Privacy and Data Policy

If you have any questions or comments about this Privacy Policy, or if you want to exercise your right to object to the processing of your personal data, you can contact us at support@dataprivacy-op.zendesk.com .

Information that may be provided by you when creating a Service account

(“Submitted Information”)

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

(“Support Information”)

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 Language;

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

(“SNS 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.

To provide the Service to you and process your device registration

We will process Services Information about you to provide our Service to you under the Terms of Use agreed between us.

The processing of information in this way is necessary, for example, for us to create your user account (if applicable), record your progress and status within a part of the Service (such as a game), to provide you with updated parts of the service (such as for security patches or content updates) and to ensure the Service delivers the features promised and functions properly (or to provide you with the opportunity to participate in a related activity, such as a prize promotion or competition activity). For these purposes, we rely upon the legal basis of performance of a contract (being performance of the Terms of Use agreed between us) and our legitimate interests (being our commercial interests in providing enhanced services and functionality to you).

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.

For the above purposes, we rely upon the legal basis of performance of a contract (being performance of the Terms of Use agreed between us).

To respond to your enquiries and requests for support

We may process certain of your Services Information (including your Support Information and certain other Services Information which might be relevant) so that we are able to properly respond to your enquiries and support requests, in accordance with the Terms of Use agreed between us.

For the above purposes, we rely upon the legal basis of performance of a contract (being our Terms of Use with you for the Service) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.

To prevent fraudulent or illegal activity

We may process your Services Information for our legitimate interests of ensuring that your use of our Services is lawful and in compliance with our agreement (being the Terms of Use agreed between us), to prevent disruption to our Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.

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.

Where our processing activity relates to detecting and fixing problems with the Service, we also rely upon the legal basis of performance of a contract (being our Terms of Use with you for providing the Service).

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: support@dataprivacy-op.zendesk.com .

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 support@dataprivacy-op.zendesk.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.

Marketing attribution

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).

Personalisation

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.

Authentication

To log you into our Service and keep you logged in.

Service delivery

To deliver our Services and third party services which may be embedded into our own Services (such as social media network connectivity).

Preferences

To remember information about your preferences such as your preferred language and configuration.

Analytics

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.

Advertising

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.

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

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, our advertising and analytics service providers and our other suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

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.

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 support@dataprivacy-op.zendesk.com .

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 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 Outplay 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; and/or
• the personal data is processed in relation to the offer of a service to a child.

You can request account deletion by sending an email to support@dataprivacy-op.zendesk.com .

Obtain a machine-readable copy of your personal data, which you can use with another service provider

• If (i) we are processing personal data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
• If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

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.
• If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. Contact information for the Information Commissioner’s Office, the UK’s independent authority setup to uphold information rights, is available here: https://ico.org.uk/.