PRIVACY AND DATA POLICY
ISSUED BY CHUCKLEFISH LIMITED
Last Updated: 17 January 2021.
- INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products and services developed and/or published by Chucklefish Limited. (“Chucklefish” / “we” / “us”). Our registered office is at 64 Southwark Bridge Road, London, SE1 0AS.
We are a company registered in England, with company number 07664836.
Together, the Games, Websites and Communities are referred to herein as the “Online Services”.
We do not use our Online Services to knowingly solicit information from, or market to, those under the age of 13.
- 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 data 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.
- INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following personal data from you when you use our Online Services (together, the “Submitted Information”):
Information provided by you when using a Game or Community
Information provided by you when using the Communities or that may be provided by you when you contact us for support or for newsletter sign-ups
User-generated content hosted and displayed in our Communities or Games
When using our Communities, you may decide to post information that may or may not contain personal data, in accordance with the rules applicable to our Communities (such as the relevant forum rules). Similarly, when using some of our Games (where this functionality is provided by us) you may decide to post certain content such as maps and in-game character dialogue, in accordance with the terms applicable for the relevant Game (e.g. the relevant end user licence agreement).
We cannot control the wider dissemination via the public internet of personal data that you may choose to post in User Content.
Information about your activities
We may collect technical information about your use of our Websites or Communities through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
Analytics may involve the use of ‘cookies’.
The following cookies are used on the Websites (as may differ between the different sites):
We may also use certain other cookies which are essential for the functionality of our service. Essential cookies are automatically applied. You may delete and block all cookies, but parts of the service may not work properly.
Our cookies are applied only for the duration necessary for them to fulfil their function.
How can I change my cookie settings?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org. Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
For mobile, your mobile device manufacturer may provide you with similar measures for control over SDKs or equivalent technologies set on your device, manageable through your device settings.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
Information about you collected from third parties
(“Third Party Account Information”)
If you choose to access or log into our Online Services (including without limitation our Games) via a third party social media platform such as Facebook, we may collect and store personal data and other information made available by that third party platform, such as your profile username, profile picture, user ID and public information about your friends.
We may also collect technical information in order to ensure that our Online Service connects correctly with your social media user account. This information may be obtained via a Facebook cookie or other similar device in our Online Service. The third party platform is responsible for obtaining your consent before sharing such data with us.
We may collect and process the following personal data from you as part of our business development and marketing activities (together, the “Partnership Information”):
If you are a person with a significant online following with a common interest to us, we may collect information about you and your online presence from your channel, posts or other online content you have shared. This may include the following:
- WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Games to you
To enable in-Game purchases
If you make purchases through the Online Services, your order and Game Information and Contact Information may be processed so that you can access these features within the Games.
For the above purposes, we rely upon the legal basis of performance of a contract.
To provide the Communities and Preventing Spam
Certain Game Information and User Content which you supply through our Online Service may be shared with other users of the Online Service. In some cases you may be able to select specific recipients (for example, if you are sending a forum post, or a private message, to a particular forum or individual) then only those recipients will receive it, however in all other cases, your information may be made publically available.
We may make your Game Information and User Content available to forum moderators. Moderators are crucial to the Communities and help make them the place that they are. Moderators are directed to only act in accordance with our instructions and to adhere to the moderator rules.
Spam is a problem for many forums and websites. In order to minimise this we use Stop Forum Spam to check that any new registration is not spam. In order to do this certain information is provided to Stop Forum Spam for the sole purpose of checking that it is not spam. You can find out more about how Stop Forum Spam use this information on their website available here: https://stopforumspam.com/privacy
For the above purposes, we rely upon the legal basis of performance of a contract and our legitimate interests, being our commercial interests to moderate the services and to prevent spam.
To respond to your enquiries and requests for support
As part of this we may also share this Submitted Information with the developers of the Games that we publish.
For the above purposes, we rely upon the legal basis of performance of a contract and our legitimate interests, being our commercial interests to respond to your queries and requests for support.
For advertising purposes
For some of our Online Services, we may process Submitted Information to show you advertisements for third party services. Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not Chucklefish. For advertising on our Online Services your personal data is processed for this purpose on the basis of our legitimate interests, being our commercial interests for advertisement-supported services.
For some of our Online Services, Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data.
Some of our Online Services integrate with AdSense, Google Analytics and GG Software. Analytics data will be processed and tracked by those third party services, and you can find out more about the way they use this information at the following locations:
To prevent fraudulent or illegal activity
We may process your Submitted Information for our legitimate interests of ensuring that your use of our Online Services is lawful, to prevent disruption to our Online Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.
To help us to improve the Online Services and help us fix any problems
We may process information about you (being the Submitted Information or any part thereof) so that we can analyse and improve our Online Services.
This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Games 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 or problems with the Online Services.
To help us to understand your usage of the Online Services
We may process information (being the Submitted Information or any part thereof) to understand how users use our Online Services, and to compile statistical reports regarding that activity, as well as understanding how users progress within a particular Online Service such as a Game. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems (such as when users may frequently be ‘stuck’ in a particular Game level) and to improve our future products and services.
To keep you up to date
Where you have consented to receive such news and products, we use your Contact Information to send you emails in order to keep you informed of news and products (such as with our email newsletters that you might like to sign up to). You can withdraw your consent, such as to receive our email newsletters, at any time and including by emailing us at email@example.com.
We may use vendors such as MailChimp and Sendinblue to assist us with managing our email newsletter databases and to assist us with sending emails to you. You can find out more about how MailChimp and Sendinblue process personal data here:
(In respect of Partnership Information) To approach you about business or partnership opportunities
Where we identify you as a person with a significant online following with common interests to us, we may use your personal data to identify business opportunities for partnership between us and you, reach out to you to propose such opportunities and, if you decide you would like to pursue such opportunities with us, to enter into and fulfil our agreement with you.
This processing is necessary for us to pursue our legitimate interests of identifying and pursuing business and partnership opportunities. In circumstances where you wish to engage with our business or partnership proposals, this processing is also necessary to take steps to enter into, and to fulfil the obligations contained within, the contract we enter into with you.
- DATA SHARING
Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, 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: 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 data to third parties (e.g. mobile network operators, gaming platform operators, game console manufacturers or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Chucklefish, our customers or others.
Digital Content Stores: Where our Game is downloaded through a third party store service such as Google Play or Apple’s App Store, we may disclose your personal data to Google and/or Apple respectively for the purposes of facilitating any in-Game payments made through these platforms.
Analytics: On occasion we may also disclose your personal information for the purpose of improving and optimising our Online Services to deliver a better experience for our users.
Social media: We may disclose your personal information to social media platforms, including without limitation Facebook or Twitter, such as where you connect your account for an Online Service with your social media account.
- AUTOMATED DECISION MAKING
For instance we use StopForumSpam, and if the new user is flagged as spamming the user will be informed of the outcome and will have the right to either have this decision re-considered or obtain human intervention to express his or her point of view and to contest the decision. If this applies to you, please contact us at firstname.lastname@example.org.
- CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly. If you are using an iOS device, you can opt out of personalised adverts by visiting https://oo.apple.com. For Android devices, you can visit https://support.google.com/ads/answer/2662922?hl=en-GB for information about opting out of personalized adverts.
We will obtain your consent to collect your information to be used for marketing purposes that require consent. If you prefer that we do not use your data in this way, let us know by writing to email@example.com or on the relevant forms or check-boxes that we may use to collect your data.
- 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 to requests without undue delay and within one month at the latest.
To make a request, please let our Data Protection Officer know via: firstname.lastname@example.org.
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 data we hold about you and to have any inaccuracies corrected.
You can download a copy of your Game account information by following the instructions in your account settings.
We will use reasonable efforts, to the extent required by law, to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).
Objecting to us processing data about you
You can ask us to restrict, stop processing or delete your personal data if:
You can delete your accounts by following the instructions in your account settings, where applicable depending on the relevant Online Service.
Obtain a machine-readable copy of your personal data, which you can use with another service provider
Make a complaint to a Supervisory Authority
- DATA RETENTION
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
We do not use our Online Services to knowingly solicit information 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 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 email@example.com.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Online Services; any transmission is at your own risk
- INTERNATIONAL DATA TRANSFERS
Where your personal data is transferred outside of the UK or EEA to a territory not subject to an adequacy decision by the UK Government and/or European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator (including in the UK) and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission or appropriate UK regulator, to ensure that appropriate safeguards are used to protect your personal data. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at firstname.lastname@example.org.
- CALIFORNIA RESIDENTS & CCPA
If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.
Please see above for:
- categories of personal information collected about you in the last 12 months (see paragraph 2);
- categories of sources from which the personal information was collected (see paragraphs 2 and 3);
- purposes for collecting personal information (see paragraph 3);
- categories of third parties with whom we share personal information (see paragraph 3 and 4);
- categories of personal information we have disclosed within the last 12 months (see paragraphs 2 and 4); and
- specific pieces of personal information we hold about you (see paragraphs 2 and 8).
We do not knowingly sell the personal information of minors under 16 years of age, except with affirmative authorisation in the case of those aged between 13 and 16.
You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit proof that they have been authorized by you to act on your behalf and proof of their own identity.
You have the right to:
- request access to your personal information;
- request deletion of your personal information;
- opt-out of the sale of your personal information; and
- not be discriminated against for exercising any of your rights under the California Consumer Privacy Act of 2018 (CCPA).
To make a verifiable consumer request, please contact us by email at email@example.com. We will attempt to verify your request within seven (7) days and may verify your request by asking for proof of identity, such as your device ID and/or user ID.
- CONTACT INFORMATION
All questions, comments or enquiries should be directed to Chucklefish at firstname.lastname@example.org. We will endeavor to respond to any query or questions within two business days.
© 2022 Chucklefish Limited. All trade marks are the property of the relevant owners. All rights reserved.