Privacy Policy

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.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games including our websites (https://www.slightlymadstudios.com/), (https://www.projectcarsgame.com/) and the WMD Platform (https://www.wmdportal.com/) (the “Website”), mailing lists we operate in respect of any Games (the “Mailing List”), our online forums in respect of any Games (the “Forums”) and user support Centre in respect of any Games  (the “Support Centre“). Together the Game(s), the Website, the Mailing List, the Forums and the Support Centre are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at info@slightlymadstudios.com

We are committed to protecting and respecting your privacy.  The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

  • 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.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use for the Website and end user licence agreements for each of the Games.

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 may make changes to this Privacy Policy in 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 through the Games.

 

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

(“Basic Information”)

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

(“WMD Data”)

In order to administer the WMD Investment Platform, we collect and process the following information relating to each investor:

  • name;
  • 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

(“Contact Information”)

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

(“Registration Information”)

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

(“Forum Information”)

In order to set up an account to use the Forums, we will collect the following information from you:

  • username;
  • email address;
  • password; and
  • a unique Forum User ID which identifies your account.

Information collected for the purposes of providing analytics

(“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

(“User Content”)

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

We will use information about you (including Basic Information, Registration Information,  [Third Party Log In Information], Analytics and User Content) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games and using the Online Services.


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

We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre and we may process Forum Information so you are able to use the Forums, in accordance with the terms of use agreed between us.


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.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

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.


 

4. COOKIES


A cookie is a text file placed onto your device when you access our Games or Website. We use cookies and other online tracking devices such as web beacons, and flash object storage to deliver, improve and monitor our Website and Games, including in the following ways:

 

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.

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

Our Website should display a notice alerting you to our use of cookies and other similar technologies and linking to this privacy policy. If you use our Website after this notice has been displayed to you we will assume that you consent to our use of cookies or similar technologies for the purposes described in this privacy policy.

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.

If you want to learn about how to opt out of Google’s use of cookies, please visit https://tools.google.com/dlpage/gaoptout/ . The Google Analytics terms of service can be accessed here: www.google.co.uk/analytics/terms/us.html. For further information please visit the website of the relevant third party.


 

5. DATA SHARING


We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

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 info@slightlymadstudios.com 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 info@slightlymadstudios.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


We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

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 info@slightlymadstudios.com.


 

9. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services.  In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at info@slightlymadstudios.com.

 

10. Security

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 info@slightlymadstudios.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 info@slightlymadstudios.com.

 

CONTACT INFORMATION

All questions, comments or enquiries should be directed to SMS at info@slightlymadstudios.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.