PRIVACY AND DATA POLICY

ISSUED BY STAINLESS GAMES LIMITED

Last updated: 12 September 2019.

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of apps and other products and services developed and/or published by STAINLESS GAMES LIMITED (“Stainless” / “we” / “us”) and as further detailed below. Our registered office is at 130 -132 High Street, Newport, Isle Of Wight, PO30 1TP. We are a company registered in England and Wales, with company number 04297229.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of our game ‘ShockRods’ (the “Game”).

If you have any questions or comments about this Privacy Policy you can contact us at support@stainlessgames.com.

We are committed to protecting and respecting your privacy. 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 and means for which personal data you supply through our 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.

Please read this Privacy Policy carefully as it contains important information about the following:

  • 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 data we hold about you.

This Privacy Policy should be read in conjunction with our terms of use as may be applicable in respect of the Game, and in conjunction with the terms of third parties to the extent they are applicable (for example, the terms of the digital content stores you may use to access our Game). Where terms of use are applicable, they will be made available via the relevant Game or in connection therewith.

We may make changes to this Privacy Policy in the future, which will be made available to you 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 ABOUT YOU

We may collect and process the following personal data from you when you use our Game (together, the “Online Services Information”):

Information that may be collected when you use the Game

(“Game Information”)

  • Your Game username / alias / nickname (where applicable);
  • Your user or account ID;
  • A unique temporary ID generated if you select to play the Game in multiplayer;
  • Game session information and Game event related information (such as your completion of a Game milestone and your in-Game progression); and
  • Language.

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

(“Contact Information”)

  • Your name; and
  • Your address, telephone number and email address.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Gameto you 

We will process information about you (including the Game Information) to deliver our Game to you under the terms of use agreed between us. The processing of information in this way is necessary, for example, for us to record your progress and current status within the Game, and to ensure the Game delivers the intended features and functions.

The Game collects information about your progress in the Game and this is stored on Apple’s services such as iCloud for game saves and Game Center for achievements and leader boards. 

For this purpose, we rely upon the legal basis of: (i) performance of a contract (being performance of the terms of use agreed between us); and (ii) our legitimate interests (being our commercial interests in providing quality services and functionality to you).

To provide multiplayer functionality

We will process information about you for providing the multiplayer functionality of the Game and match you with players at the same game level, platform and game mode as you. The information used is a temporary unique ID which is used on the GameLift servers provided by Amazon Web Services. The unique ID, as well as your then-current game level, platform and game mode, is only stored for the length of the multiplayer session.

For this purpose, we rely upon the legal basis of: (i) performance of a contract (being performance of the terms of use agreed between us); and (ii) our legitimate interests (being our commercial interests in providing multiplayer functionality to you).

To respond to your enquiries and requests for support 

We may process certain of your Online Services Information (including your Contact Information) 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: (i) performance of a contract (being our terms of use with you for the Game); and (ii) our legitimate interests, being our commercial interests to respond to your queries and requests for support.

To help us to improve the Game and help us fix any problems 

We may process information about you (being certain of the Online Services Information) so that we can fix problems.

This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Game functions properly so that you and other users have the best experience when, for example, playing the Game; (ii) improving the quality of our Game, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Game.

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 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, 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 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. gaming platform operators or stores, game console manufacturers 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 Stainless, our customers or others.

5. AUTOMATED DECISION MAKING

We may use automated decision-making methods which do not involve human involvement to process your information, and shall do so only in the ways and for the purposes that are described in this Privacy Policy.

6. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA 

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.

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 download a copy of your Game account information by following the instructions in your account settings (where this functionality is made available). Where this functionality is not available you can request a copy by emailing support@stainlessgames.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 ours 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 may be able to delete your account by following the instructions in your account settings, where available in the Game. You can also request account deletion by sending an email to support@stainlessgames.com.

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.
  • 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/

7. DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than 180 days following the deletion of your Game profile or another similar form of cessation of your use of the Game.

8. 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 at support@stainlessgames.com

9. SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Game, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us. 

Please be aware that, while we make the security of our Game and your personal information a high priority, no security system can prevent all security breaches. 

Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted through our Game; the sharing of your personal information with us and any transmission is at your own risk.

10. 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 Game, 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 support@stainlessgames.com.

11. CONTACT INFORMATION

All questions, comments or enquiries should be directed to Stainless at support@stainlessgames.com. We will endeavor to respond to any query or questions within a reasonable amount of time. 

© 2019 STAINLESS GAMES LIMITED. All Rights Reserved.