Privacy policy

This privacy policy applies between you, the User of this Application and State of Play Games Ltd, the owner and provider of this Application. State of Play Games Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the App. The magority of the data is anonymised and we have no intention of storing identifyable data expect to save player progress. Please read this privacy policy carefully.

Definitions and interpretation

  1. In this privacy policy, the following definitions are used:
    Data collectively all information that you submit to State of Play Games Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998;
    State of Play Games Ltd,
    we     or us    		 State of Play Games Ltd, a company incorporated in England and Wales with registered number Preston Park House whose registered office is at South Road, Brighton, East Sussex, BN1 6SB;
    User, Player or you any third party that accesses the App and is not either (i) employed by State of Play Games Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to State of Play Games Ltd and accessing the App in connection with the provision of such services; and
    App or Application any App produced by us on any and all platforms, including but not limited to the Apple App Store and the Google Play Store.
  2. In this privacy policy, unless the context requires a different interpretation:
    1. the singular includes the plural and vice versa;
    2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
    3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
    4. "including" is understood to mean "including without limitation";
    5. reference to any statutory provision includes any modification or amendment of it;
    6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

  1. This privacy policy applies only to the actions of State of Play Games Ltd and Users with respect to this App. It does not extend to any apps that can be accessed from this App including, but not limited to, any links travelled to from inside the app.

Data collected

  1. We may collect the following Data, which includes personal Data, from you:
    1. Device Type (automatically collected);
    2. Operating system (automatically collected);
    3. Actions inside the app
    4. Player-generated usernames & puzzles
      5. in each case, in accordance with this privacy policy.

Our use of Data

  1. For purposes of the Data Protection Act 1998, State of Play Games Ltd is the "data controller".
  2. Only data associated with player session saving is identifiable. All other data, intended for improvment of products, is anonymised.
  3. Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
  4. All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (Security).
  5. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our App. Specifically, Data may be used by us for the following reasons:
    1. internal record keeping;
    2. improvement of our products / services;
    3. to distribute player-generated usernames & puzzles distributed to other players;
    4. to promote the game through first or third party channels

    6. in each case, in accordance with this privacy policy.

Links to other websites

  1. This App may, from time to time, provide links to other apps / websites. We have no control over such apps / websites and are not responsible for the content of these. This privacy policy does not extend to your use of such apps / websites. You are advised to read the privacy policy or statement of other apps / websites prior to using them.

Accessing your own Data

  1. You have the right to ask for a copy of any of your personal Data held by State of Play Games Ltd (where such Data is held) for no charge.

Security

  1. Data security is of great importance to State of Play Games Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this App.
  2. If password access is required for certain parts of the App, you are responsible for keeping this password confidential.
  3. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the App.

Transfers outside the European Economic Area

  1. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
  2. If we transfer Data outside the EEA in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. You expressly agree to such transfers of Data.

General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

  1. State of Play Games Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

    You may contact State of Play Games Ltd by email at mail@stateofplaygames.com.


 

PRIVACY POLICY

APPLE ARCADE

STATE OF PLAY GAMES LTD

1. GENERAL TERMS

These terms apply to the use of games and other products and services referred to herein and developed and/or published by STATE OF PLAY GAMES LTD (“State of Play” / “we” / “us”), registered office Preston Park House, South Road, Brighton BN1 6SB, company number 06519943.

This privacy and data policy ("Privacy Policy") applies and has effect in respect of our games available on Apple Arcade and referred to herein as the “Game”.

The Game collects information about your progression through and achievements in the Game (“Game Progress”). This Game Progress information is stored on Apple services such as iCloud for game saves and Game Center for achievements, and is not stored by us. We do not store personal or gameplay data on our servers and its use is governed by Apple’s policies.

This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through the Game is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018.

You have the right to object to the processing of your personal data in certain circumstances. Information on your right to object, and your other rights, is set out below.

This Privacy Policy should be read in conjunction with such Terms of Use as may be applicable in respect of the Game. Where Terms of Use are applicable, they will be made available via the Game.

We do not accept any responsibility or liability for the privacy practices of third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Game.

2. INFORMATION WE MAY COLLECT

In addition to the Game Progress information we may collect and process the following personal data from you (together, “Your Information”):

Information that may be provided by you when you contact us for support

Your name
You email address
Your address and telephone number if provided

3. WHY WE COLLECT INFORMATION

To respond to your enquiries and requests for support

We may process Your Information so that we are able to properly respond to your enquiries and support requests.

This process is necessary to pursue our legitimate interests, those being our commercial interests to respond to your queries and requests for support and to maintain good commercial practice in customer service.

To help us to fix any Game problems

We may process information about you so that we can fix Game problems, bugs and defects reported by you.

This processing is necessary for us to pursue our legitimate interests, being our commercial interests of ensuring that our Game functions properly to ensure the best experience for all users.

4. DATA SHARING

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 our personnel, 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.

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 (for example, 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 our rights, property or safety, or those of our customers or others.

5. YOUR RIGHTS

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.

To make a request, please let us know by email to mail@stateofplaygames.com

To 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.

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.

To object to us processing data about you

You can ask us to restrict, stop processing or delete your personal data if:

i) 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;

ii) We are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;

iii) The personal data was unlawfully processed;
iv) You need the personal data to be deleted in order to comply with legal obligations;

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

If (i) we are processing 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.

To 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.

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. Information and contact details for the Information Commissioner’s Office, the UK’s Supervisory Authority, is available here: https://ico.org.uk/.

6. CHILDREN

The Game collects, uses, and discloses data from children in the same way as for other users, as described in this policy. The Game’s use of this data is limited to support internal operations of the Game. If you wish for this information to be deleted please contact us.

7. SECURITY

Once we have received your information, we will use strict procedures 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 Game; any transmission is at your own risk.

8. INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the

fulfilment of your orders, the processing of your payment details, the maintenance of the Service, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the 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 and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, 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 mail@stateofplaygames.com

9. CONTACT INFORMATION

All questions, comments or enquiries should be directed to mail@stateofplaygames.com © 2021 State of Play Games Ltd