PRIVACY AND DATA POLICY
ISSUED BY SAD PUPPY LTD
Last Updated: 21 December 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by Sad Puppy Ltd (‘Sad Puppy’ / ‘we’ / ‘us’). Our registered office is at Vault 2, Pinto Wharf, Valletta Waterfront, Floriana, FRN 1913, Malta. We are a company registered in Malta, with company number C78780.
- 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 information 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.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
Information provided by you when using the Games
We will collect, or you may submit, the following information when you play our Games:
Information provided by you when contacting email support.
We may ask you for, or you may submit, certain information to us whenever you contact us via social media, through the Games, email@example.com, firstname.lastname@example.org OR email@example.com.
This may include:
Information used for the purposes of serving advertisements
Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:
Information collected for the purposes of providing analytics
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
We use the following third party analytics providers
The above third parties may collect analytics data on our behalf and in accordance with our instructions, and their applicable privacy notices. If you would like to find out more about the way in which the above third parties may collect and process this information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
Information about you collected from third parties
(“Third Party Log In Information”)
When you access the Games via a third party social media provider such as Facebook, we may collect and store technical data relating to you in order to ensure the Games connect to the correct Facebook account.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide our Games to you
To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information and Analytics) so that we can analyse and improve our Games and Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Online Services and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.
To respond to your enquiries and requests for support
To improve the monetisation of the Games via in-app purchases
We may process information (including Basic Information, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-app purchases. This may include the implementation of dynamic pricing models, so that in-app purchases are priced according to relevant factors, such as location and gameplay progression so that we can offer temporary promotional discounts.
For advertising purposes
We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.
The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually.
We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games. We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may withdraw it at any time.
We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks :
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.
To prevent fraud and illegal activity
We process personal data 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, to enforce our legal rights and to comply with our legal obligations.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).
To help us understand how you use our Website, and how often, so we can improve them to deliver a better experience for our users.
To carry out research and statistical analysis to help improve our content, products and services.
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 Website.
We work with third parties who may also set cookies on our Website, for example Google Analytics, which we use to monitor how visitors use our Website. Google is responsible for the cookies they set on your device.
5. DATA SHARING
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 Sad Puppy, our customers, or others.
Digital Content Stores: Where the Games are downloaded though Google Play and/or iTunes, we may disclose your personal information to Google and/or Apple respectively for the purposes of facilitating any in-Game payments made through these platforms.
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by contacting us via MALTAGDPR@exient.com and let us know that you no longer wish to receive promotional or other marketing material from us or third parties.
We provide a link to the Website within the Games through which users can request the deletion of their personal data.
7. 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 without undue delay, and within one month at the latest.
To make a request, please let us know by sending an email to MALTAGDPR@exient.com.
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 information we hold about you and to have any inaccuracies corrected.
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).
We provide a link to the Website within the Games through which users can request what personal data of theirs is being stored and also request us to amend such information.
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
§ you consented to our processing the personal data, and have withdrawn that consent;
§ 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 Sad Puppy 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;
§ the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
Make a complaint to a Supervisory Authority
8. Data Retention
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, databases containing personal data are encrypted at rest and encrypted in transit. In addition, roll based user access control is used and where possible. We also use multi factor authentication, IP whitelisting and SSH Keys for additional protection.
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 you make in-Game purchases via iTunes or Google’s Play store, the confirmation that your purchase is valid as required by Apple or Google for such purchases will be processed using servers hosted in Singapore in the event that there is a problem with the servers hosted in Ireland.
The online Services are hosted by servers located at a data centre in France while our back up data is hosted by Amazon Web Services.
Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission 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 MALTAGDPR@exient.com.
All questions, comments or enquiries should be directed to Sad Puppy at MALTAGDPR@exient.com. We will endeavour to respond to any query or questions within three business days.
© 2018 Sad Puppy Ltd. All trade marks are the property of the relevant owners. All rights reserved.