or respond to messages and communications that we or other users of the Websites send to you, we will keep a record of that correspondence;
your interactions with us on our social media channels;
and information which is collected via cookies (which are small text files placed on your device), and other similar technologies. Cookies allow us and Third Parties to collect information, such as your device’s model, operating system and screen size and other information about how you use our Services. For more information, see Ad identifiers, cookies and similar technologies below.
We use this information:
as necessary in order to provide the Websites and related Services to you;
for the purposes of contacting you, for example as part of customer service or to send you updates about the Websites;
for the purposes of managing your account and relationship with us and improving your experience when you use the Websites;
for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;
for the purposes of marketing and promotion of our Games and other Services, for example sending you communications (including by email) for these purposes on our, or a third party’s behalf. For example, we might send you information about merchandise relating to our Games. If you do not want us to use your information in this way please let us know by either opting out within your account, see Opting-out of direct marketing from below or by contacting us here;
to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Websites;
for the purposes of preventing cheating, crime, toxic or abusive behaviours or fraud. We will also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention where we are required to do so; or
as otherwise expressly set out in this Privacy Policy or as required by applicable law.
When using the any online forum, please be aware that in addition to your name, any questions, answers, comments or submissions that you post will be publicly available and any data you provide can be read and/or used by other users. You should therefore only share content that you are comfortable sharing publicly
Playing Socially
You can choose to use a third party social network (such as Facebook) to add information to your Profile or to connect to your account. If you do this, then your personal information will be visible to other players and we’ll also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising.
Your Profile
When you play our Games either with, or without creating an account, we will give you a randomly generated unique identifier known as a “Profile”. If you choose to create an account this will add your personal information to your Profile, such as your first and last name, avatar, email address or other information. We can then identify you with your personal information.
Your Profile and the information it contains will be visible to other users of our Services. If you choose to create an account by adding personal information to your Profile, it will be visible to your friends and other players anywhere in the world.
If you choose to view another individual’s Profile, that individual and other users of our Services will know that you have visited them because some of your social information and a link to your Profile will be displayed on that individual’s Profile.
Connecting with a third party network
Where we make this available, you can choose to log in to your Profile using your account details with a third party network, such as Facebook or Apple. If you do this, you will be able to use your account to log in on multiple devices and synchronise progress across those devices. Where available, you will also be able to see which of your friends are playing the same Game and their progress through the Games (and they will be able to see you and your progress), or access other functionality we make available in our Games and other Services, such as inviting friends to play, asking other players for in app items and one-to-one messaging.
Information we receive from Facebook
If you log in to your Profile using your Facebook account details, we will receive some of your Facebook account information. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information.
We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our Games. You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your Profile. If you provide us with your email address we will from time to time use that email address to send you marketing emails about our other Games and Services, in accordance with applicable laws. You can opt out of this at any time – see Opting-out of direct marketing from below.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our Games. If you do not wish your Facebook friends to be able to see you and your progression in our Games, you can prevent this by disconnecting from Facebook within our Games and updating your app permissions for our Games from within your Facebook settings.
We would recommend that you read Facebook’s Privacy Policy (https://www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.
Information we receive from Apple
If you log in to your Profile using your Apple account details, we will receive some of your Apple account information. Exactly what information we receive will depend on your settings in your Apple account, but typically we will receive your basic public profile information such as your name and email address. You can revoke future access to your information at any time by following the steps at https://www.apple.com/uk/privacy/control/
We would recommend that you read Apple’s Privacy Policy (https://www.apple.com/legal/privacy/en-ww/) and review your privacy settings from time to time to make sure that you understand fully how your Apple data is shared.
Marketing
Where we record your preferences as permitting us to do so, (see further below on how to change your preferences) we and our third-party partners use information collected about you to send you marketing communications about our Games and other Services based on your interests. For example, we will send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.
We will use the information that we hold about you to promote our Games and other Services or those of our Group Companies in a number of ways. This might include:
advertising within third party websites, apps and Internet-connect devices;
showing you promotions for other Company or its Group Companies’ games in the Games you play;
or
sending you marketing materials by email.
We will use the information that we hold about you to promote our Games and other Services or those of our Group Companies in a number of ways. This might include:
advertising within third party websites, apps and Internet-connect devices;
showing you promotions for other Company or its Group Companies’ games in the Games you play;
or
sending you marketing materials by email.
What information do we use for marketing?
We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we will have about you, such as:
ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
the Games you play and information about how you interact with our Games and other Services;
your age, country or region, and gender;
and other information that we collect from you or might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal basis to share that information with us.
Marketing partners
When we market our Games in media published by other companies, we use various third-party marketing partners to assist us on our behalf, and we will share information which we have collected about you with such third parties for these purposes.
Our marketing partners will help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for our Games or other Services, they will serve you with an ad while you are using other websites and services.
By accepting this Privacy Policy and downloading or continuing to play our Games, and unless you opt out of targeted advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.
This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners’ privacy policies for more information. A list of our marketing partners and their privacy policies can be found on their sites.
Opting-out of direct marketing from US
You can exercise choices over the direct marketing we send you in the following ways:
you can give your consent for us to send you direct marketing emails by opting in when we collect your email address or by choosing not to share your email address with us;
you can remove yourself from receiving email marketing from us at any time by simply clicking the unsubscribe link in any direct marketing email we send to you or by contacting the support team. If you have chosen to receive more than one type of marketing communications from us, you will need to opt out of all of them individually. It will take a few days for us to update our records before any opt out is effective; and to disable interest-based advertising, please see How to adjust your preferences for targeted advertising below.
You should note that if you opt out of receiving targeted advertising, you will still see advertising and you will see advertising for our products, but that advertising will not be targeted using your personal information.
Advertising
Our Games include advertising for third party products and services.
We and our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our Games.
Where applicable, and Where local laws allow, we will opt you into targeted advertising by default. You can change your preferences at any time in the Privacy and Security settings of our Games.
We use information that we hold about you to better target ads for third party goods and services to players that might be most interested in them. These ads will be shown to you within our Games or Services.
What information is used for advertising?
We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our Games that might be of interest to you. This includes information such as:
ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
the Games you play and information about how you interact with our Games and other Services; and
your age, country and region, and gender; and
other demographic and interests-based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
Advertising partners
When you play our Games or use our other Services, identifiers and other information from your device is collected and shared with our advertising partners to enable the technical delivery of ads to your device.
Our advertising partners will combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our Games or to improve the accuracy of their targeting and measurement systems.
If you consent to, or are opted into, the collection and use of your data for targeted advertising purposes by our advertising partners your information will be used as set out in this section and as further described in our partners’ privacy policies. We recommend that you review our advertising partners’ privacy policies for more information. A list of our advertising partners and their Privacy Policies can be found online. You can refuse or withdraw your consent to such use at any time – for more information, see How to adjust your preferences for targeted advertising.
How to adjust your preferences for targeted advertising
You can choose to prevent your device’s ad identifier being used for interest-based advertising (referred as “personalised ads”, “cross-contextual ads” or “targeted ads”) by updating the settings on your device.
When we record that your preference is not to be shown targeted advertising, you will still be able to play our Games and you will still see advertising in our Games, but those ads will not be targeted using information that we or our advertising partners hold or collect about you. However, you will still receive ads based on criteria such as the Game you are playing, the content of that Game, or the region in which your device is located.
If you would prefer that your personal information is not processed to receive targeted ads in a particular Game, you can update your preferences via the Privacy and Security setting in that Game. You can also submit an opt-out request for all of our Games here. Please note that outside of US states with applicable privacy laws, even if you have opted-out of targeted ads in our Games, you may still receive targeted ads from Facebook. If you would prefer that Facebook does not use your personal information for targeted ads, you need to log into your Facebook account and update your settings there.
Opting out of targeted advertising at device level: You can choose to prevent your device’s ad identifier being shared and used for targeted advertising by changing the settings of your device. On some devices it may be possible to reset your device’s ad identifier. Settings vary from device to device but you will usually find the ad identifier settings under “Privacy”, “Tracking” or “Ads” in your device’s settings. If you live in the USA, the EEA or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for EEA users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).
Ad identifiers, cookies and similar technologies
To provide our Games and other Services, Websites and targeted advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.
Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and to collect information from your device. For example, these technologies allow us and our third party advertising partners to:
recognise you and your device;
provide targeted advertising to you;
allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
allow us to understand how you interact with our Websites (for example, where we use cookies such as the Google Analytics cookie on our Websites);
allow our payment processors to process your payment instructions; and
enable us and third parties to provide you with more customised services, for example to provide our Services in the correct language.
For more information on the cookies we use and why we use them, please refer here
How do ad identifiers, cookies and similar technologies work?
Ad identifiers are identifiers such as the Android advertising ID and/or Apple’s ID for advertisers (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.
Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser or by using the cookie settings on our Websites.
Your Rights
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below
Those rights include:
Right of access. You have a right to know what information we hold about you and in some cases to have that information communicated to you. If you wish to exercise this right please contact us by completing this form selecting “Privacy and Legal” then subtopic “Please provide my information”. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we will not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please contact us here and we will correct it as soon as we can.
Right of erasure. You have a right to request to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please complete this form selecting “Privacy and Legal” then subtopic “I want to permanently delete my account”. Please note that in order to process your request you must delete our Games from your mobile devices and clear our cookies from any device where you have played our Games in a web browser. Where we delete personal information about you, we will still retain some, or all, of that information for other purposes such as maintaining financial records, protecting, or enforcing legal rights, maintaining marketing suppression lists or for technical reasons. In addition, we will also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores, and any chat messages will be cached on other players’ devices and we will not be able to remove or update that information from those devices, for example if that device is not connected to a wifi network.
Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We will ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile Games and deleting our Games from your mobile devices. Please note that if you completely deactivate your account all your progress in our Games and any unspent virtual items, such as they are will be lost, and we will not be able to restore them in the future.
Data portability. In some circumstances, you will have the right to request that your personal information is provided to you so you can transfer this to another data controller.
Restriction of processing. In some cases, you will have the right to request a restriction of the processing of your personal information, such as when you are disputing the accuracy of your data held by us.
Right to object. You have the right to object to the processing of personal information about you which is processed on the grounds of legitimate interests.
Direct marketing opt out. If you have chosen to receive direct marketing communications from us, you can change your mind at any time see the section above
Children's Privacy
In accordance with our Terms of Use in Terms and Conditions you must be over a certain age to play our Games and use our Services, depending on where you live. This age is 13 and above.
We do not knowingly collect or solicit personal information from or direct or target interest-based advertising to anyone under the ages set out, or knowingly allow such persons to use our Games and Services. If you believe that we might have any information from or about a child under the age set out, please Contact Us
Our Games are intended to be played by adults and we do not knowingly collect, and do not wish to collect, information about children. Please do not play our Games or use our other Services if you are under the relevant age.
Other General
This Privacy Policy contains further details about:
who we share your information with and the reasons for sharing it;
measures we take to keep your information secure;
the legal basis under which we process your information;
how long we retain your information and where we store it;
when and why we share your information with third parties, including transfers outside of the European Economic Area (the “EEA”), the UK, Switzerland and Canada (including Quebec); and
changes or updates to our Privacy Policy.
Sharing
In addition to what is described in this Privacy Policy, we will also share your information:
with the various Group Companies, including for the group companies’ own marketing purposes;
with third-party partners and licensees engaged by us to provide you with goods or services you have requested;
where we have your consent to do so (including as set out in this Privacy Policy);
as reasonably necessary in order to provide our Services to you (for example, by providing your personal information to partners we use to fulfil the Services or to communicate with you);
where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment partners);
where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
where we reasonably believe it is permitted by applicable law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; to exercise, establish or defend our legal rights or
where it is necessary to protect the rights, property, or safety of any person and of our Company, personnel and users; and
if there is a sale of the assets of Company or corporate restructuring, or as a result of a change of control of us or one of its Group Companies, or in preparation of any of these events. Any third party to which we transfers or sells our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.
We will also share your information with our Service Providers if necessary to enable them to provide services to us.
Any information, including personal information you reveal in a bulletin board, message board, chat room or other public forum is publicly viewable.
Security
We takes appropriate security and technical measures to protect your information from unauthorised access, loss and misuse. In addition, we request that our partners who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. In addition, we request vendors who process personal information on our behalf to take a range of security measures designed to help protect your personal information. However, we cannot guarantee the absolute security of your information online and offline, as the internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
We maintain and keep your personal information confidential, unless it is not confidential by nature, for example publicly-available information like user generated content, leaderboard rankings and scores, etc or information that you post or publish on your social media.
Legal Basis
In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal basis which we rely upon are the following:
Contractual Necessity and performance of the Games and other Services. We process your personal information for the performance of our Games and other Services, to provide or support of our Games and other Services, or for any other feature you request or enable. This includes using your personal information, for example, to:
provide you the Games and other Services you have requested;
support game functionality, such as chat functionality or third-party social network connectivity;
support purchases you made;
administer your profile or account;
provide global customer service; and
provide a fair gaming experience by using anti-fraud technologies such as bans or blocks of accounts.
Legitimate Interests. We process your personal information where we have a legitimate interest to do so. This includes the processing of your personal information, for example:
Marketing and Advertising of our Games and other Services;
Analytics, research and optimisation of our Games and other Services;
Debugging and improving our current and future Games and other Services;
Give exclusive content, personalise your online experience with us;
Contact you in accordance with applicable marketing preferences; and
For the establishment, exercise or defence of legal claims.
Consent. We process your personal information based on your consent, for example, when you consent to:
enable targeted advertising in our Games;
the storage of information on your device by us and our advertising partners, including through the use of cookies and other trackers;
receive newsletters, direct e-mails and surveys about our Games and Products that may be of interest to you;
enable certain other marketing features;
sharing data with our partners or Group Companies.
Where we ask for your consent to use your information for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.
Legal Obligation. We process your personal information for compliance with a legal obligation to which we are subject, such as to maintain records relating to tax or to respond to a valid legal request for certain data.
In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our Games we will still collect some personal information about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal information about you at all, you should cease playing our Games and stop using our Services.
Retention
We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.
Location of storage
We store your information on servers that we control some of which are based in the EEA and UK, and in other areas. We will also use servers and engage providers that are located outside the EEA and UK in order to process and store your information and to provide services to us.
International Transfer
We may transfer your information to Group companies or third parties in jurisdictions outside of where you live, including outside of the EEA, the UK, Switzerland, Canada (including Quebec), such as the United States. Please note that these jurisdictions will not have the same data protection laws as your jurisdiction and there may be legal means for courts, law enforcement and national security authorities in those jurisdictions to require access to your information. We take steps to ensure that there are adequate safeguards and mechanisms in place (for example, the use of EU model clauses) to allow the transfer of your information across borders outside of your jurisdiction.
GDPR – Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
As related to GDPR, for Data Controller (means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed) we are a Data Controller of your Personal Data.
For Data Processors (or Service Providers) (means any natural or legal person who processes the data on behalf of the Data Controller), we may use the services of various Service Providers in order to process your data more effectively.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the specific data protection rights.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Specific Service Providers
We utilise specific service providers in the areas of Advertising, Analytics, Behavioral Remarketing and Payments.
Changes to this Privacy Policy
We will update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us unless we provide otherwise.
Contact Us
If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then please contact us at do119-lightcode-support@protorealitygames.com