PRIVACY AND DATA POLICY
ISSUED BY SLIGHTLY MAD STUDIOS LIMITED
Last Updated: May 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by Slightly Mad Studios Limited (‘SMS’ / ‘we’ / ‘us’). Our registered office is at 5th Floor Mill House, 8 Mill Street, London, SE1 2BA. We are a company registered in England, with company number 06552778.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal information you have provided to us.
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.
2. INFORMATION WE MAY COLLECT ABOUT YOU
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:
- your console’s unique device ID (Console ID) (if applicable);
- your Steam ID (if applicable);
- any third party platform profile display names;
- your user preferences; and
Core information milestones related to your gameplay, such as your overall progression to a particular level or stage, or the completion of certain activities during your gameplay (for example, completing a tutorial or passing a level).
Information used to administer the WMD Investment Platform
In order to administer the WMD Investment Platform, we collect and process the following information relating to each investor:
- email address;
- IP Address;
- the date of investment;
- payment transaction information; and
- Paypal information.
Contact information provided by you when you contact us or use the Support Centre
We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Support Centre.
This may include:
- your email address; and
- your name.
Information provided when you register your Game
In order to access restricted sections of the Website you are required to prove that you have purchased a Game by registering and providing the following information:
- username / email address; and
- encrypted password.
Once registered, you may then submit bug reports.
Information provided by you when using the Forums
In order to set up an account to use the Forums, we will collect the following information from you:
- email address;
- password; and
- a unique Forum User ID which identifies your account.
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:
- how many times you visit the Website;
- which pages you go to;
- traffic data;
- your IP and MAC address;
- your internet service provider;
- your Console ID;
- your user ID (which is generated by us and allocated to you when you first play our Games);
- your device operating system & version;
- your device make and model;
- game play attempts, progression and results;
- session game time start, end and duration;
- the country of your device; and
- identification of crashes and defects.
Contact information provided by you when you sign up to our Mailing List
(“Mailing List Information”)
We may ask you for, or you may submit, certain contact information to us whenever you sign up to our Mailing List.
This may include:
- your email address; and
- your name.
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, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook 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.
Content created by our users which we host and display on the Forums and in the Support Centre
When users submit their own User Content to the Forums or Support Centre, this content may contain personal and non-personal information. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Online Services to you
To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content, Registration Information and 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; and (iii) identifying and correcting any bugs in the Games and Online Services.
To respond to your enquiries and requests for support and to enable you to use the Forums and Support Centre
To acquire new users and engage current users
- We may process Mailing List Information to make suggestions and recommendations to you and other users of our Games about goods and services that may interest you or them, to provide you with information about other games and services we offer that are similar to those that you have already purchased; and to notify you about changes to our Games or the services we provide.
- We may also process this information to pursue our legitimate interests of acquiring new users for our Games.
- We may process Purchase Information at an aggregated level to pursue our legitimate interest of creating reports.
[We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.
To prevent fraud and illegal activity
We process personal data (including WMD 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.
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
To administer the WMD Investment Platform
We process WMD Data in order to perform our obligations to those Investors, and on the basis that we are required to retain certain records in accordance with applicable law.
We may disclose this information to the extent we are requested to do so by a regulator or obligated to do by court order.
|Authentication||To log you into our Website and Games and keep you logged in.|
|Preferences||To remember information about you such as your preferred language and configuration.|
|Analytics||To help us understand how you use our Games and Website, and how often, so we can improve them to deliver a better experience for our users.To carry out research and statistical analysis to help improve our content, products and services.|
Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Games and Website.
We work with third parties who may also set cookies on our Website, for example Google Analytics, Facebook, Twitter and YouTube, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Games and Website. These third party suppliers are responsible for the cookies they set on your device.
5. DATA SHARING
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 SMS, our customers, or others.
Digital Content Stores: Where the Games are downloaded through Steam, Xbox Live, PSN, we may disclose your personal information to Valve Corporation, Microsoft and Sony, respectively for the purposes of facilitating any payments made through these platforms.
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by changing your account settings in the Online Services at any time. Alternatively, you can contact us via firstname.lastname@example.org and let us know that you no longer wish to receive promotional or other marketing material from us or third parties.
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
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:
- you consented to our processing the personal data, and have withdrawn that consent;
- we no longer need to process that personal data for the reason it was collected;
- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of SMS or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed;
- you need the personal data to be deleted in order to comply with legal obligations;
- the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
- If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
- If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
8. Data Retention
WMD Data, User Content and Forum Information are retained indefinitely. If you would like us to delete your Forum account or any User Content that you have posted, please let us know by sending an email to firstname.lastname@example.org.
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as SMS 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.
11. INTERNATIONAL DATA TRANSFERS
It is possible that your personal information may be transferred outside of the EEA by third parties referred to in the policies as being the recipients of your data. 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.
Our servers are hosted by email@example.com.
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 SMS at email@example.com. We will endeavour to respond to any query or questions within three business days.
© 2018 Slightly Mad Studios Limited. All trade marks are the property of the relevant owners. All rights reserved.