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PRIVACY AND DATA POLICY
Issued by Playdeo Limited.
Last updated: 1 April 2019

1. INTRODUCTION AND GENERAL TERMS

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of the mobile apps (“Apps”) and the website www.playdeo.co.uk (the “Website”), of Playdeo Limited (“Playdeo”, “we”, “us”, “our”). The Apps and the Website shall together be the “Online Services” for the purposes of this Privacy Policy. We are a registered company in England, with the following company details:

Registered company number: 10308945.
Registered address: Unit 111, Canalot Studios 222 Kensal Road, London, United Kingdom, W10 5BN
Email: info@playdeo.co.uk

If you have any questions or comments about this Privacy Policy, please contact us by email.

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 “controller”. We will comply with all applicable data protection laws, including (as applicable) the General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018 (the “Data Laws”). “Controller” and “personal data” shall have the meanings given to them in 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.

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 data 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 the future, which will be made available to you. You should check back here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email, the Website and/or through the other Online Services.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data when you use our Online Services.

a) Information provided by you when using our Apps

We will collect the following information from you when you use our Apps (the “Basic Information”):

- Event and gameplay / app usage data about your use of the App and its content, including without limitation:
- Tutorials completed (as applicable);
- Progression points reached;
- Attempted completions;
- Progress and status;
- Videos / features viewed and/or interacted with (as applicable);
- In-app purchases made and virtual items and content (including without limitation virtual currency) obtained and/or used;
- App session start time;
- Scores; and
- Selected language.

- A unique pseudonymous identifier (a player ID);
- Unique device identifiers for the device on which the App is operated; and
Location data

Depending upon how you access the App, we may collect this information from third parties that you access the App through, or when you use the App in connection with them (for example, Facebook).

b) Analytics

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics (“Analytics”). Personal data we may collect includes the following:

- your user ID;
- your device operating system & version;
- your device make and model;
- App play / usage statistics and events;
- App play / usage time start, end and duration;
- App play / usage frequency;
- Purchase transaction types including pricing bandings, promotional bundles and spend on virtual items;
- The country of your device and the time, date and install source of the App download;
- Advertisements viewed and clicked
- Identification of crashes, errors, bugs and defects; and
- Location data

c) Advertising data

Through our third party advertising network partners, we may gather information about your devices when you install or use our Apps, depending on the permissions you’ve granted (“Advertising Data”). This may include:

- The make, model and operating system of your device;
- Properties of your device, such as screen size and orientation, audio volume and battery;
- The mobile network operator linked to your device;
- The Apps you have used;
- The country, time zone and locale settings on your device (i.e. country and preferred language);
- Network connection type and speed;
- IP Address;
- An advertiser ID, which is a pseudonymous identifier unique to your device; and
- Location data.

d) Support information

When you contact us asking for support or assistance, we may ask for (or receive from you) certain of your information including your email address and your name (“Support Information").

e) News subscriber information

We may operate news and offer subscriber services, through which you can provide us with your contact information to receive news, offers and updates from us (for example, by signing up on our Website). For these purposes, we collect:

- Your name; and
- Your email address.
(“Sign-up Information”)

f) Use of cookies and similar devices

The collection of any of the foregoing information may include the use of cookies and similar devices. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Similar devices called software development kits (“SDKs”) can be used within mobile applications to, without limitation, collect information about app users and how the app is used. Cookies and these similar devices are widely used to make websites and apps work, to provide functionality, to make websites and apps (and related services) more efficient and to provide website / app owners with information about how the website / app is being used and who's using it.

The following third-party SDKs are used in our Apps:

Facebook SDK
This device is used within our Apps for:
- our Analytics purposes;
- to allow us to understand which publisher of our advertisements referred you to us; and
- to allow us to provide you and other individuals with more relevant advertisements and marketing.
https://www.facebook.com/privacy/explanation

Google Firebase Analytics SDK
This device is used within our Apps for:
- our Analytics purposes;
- to allow us to understand which publisher of our advertisements referred you to us; and
- to allow us to provide you and other individuals with more relevant advertisements and marketing.
https://safety.google/privacy/privacy-controls/
https://safety.google/privacy/ads-and-data/

Adjust SDK
This device is used within our Apps for:
- our Analytics purposes;
- to allow us to understand which publisher of our advertisements referred you to us; and
- to allow us to provide you and other individuals with more relevant advertisements and marketing.
https://www.adjust.com/terms/privacy-policy/

If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above. You may also find the following resource helpful: http://www.youronlinechoices.com/uk/your-ad-choices.

For websites, most web browsers allow you to control cookies through your browser settings. To find out more about cookies generally and how to manage or delete them, you can visit: http://www.allaboutcookies.org/.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide our Online Services to you

We will use information about you (including the Basic Information and Analytics) for delivering our Online Services to you under the relevant agreement between us. The processing of information in this way is necessary, for example, for us to record your progress and current status within an App, and to ensure the Online Services deliver the features promised and function properly, so that you have the best experience when using any one of our Online Services.

To improve our Online Services and correct problems

We will use the Basic Information and Analytics to detect and correct problems such as errors, bugs, viruses and other problems with our Online Services and for our internal research purposes as we work to continually improve our Online Services. We undertake this type of processing on the basis of our legitimate interests, being our business interests in maintaining quality services and continually improving the quality of our services.

To respond to your enquiries and requests for support and to enable you to use the Online Services

We may process Basic Information and Support Information so that we are able to properly respond to your enquiries and support requests and so you are able to use the Online Services, in accordance with the relevant agreement agreed between us. We do so on the basis of our legitimate interests, being our commercial interests to assist and maintain good relationships with our users, and also to properly perform our obligations under our agreement with you.

To acquire new users and engage current users

We may process information (including Advertising Data and Analytics) to encourage engagement from our less active users and to notify them, for example, of new virtual items or other promotions on offer. We process this information on the basis of our legitimate interests of promoting and continually improving the commercial success of our Apps.

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 and advertising, including with the creation of ‘lookalike’ audiences. This may allow us to offer more relevant marketing to potential new service users without using information that personally identifies you. Where we use your personal data to understand which publisher of our advertisements referred you to us, or for a lookalike campaign where your personal data is processed, or in order to provide you with more relevant advertisements or marketing, we rely upon the legal basis of legitimate interests in order to process your personal data.

We will not pass your information to, or process your information for the purposes of marketing by, third parties unless it is a legitimate interest.

To improve the monetization of the Apps via in-app / in-App purchases

We may process information (including Basic Information, Advertising Data and Analytics) to understand how users use our Apps, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within an App. This processing is necessary for us to pursue our legitimate interests of improving the Apps and increasing the amount of revenue generated via in-App purchases (where they are applicable). This may include the implementation of dynamic pricing models, so that in-App purchases are priced according to relevant factors, such as geography and gameplay / app usage progression so that we can offer temporary promotional discounts. We will not pass your information to third parties for the purposes of dynamic pricing unless it is a legitimate interest.

To prevent fraud and illegal activity

We process personal data (including the Basic Information and Analytics) 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, and 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 relevant agreement with you, we may use your personal data to inform relevant third parties such as law enforcement agencies about the content.

4. 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 UK 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 Playdeo Limited, our customers, or others.

Digital Content Stores
: Where the Apps are downloaded / accessed through third party platforms or stores including without limitation Google Play and/or iTunes / Apple App Store, we may disclose your personal information to these platforms / stores for the purposes of facilitating any App-related payments made through these platforms (as applicable).

5. 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 below.  We aim to comply without undue delay with a request, and within one month at the latest. To make a request, please let us know by sending an email to info@playdeo.co.uk. Your rights include that:

- You can ask for a copy of data we are processing about you and have inaccuracies corrected;
- You have the right to request a machine readable copy of the personal information we hold about you, which you can use with another service provider. If you request, we will provide you with the relevant personal information 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 provider if you prefer; and
- 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).

6. OBJECT TO US PROCESSING DATA ABOUT YOU

You can ask us to restrict, stop processing, or to delete your personal data if:

- 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 ours 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; or
- The personal data is processed in relation to the offer of a service to a child.

7. 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 at info@playdeo.co.uk. 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. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of thirteen (13). In the event that we learn that we have collected personal data from a child under thirteen (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 thirteen (13) years of age please contact us at info@playdeo.co.uk.

9. DATA RETENTION

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

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator where we are legally required to do so. 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

Where we transfer your personal data outside of the EEA, we ensure that appropriate legitimising measures are in place with the relevant parties so that a similar degree of protection is afforded to your personal data as it would be within the EEA. These measures may include: (i) standard data protection clauses adopted by a data protection regulator and approved by the European Commission; (ii) where we transfer your personal data to a third party in the United States of America, we may transfer the personal data to them if they are a part of the Privacy Shield (which requires them to provide similar protection for personal data shared between the EEA and USA); or (iii) other mechanisms 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@playdeo.co.uk.

12. CONTACT INFORMATION

All questions, comments or enquiries should be directed to Playdeo Limited at Unit 111, Canalot Studios 222 Kensal Road, London, United Kingdom, W10 5BN or info@playdeo.co.uk.  We will endeavour to respond to any query or questions within three business days.

© 2019 Playdeo Limited. All rights reserved.