Last updated 24 July 2018
What information do we collect
We collect information when you play or set up your account for our Games. If you choose to set up a profile for the Games Services using a social media account, we will collect certain information from that account including your name, profile picture and email address. We collect information from you as you use our Game Services, including game play and log data. More Information.
How will we use this information?
We use your information to provide the Games to you. We use your information to support and improve the Games, to provide you with a personalised experience and to respond to queries. [With your consent we send you marketing emails and provide you with in-game advertisements that may be of interest to you. Such consent can be withdrawn at any time.] We retain your data for as long as necessary for the purpose for which it was collected, in accordance with our retention policy. More Information.
Who do we share your information with?
We use third parties for support services, such as game servers, support ticketing and analytics. We use these third party services solely to process or store your information for the purposes described in this policy. We also work with certain advertising partners for the delivery to you of advertisements. We also share your information with our related group companies and as required by law. More Information.
Where do we process your information?
Our servers are located in the United States. Our support, engineering and other teams are located in the United Kingdom. Some of our providers are located outside of the EEA (including in the United States), as set out below. More Information.
How can I exercise my rights over my information?
You may have rights to access, receive copy of, or delete, your data or restrict or object to our processing of, your data. More Information.
How will we notify you of changes?
Yakuto Limited (“Yakuto”, “we” or “us”) is a company registered in the United Kingdom with its office located at 44-48 Paul Street, London, EC2A 4LB, United Kingdom. We are the data controller of your data when you use the Game Services. If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at email@example.com.
THE TYPES OF PERSONAL INFORMATION WE USE
This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:
- Information you give us. You give us information about you:
- when you register for the Games Services using a connected social media account (Facebook or Google Play) we receive your name, email address, nickname and profile photo.
- If you register we also generate a unique user ID for you.
- If you play without registering you will be assigned a “guest name”. [This is stored on your device, but is visible to those other users you interact with].
- when you register for and interact with the Forum and customer support via our website our service provider Zendesk collects: [(a) if you register with social media (Facebook, Google or Twitter) your email address and name; or (b) if you register separately, your full name, email and password. You may also elect to personalise your account by adding your phone number, a photo and a description of yourself. You may submit an ad hoc request to customer support whereby you only provide your email address. Any content you choose to share on the Forum or with customer support is also collected.
Our Service is not intended for children. Children must not use the Service for any purpose. Persons under the age of 16 are required to obtain parental/guardian consent prior to using the Game Services.
HOW WE USE YOUR PERSONAL INFORMATION
We will use the information in the following ways and in accordance with the following legal bases:
|Purpose||Personal Information||Legal Basis for Processing|
|Registration for a Game account||Location (city level), device ID, unique UserID, device information (model, brand, operating system) and from Google or Facebook (as applicable) email address, name and profile photo||Necessary to perform our contract with you to, at your request, provide the Games linked to an account|
|Playing a Game as a guest||Location (city level), device ID, device information (model, brand, operating system), nickname||Necessary to perform our contract with you to play the Games and maintain game play|
|Playing a Game and progressing||
Scores, leagues, progress and other game play data
If a user has registered: UserID
If a user is a guest: device ID
|Necessary to perform our contract with you to play the Games and maintain game play|
|Allowing a user to either purchase a Game or make in-app purchases via Google Play and IOS App Store, and maintaining a record of your transaction history||Limited personal data about the transactions conducted via Apple or Google: UserID, device ID, product purchased and cost, purchase/transaction ID||
Necessary to perform our contract with you to keep track of your requested transaction so we can provide you with details of such transactions.
It is in our legitimate interests to use this information to deal with any disputed transaction and to defend any contract claims
|Monitoring the performance of certain game functions and the success of user acquisition and marketing campaigns (attribution to marketing channels)||Game play/events, sessions, log data (date and time), device ID, advertising ID, city level location data, device name, transaction information above||It is in our legitimate interests to monitor the success of our campaigns, our games and how users interact with them|
|Troubleshooting in order to improve our services and the functionality of the Game||In-app events, mobile brand, CPU structure, CPU model||It is in our legitimate interests to improve our services for our customers|
|Providing you with advertising that is relevant and interesting to you||Advertising ID, device ID, city level geolocation, IP address, browsing history and in-Game interactions||We process this information for this purpose with your consent (which can be withdrawn at any time in the settings)|
|Providing you contextual advertising that is not specifically targeted at you||Device ID, Advertising ID||It is in our legitimate interests to monetise our Games with non-interest based advertising|
|Sending you push notifications about in-app events||Device ID, UserID, game play details||It is in our legitimate interests to notify you about in-Game events, and you can turn this off at any time in your IOS or Android settings|
|WEBSITE AND FORUM|
|Creating a Zendesk account for the purposes of using the Forum or submitting a customer support requests on the Website||
If registering with a social medial account (Google, Facebook or Twitter), your email address and public profile. Without social media, your full name, email address and password.
You can choose to add a phone number, photo and description to your profile
|Necessary to perform our contract with you to create your support and forum account and to facilitate retrieval of a forgotten password|
|Responding to your customer support queries and to improve our services where issues are flagged||
Customer Support Ticket ID, game event data, timestamp, Zendesk account details and your communications with Support
You also have the option of providing a photo to illustrate any errors
|Necessary to perform our contract with you to provide and support the Game and respond to your queries|
|Allowing you to post on the Forum||Forum post content and account profile||Necessary to perform our contract with you to provide and support the Forum|
|Sending you newsletters about in-Game offers and our other products and services||Email address||We collect this information with your consent (which can be withdrawn at any time by following the un-subscribe mechanism at the bottom of each communication)|
Your personal information is kept as long as necessary to achieve the purpose set out above. Generally it is stored for the lifetime of your interaction with the relevant Game Services (i.e. until deleted in accordance with your request) then for up to 90 days. Transaction records however will be stored for longer in order to handle any disputed transactions. Where you subscribe for our newsletter, your personal information will be kept until you unsubscribe, after which point it will be moved to a suppression list to ensure you are not contacted again.
When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.
In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.
HOW WE STORE AND SHARE YOUR PERSONAL INFORMATION
In order to perform our contract with you, your personal information will be accessible from and will be processed by our employees and on our servers located in the United Kingdom.
We share your personal information with selected third parties in and outside your country, including:
- third parties that provide services in support of the Games and the Website, including:
- Cloud service provider: Google LLC (and its affiliates) who are based in the US, for the storage of all data identified in this policy. Such transfer is on the basis of the European Commission’s model contracts for the transfer of personal data to third countries pursuant to Decision 2004/915/EC (Model Clauses);
- Newsletter provider: The Rocket Science Group LLC (trading name, Mail Chimp), who are based in the US, for the purpose of automating our marketing, on the basis of who are based in the US on the basis of their EU-US/Swiss US Privacy Shield certification;
- Customer support and Forum: Zendesk Inc., who are based in the US, for the purpose of hosting and maintaining the customer support and Forum functions, on the basis of Model Clauses;
- Analytics: we work with a number of analytics and mobile measurement service providers including, Adjust GmbH, who are based in Germany, Google LLC (Firebase – see above) and Facebook, who are based in the US on the basis of their EU-US/Swiss-US Privacy Shield certification;
- related group companies with whom we share your personal information to operate the Game Services:
- Miniclip S.A., a Swiss based company. Switzerland was found to have an adequate level of protection for personal data under Commission Decision 2000/518/EC of 26 July 2000.
- law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection); and
- a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
Although we have in place security practices to maintain the privacy and integrity of your personal information, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.
You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at firstname.lastname@example.org.
You have the right to access personal information we hold about you, how we use it, and who we share it with.. If you believe we hold personal information about you, please email us at email@example.com with details of what information you believe we hold and would like access to.
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game Iaccount. If you believe we hold any other personal information about you and that information is inaccurate, please email us at firstname.lastname@example.org.
You can delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please email us at email@example.com.
You may request that we erase the personal information we hold about you in the following circumstances:
- you believe that it is no longer necessary for us to hold such personal information;
- we obtained your consent to process the personal information and you withdraw that consent (and we have no other grounds for processing the Personal Information); or
- you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request. We will need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
- You may request we stop processing and just store the personal information we hold about you where:
- you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
- you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
- you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at firstname.lastname@example.org.
Contact & Complaints
Questions, comments and requests regarding this policy are welcomed and should be addressed to email@example.com.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority – this may be the Information Commissioner which is the authority where we operate by calling +44 (0)303 123 1113, or alternatively in the country in which you live or work - where you think we have infringed data protection laws.
If we make any material changes to this policy, we will post the updated policy here and notify our users within the Game. Please check this page frequently to see any updates or changes to this policy.