PC & CONSOLE GAMES PRIVACY AND DATA POLICY

1. Introduction and general terms

At Kwalee Limited (‘Kwalee’ / ‘we’ / ‘us’), we respect your privacy. Our registered office is at Kwalee Ltd, Midlands Technical Centre, Southam Road, Radford Semele, Leamington Spa CV31 1FQ. We are a company registered in England, with company number 07648078.

This privacy and data policy (“Privacy Policy”) describes our practices with respect to the information we collect when you interact with our PC and console games (the "Game(s)" or “Kwalee Products”).

The Privacy Policy explains the basis on which personal data or personal information (collectively “personal data”) will be collected, used, processed, and disclosed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Kwalee Products are processed, we are the “data controller” or “business.”

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

• What personal data we may collect about you;
• How we will use personal data we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal data we or our service providers maintain.

By expressly consenting to this Privacy Policy, you confirm you have read, understand, and consent to the collection, use, processing, and disclosure of your personal data in accordance with this Privacy Policy, and understand that, in jurisdictions where it is available, Kwalee also relies on other lawful basis for the foregoing as more fully set out below. If you do not agree with our Privacy Policy, your choice is not to use the Kwalee Products.

The Kwalee Products may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies that govern their collection of your personal data, and we recommend that you review them.  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. Personal data we may collect about you

We collect and process the following information from or about you:

Information provided by you when using the Games

(“Basic Data”)

We will collect the following personal data from you when you play our Games:

• a unique pseudonymous identifier for you (User ID);
• your user preferences;
• game session time;
• in-game interactions (including interactions you have with other players) and in-game purchases that you may make;
• anonymous core information milestones related to your gameplay, such as the completion of certain activities during your gameplay; and
• content that you may create, upload or share in one of our Games.

Information collected for the purposes of providing analytics

(“Analytics”)

We may use tracking technologies to collect technical information, including personal data, about your use of the Kwalee Products which we use for our analytics purposes. Personal data we may collect includes the following:

• your User ID (which is generated by us and allocated to you when you first play our games);
• your device operating system and version;
• your device make and model;
• game play attempts, progression and results;
• session game time start, end and duration;
• purchase transaction types;
• the country of your Device;
• the time, date and install source of your first download; and
• identification of crashes, bug reports and defects.

Information about you collected from third parties

3. Why we collect and process information about you

We will process your personal data for the following purposes.

To provide our Games to you

We will use personal data about you (including Basic Data and Analytics) to provide our Games to you. The processing of personal data in this way is necessary for us to record your progress and current status within a Game, and to determine whether the Games features function properly, and to improve your experience when playing any one of our Games. In jurisdictions that permit it, we also process personal data based on our legitimate interest or for the performance of a contract, as applicable.

To help us improve the Kwalee Products and fix any problems

We may process non-identifiable Analytics so that we can analyse and improve our Games and Kwalee Products. 

This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Kwalee Products function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Kwalee Products; (ii) improving the quality of our Kwalee Products, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Kwalee Products and (iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Kwalee Products is lawful and non-fraudulent, complying with our legal obligations, 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 EULA or any other applicable terms hereunder, we may use your personal data to inform relevant third persons such as law enforcement agencies.

4. Data Sharing

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

Suppliers and service providers: We may transfer your personal data to our suppliers and service providers that provide services to us, including data analytics providers, IT and related services, payment processing, customer support providers, and security fraud-detection services. Our policy is to limit how our service providers use your personal data so that they only use it for the purpose of providing services to us.

Group Members: We may share your personal data among Kwalee group members, including our affiliates, subsidiaries and parent company for the reasons set out in this Privacy Policy, including developing and supporting the Kwalee Products and users, and sharing between teams collaborating on these purposes.

Merger or acquisition: If we are involved in a merger, acquisition, sale of all or a portion of its assets, bankruptcy, or other corporate restructuring, you will be notified via account message and/or a prominent notice on our website of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.

Required by law: In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing personal data to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal data 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 Kwalee, our customers, or others. This includes exchanging personal data with other companies and organisations for fraud protection.

With your consent: We may disclose your personal data otherwise with your approval and consent.

5. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

Depending on where you live, you may have some or all of the following rights over the way we process personal data relating to you, as set out in the table below.  We aim to comply with your requests as required by applicable law.

To make a request, please let us know by sending an email to privacypolicy@kwalee.com or submit a request via our webform. To protect your information, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity.

Under certain laws, you may exercise these rights yourself or you may designate an authorised agent to make these requests on your behalf. We may request that your authorised agent have written permission from you to make requests on your behalf and may need to verify your authorised agent’s identity.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You may have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. Specifically, you may have the right to request the categories of personal data we have collected, the categories of sources from which we collected the personal information, the purposes for collecting, selling, or sharing the personal information, the categories of third parties with whom we have shared or sold your personal information, and the specific pieces of personal information we have collected about you

We will use reasonable efforts to the extent required by law to supply and correct personal data held about you on our files (and with certain third parties to whom it has been disclosed to).

Ask us to restrict or delete your data

You may be able to ask us to restrict or delete your personal data in certain circumstances, including if we no longer need to process that personal data for the reason it was collected, or you have objected to us processing your personal data and we are considering your request.

Withdraw your consent or object to or opt out of us processing your personal data

If you consented to our processing your personal data, you may be able to withdraw that consent. Similarly, if we process your personal data, on the basis of the legitimate interests of Kwalee or a third party, and you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it, then you may have the right to object to the processing.

For example, you could withdraw your consent or object to our processing your personal data for marketing purposes.

We do not sell or share personal information and have not engaged in business transactions with third parties that might be considered a “sale” or “sharing” of personal data as those concepts are defined in the California Consumer Privacy Act (“CCPA”).

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 or sending an email to privacypolicy@kwalee.com.

We hope that we can satisfy queries you may have about the way we process your personal data. However, if you do not agree with the way we have processed your data or responded to your concerns, you also have the right to submit a complaint to a Data Protection Supervisory Authority. You can bring the complaint in your country or state of residence, place of work or where an alleged infringement of data protection law occurred. You can also submit a complaint to the UK Information Commissioner's Office, where Kwalee is headquartered.

Unsubscribing from Marketing

You may unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link in any marketing email we send to you. Even if you unsubscribe from marketing, you may still receive non-marketing emails from us.
 

6. DATA RETENTION

We will hold your personal data on our systems for as long as is necessary for the relevant purpose, or as otherwise described in this Privacy Policy. If you delete one of our Games or cancel your account, we may retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and for other lawful business purposes.

7. CHILDREN

We do not use our Kwalee Products to knowingly solicit or collect personal data from or market to children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age we will delete that personal data as quickly as possible. If you believe that we might have any personal data from or about a child under 13 years of age, please contact us at privacypolicy@kwalee.com.

8. SECURITY

We take technical and organisational precautions to prevent the loss, misuse or alteration of your personal data.  For example, our databases contain encrypted and anonymised information only, are password protected and limited to essential employees only (such as Kwalee 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.

9. INTERNATIONAL DATA TRANSFERS

If you use our Kwalee Products from the UK or EEA, it is possible that your personal data may be transferred outside of the UK and EEA to our affiliates, service providers or other third parties in other countries around the world that do not provide an adequate level of data protection as defined by data protection laws in the EEA and the UK. Certain third countries, such as Canada, the Republic of Korea and Japan, have been officially recognized by the European Commission and the UK Secretary of State as providing an adequate level of protection. Transfers within our corporate group or to third parties located in third countries that have not received such recognition take place using an acceptable data transfer mechanism, such as the EU and/or UK Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications, on the basis of permissible statutory derogations, or any other valid data transfer mechanism issued by the EEA, Swiss or UK authorities.

If you would like to receive further information about how we transfer Personal Data or, where available, a copy of the relevant data transfer mechanism, please let us know by writing to privacypolicy@kwalee.com.

10. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, this section also applies to you and supplements the information contained elsewhere in this Privacy Policy. We collect, use, and disclose personal information as described above.  We do not collect any sensitive personal information. We do not sell or share personal information, and we do not disclose personal information to third parties for those third parties’ direct marketing purposes.  Your individual privacy rights to access, delete, and correct are described above in Section 5.

11. CHANGES TO THE PRIVACY POLICY

We may make changes to this Privacy Policy in future. You should check this page from time to time to ensure you are aware of any changes and can see when this Privacy Policy was last updated by noting the "last updated" date at the top of this page. Where we make any material changes to this Privacy Policy, we may notify you of such changes through the Games or by email.

12. CONTACT INFORMATION

All questions, comments or enquiries should be directed to Kwalee at privacypolicy@kwalee.com.

Any data subject request including a request to Do Not Sell or Share My Personal Information shall be submitted through this Webform.

© 2023 Kwalee Limited. All trademarks are the property of the relevant owners. All rights reserved.