Effective Date: May 25, 2018
- The ways we collect personal data about you and why we do so
- How we use your personal data
- The choices you have about your personal data.
THE DATA WE COLLECT
Data you provide us
- Contact Information (such as name and email address)
- Player name and password
- Profile information
- Other data you choose to give us (such as data to identify a lost account, surveys regarding the Services or your participation in a sweepstakes or contest through the Services)
- Your messages to the Services (such as chat logs and customer support emails)
Data we collect automatically
- Data about your account and game progress
- Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC Address, IMEI)
- Data about your device, such as device name and operating system, browser type and language
- Data we collect with cookies and similar technologies (see more below)
- General location data
- Precise geo-location data (GPS, with your consent)
- Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services
- In most cases, we also create a Upbeat Games-specific ID for you when you use the Services.
Data we collect from our partners
- Data we receive if you link a third party tool with the Services (such as Facebook or Google). Exactly what information we receive when you sign into the Services with Facebook will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information. We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games.
- You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your Upbeat Games profile. If you provide us with your email address we may from time to time use that email address to send you marketing emails about our other games and Services.
- If you log in to your Upbeat Games Profile using your Google account details, we will receive some of your Google account information. Exactly what information we receive will depend on your settings in your Google account, but typically we will receive your basic public profile information such as your name, email address and profile picture. If you choose to grant us access to your Contact List, we will use and store this to help you find those of your Google contacts that are already playing our games.
- Demographic data (such as to determine the coarse location of your IP address)
- Data to fight fraud (such as refund abuse in games or click fraud in advertising)
- Data from platforms that the games run on (such as verify payment)
- Data for advertising and analytics purposes, so we can provide you better Services
WHY DO WE COLLECT YOUR DATA
To make the Services work
In order to make the services work, we process data necessary to:
- Register accounts and allow you to use our Services
- Operate the Services
- Verify and confirm payments
- Provide and deliver products and services you request
- Send you Services-related communications
- Comply with our legal obligations
To make the Services more suitable for our players
To provide great Services to our players, we have a legitimate interest to collect and protect necessary data to:
- Update and develop player profiles
- Develop and improve the Services and player experience
- Manage our relationship with you
- Provide social features as part of our Services
- Customize your Services experience
- Provide customer support
- Provide you Upbeat Games offers in the Services, and by email
- Send you related information, such as updates, security alerts, and support messages
- Enable you to communicate with other players
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners
- With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.
- To carry out research
- To remember you next time you visit one of our Services
To Develop new services
We use the information we collect in existing services to help us develop new ones
To show personalized advertisements (interest-based advertising)
We use advertising to fund our Services and to make our games available for free. We show third party advertising in our games and also advertise our Services via third parties.
To show you personalized advertisements in the Services we have a legitimate interest to process necessary data to:
- Track the content you access in connection with the Services and your online behaviour
- Deliver, target and improve our advertising and the Services
For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.
To keep the Services safe and fair
Ensuring a level playing field in the Services is a top priority for us. For more information on our acceptable use policy, see the Upbeat Games Terms of Service.
In order to keep the Services and its social features and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:
- Analyze and monitor use of the Services and its social features
- Moderate chats either automatically or manually
- Take action against fraudulent or misbehaving players
To analyze, profile, and segment
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
For marketing, promotion and advertising of our games and services
We may use the information that we hold about you to promote our Services in a number of ways. This might include:
- advertising within third party websites, apps and Internet-connect devices;
- showing you promotions for other Upbeat Games games in the games you play;
- sending you marketing materials by email.
- tracking game installs (for purposes of measuring the effect of marketing campaigns).
WHO CAN SEE YOUR DATA
Apart from Upbeat Games, your data can be accessed by others in the following situations:
Other players and users
Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting from Facebook from within our games and updating your app permissions from within your Facebook settings.
Partners working for Upbeat Games
Upbeat Games has partners to perform services for us. These partners process your data only at and according to Upbeat Games' instructions to provide the Services, such as hosting, player support, advertising, analytics and fraud prevention.
Other companies and public authorities
In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
We may also share your information in connection with any merger, sale of our assets, bankruptcy or a financing or acquisition of all or a portion of our business to another company.
Advertising and Social Media partners
The Services includes features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at http://upbeatgames.com/partner-opt-out. These partners may access your data and operate under their own privacy policies.
You consent to the collection and use of your data for targeting advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
To enable us to show in-game ads and to enable advertising partners (or ad networks) to find appropriate ads to serve to you in our games and on third party properties we may send information to advertising partners such as: advertising IDs, IP-address, the games you play and information about how you interact with our games and Services, age, country, gender and other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.
Upbeat Games does not control which specific ads are shown in our games through our advertising partners (this is controlled by them) but we may blacklist certain categories of ads.
When we market our games in media published by other companies, we use various third party marketing partners to assist us on our behalf, and we may share information which we have collected about you with such third parties for these purposes.
Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for our games or Services, they will serve you with a Upbeat Games ad while you are using other websites and services.
INTERNATIONAL DATA TRANSFERS
When you use Our Services, your data may be sent to the United States and possibly other countries.
As part of our international operations, we may transfer data to our Affiliates (which means subsidiaries, parent companies, joint ventures and other corporate entities under Upbeat Games group from time to time for our legitimate business purposes
We store information about players and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal data collected within the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of the EEA.
The data we hold may also be processed by employees operating outside of the EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
If you are a resident in a jurisdiction, where transfer of your personal information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer for us to provide you with our services.
YOUR RIGHTS AND OPTIONS
Opt-out of marketing emails and other direct marketing
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Opt-out of targeted advertising
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android). For more information, see also: http://upbeatgames.com/partner-opt-out.
Opt-out of location-based services
We may give users the opportunity to opt-in to location-based services, which rely upon a device’s GPS coordinates. You may opt-out of these location services via the settings on your device. A user’s location may be used to suggest friends with whom they might want to connect, analyze usage trends or target certain promotions.
Access the personal data we hold about you
You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 3 months of receipt of your request and verification of your identity.
Your other rights
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.
Should you wish to have any information about you deleted, please contact us. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
Please note that if you completely delete your account all your progress in our games and any unspent virtual items, will be lost and we may not be able to restore them in the future.
COOKIES AND SIMILAR TECHNOLOGIES
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.
Performance of contract (under our terms of service) as legal basis for processing is when we make our services available to you, provide customer support, integrating our services with technology and distribution platforms such as Apple iOS, Google Android and Amazon AppStore and inform you of the service related changes and services progress.
We process your personal data on the basis of our legitimate interests for example when we provide you our services and game events, serve interest based advertisements to you (both in-game and on third party properties), carry out marketing, keep our games secure, for engineering purposes, analysing the users’ behaviour across our games, moderating chat discussion.
We have Legal obligation to process your personal data when to comply with a legal obligation, such as the prevention of crime or fraud or to maintain records relating to tax.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
HOW DO WE PROTECT YOUR DATA
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
When we collect personal information we do not know the age of our players. If we learn that we have inadvertently gathered personal information from a child under 13 years of age, we will take reasonable measures to erase such personal information from our records.