Privacy and Data Policy
ISSUED BY OUTPLAY ENTERTAINMENT LIMITED
Last updated: 01/09/2021
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of the Outplay Entertainment Limited (“ Outplay” / “we” / “us”) services and as further detailed below. Our registered office is at Floor 3 1 - 4 Atholl Crescent, Edinburgh, Scotland, EH3 8HA. We are a company registered in Scotland, with company number SC386157 and VAT number GB 199 4253 62.
- 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 we hold about you.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following personal data from you when you use our Services (for example, our games or a game website forum) (together, the “Services Information”):
Information that may be provided by you when creating a Service account
o Your email address (for example, if you create a website forum account with us);
o Your name;
o Your account username;
o Your account password; and
o Your date of birth.
Information that may be provided by you when you contact us for support
o Your full name;
o Your email address; and
o Your telephone number (if you choose to provide this).
Information about your activities
(“Technical and Usage Data”)
We may collect technical and usage information about your use of our Service through tracking technologies and analytics collection in our Services. Personal data we may collect in this way includes:
o IP address;
o Geolocation information (i.e. longitude and latitude);
o Service user ID (a unique ID that we generate which identifies Service users);
o Device information (such as your device ID, operating system and version, device brand, device family, model and manufacturer);
o Mobile network carrier (if applicable);
o Country, market and region information;
o Error and crash data (identifying a Service crash event);
o Advertising identifier numbers (such as IDFA (iOS devices) and ADID (Android devices)); and
o Events related to your Service usage, such as achievement of a milestone and the occurrence of other events during your Service usage (such as virtual currency balance, session durations and your choices and progression for and in different parts of the Service).
Analytics and profile information
(“Analytics and Behavioural Data”)
We may collect, or create by analysis of other Services Information, analytical information in connection with your Service usage including without limitation:
o When you first launched / began using the Service;
o Whether you use our free Services, or whether you use paid-for Services and how much you spend;
o Whether you discovered our Service organically, or whether you discovered the Service through an advertising campaign;
o What your Service usage habits are (for example, whether you use the Service in a particular way or only use a part of the Service and how often you use it); and
o We may associate your account with a user segment group which we think have shared characteristics, such as perceived interest in a particular type of gameplay or particular parts of our Services.
Social networking site data
For some of our games with connectivity with social media networking sites such as (without limitation) Facebook (“ SNS”), or which are operated on, through or in connection with such social media networks and stores, we may collect the following of your personal data relating to your SNS account:
o User ID number;
o Account first and last name;
o Account email address;
o Profile picture;
o Birthday; and
o User ID’s of your friends who are Service users.
Prize promotion data
(“Prize Promotion Data”)
If you choose to participate in a prize promotion with us (such as a competition where you could win a prize from us or our partners), we may collect the following personal data about you:
o Your name;
o Your email address;
o Your mailing address; and
o Information to confirm your prize eligibility; where applicable (e.g. date of birth and your entry information / submission).
Direct marketing subscriptions
(“Direct Marketing Data”)
Some of our services, such as our websites, may offer direct marketing subscription services for you to sign-up to (to obtain news and updates from us, for example). The personal data we may collect from you for this type of service will be clarified on the relevant Service (such as in sign-up or tick-box information). It may include, without limitation, your name and email address.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Service to you and process your device registration
To enable purchases
If you make purchases or subscriptions through or in connection with the Service (where we may make that functionality available at our discretion), your order and certain relevant Services Information may be processed so that we can process your order and so that you can access the features within the Service.
To respond to your enquiries and requests for support
To prevent fraudulent or illegal activity
To help us to understand usage of the Service, improve the Service and to help us to fix any problems
We may process information about you (being certain of the Submitted Information, Technical and Usage Data, Analytics and Behavioural Data and SNS Data) so that we can understand usage of our Services, analyse and improve our Service and develop new services or new parts thereof.
This processing is necessary for us to pursue our legitimate interests, being our commercial interests in: (i) ensuring that our Service functions properly so that you and other users have the best experience; (ii) improving the quality of our Service; (iii) identifying and correcting any bugs or problems with the Service or any part thereof; and (iv) developing and creating new services in the future.
To serve more relevant advertising to you
We may process information about you (being certain of the Submitted Information, Technical and Usage Data, Analytics and Behavioural Data and SNS Data) in order to serve advertising to you in our Services (or third party services) which we and/or our advertising vendors and partners think is of more interest for you. We undertake this data processing activity on the legal basis of your consent. You have the right to withdraw your consent at any time. If you would like to do so, you can email us at: firstname.lastname@example.org .
To keep you up to date about our services and products
Where you have consented, or where it is otherwise lawful for us to do so, we may use your Services Information to send you emails in order to keep you informed about our news, services and products. Where we rely upon your consent to do this, you can withdraw your consent at any time by sending an email to email@example.com .
Push notifications and similar notifications on your device
Where you have consented or where it is otherwise lawful to do so, we may use your Services Information to send ‘push notifications’ or in-Service notifications (for example, on your device and in relation to the Service or a part thereof). Your device’s operating system provider may obtain your prior consent for these purposes and we would rely upon that consent for this activity. You may be able to amend your push notification settings generally within your device’s settings.
To understand your location (tailoring our Services by locale)
Where you have consented or where it is otherwise lawful to do so, we may use your geolocation Services Information for localising our Services (e.g. by content such as language) and advertising in our Services, and also for our analytics purposes of understanding where our users are based. Your device’s operating system provider may obtain your prior consent for these purposes and we would rely upon that consent for this activity. You may be able to amend your geolocation permission settings generally within your device’s settings.
We may process Services Information so that we can understand which publisher of our marketing materials referred you to us and, for example, to which marketing campaign that referral related. This information is helpful for our purposes of understanding which marketing and promotion activity is successful. We process this personal data on the basis of our legitimate interests, being our interests in promoting and improving our Services and their commercial success (including by improving our advertising and marketing).
We try to make our Services as interesting for you as we can. To help us to do that, we may customise some aspects of in-game presentation, content, content suggestions and offers. So that we can do this, we may process certain of your Technical and Usage Data and Analytics and Behavioural Data. For this processing, we rely upon the legal basis of legitimate interests, being our commercial interests in providing you with more engaging, high-quality content and services.
To log you into our Service and keep you logged in.
To deliver our Services and third party services which may be embedded into our own Services (such as social media network connectivity).
To remember information about your preferences such as your preferred language and configuration.
To help us understand how you use our Services, such as how often, so we can improve Services and deliver a better experience and also for us to carry out research and statistical analysis to help us develop new content, products and services.
To help us deliver in-Service advertising to you, such as in our games (which may be served by, or facilitated by, third parties). These are also used to help us and our partners and vendors measure the effectiveness of advertising and whether it was actually served to you.
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 Services or may not have the same quality of experience.
We may work with third parties who may also set cookies and equivalent technologies on our Services, for example: Google Analytics, Google AdWords, YouTube, Facebook, Twitter and LinkedIn, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Services.
5. DATA SHARING
Payment providers : Where you instigate a payment with us, your payment related information will be processed by our payment providers.
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. our licensors, app operators, stores 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 Outplay, our customers or others.
Digital Content Stores: Where our Service (or a part of it) is accessed through a third party store service such as (without limitation) an iOS, Amazon or Android application store, we may disclose your personal data to the relevant store/platform for the purposes of facilitating any in-Service payments made through these platforms.
6. AUTOMATED DECISION MAKING
7. MARKETING INFORMATION
8. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
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 with requests without undue delay and within one month at the latest.
Ask for a copy of personal data we are processing about you and have inaccuracies corrected or request erasure
You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. You can request a copy by emailing firstname.lastname@example.org .
We will use reasonable efforts, to the extent required by law, to comply with requests to supply, correct or delete personal data held about you on our files (and request that any third parties to whom it has been disclosed to do the same).
Object to us processing personal data about you
You can ask us to restrict, stop processing or delete your personal data if:
You can request account deletion by sending an email to email@example.com .
Obtain a machine-readable copy of your personal data, which you can use with another service provider
Make a complaint to a Supervisory Authority
9. DATA RETENTION
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. In regards to our games and applications, we generally retain your personal data relating to the game for up to two (2) years after your last active session (unless you let us know you would like it to be deleted).
Outplay will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Service and your personal data a high priority, no security system can prevent all security breaches.
Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Service; subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.
12. INTERNATIONAL DATA TRANSFERS
Where your personal data is transferred outside of the UK and/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 and/or the UK Government, to ensure that appropriate safeguards are used to protect your personal data, together with other appropriate safeguards to protect your personal data. If you require more information about these safeguards, you can contact us at firstname.lastname@example.org .
13. CALIFORNIA RESIDENTS & CCPA
If you are a California (USA) 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 5);
- categories of personal information we have disclosed within the last 12 months (see paragraphs 2 and 5); and
- specific pieces of personal information we hold on you (see paragraph 2).
For the purposes of the CCPA, please be aware that (per the details above) we have disclosed for business purposes, but we have not sold, your personal information to third parties within the last 12 months.
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 provide proof of their own identity.
Where the CCPA applies, you have the right to:
- request access to your personal information including how it is used and shared
- request deletion of your personal information; and
- 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 may verify your request by asking for proof of identity, such as your device ID and/or user ID.
14. CONTACT INFORMATION
All questions, comments or enquiries should be directed to Outplay at
. We will endeavor to respond to any query or questions within a reasonable
amount of time.
Our Data Protection Officer can be contacted here: DPO@outplay.com
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