Last Updated: 20 July 2022
This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our “L.O.L. Surprise!” game application where we make this Policy available (the “App” or the “Services”). Please read the Policy carefully to understand our views and practices regarding your personal data.
We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including without limitation the Data Protection Act 2018 and the UK GDPR (as defined in the Data Protection Act 2018). Where we decide the purpose or means for the processing of the personal data that you provide when using our Services, we are the “data controller”.
You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
If you have any concerns over privacy, or this Policy, contact us at firstname.lastname@example.org.
1. How we collect and use your personal data
1.1 The table below explains what data we collect, how we use it, and which recipients it might be shared with.
|Your data||How we use it||Third Party Recipients|
Game operation, App analytics and usage information:
We collect game data such as your progress and inventory, your device ID, unique game ID, internet protocol (IP) address, time zone setting and high-level location, operating system and platform and other technology on the devices you use (“App Technical Data”)
We process this information to operate the App, manage purchases and to compile statistical reports regarding that activity (for example, your IP address is used to approximate the country from which you access our App). We also use this information to understand how players use the App to improve the gameplay experience.
We process this information on the basis of our legitimate interests, being our interests to operate and improve the App.
Google Firebase and Analytics:
|Customer support information (information we receive when you get in touch with us for support):
Note that you must be 16 or over for us to provide customer support.
We may process App Technical Data to serve contextual advertising to you in the App
Our third party advertising partners may process your personal data to serve contextual advertising to you in the App.
Contextual advertising helps support the commercial viability of operating, updating and improving the App.
We process this information on the basis of our legitimate interests, being our interests to promote the success of our company.
Note that we do not serve personalised advertising in the App.
|Mobile measurement partner:
We use a third party service to track the effectiveness of our marketing campaigns
We use a service called Singular to help us to measure and monitor our marketing activities.
We enable the strictest settings in Singular’s software in the App so that no personally identifiable information is tracked or shared with ad networks.
|Device-level consents and push notifications.
Most smartphone and tablet devices compatible with the App provide in-device privacy control mechanisms such as that the device may require your prior consent (to your device provider) in order for the App to access certain device data.
You can control your device-level consents by selecting your preferred option in the ‘pop-up’ option your device presents to you at the relevant time. Also, you may be able to edit your preferences later in the ‘settings’ options available from your device provider.
Your editable consent preferences may include, for example, whether you would like the App to send you ‘push notifications’ on your device or not.
Please note that the App does not process any of your personal data to send push notifications.
2. Your Rights In Relation To Your Personal Data
2.1 You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
- for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
- to restrict, stop processing, or to delete your personal data;
- for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
- to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/.
2.2 To make a request in relation to any of the aforementioned rights, please send your request to email@example.com.
2.3 You may request deletion of your personal data by sending an e-mail to firstname.lastname@example.org. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.
2.4 For data processing activities for which we rely upon your consent, you can withdraw your consent at any time by using the tools provided (if applicable, such as through your device settings) or otherwise by contacting us at email@example.com.
3. Disclosure of your Personal Data
3.1 We will share your personal data with third parties only in the ways that are described in this Policy.
3.2 Group, suppliers, subcontractors, service providers. We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
3.3 Government authorities. In addition, we may disclose your personal data 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 to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
3.4 Potential acquirers or investors. If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the App of any changes in ownership or use of your personal data, as well as any choices you may have.
3.5 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 us, our personnel or customers, or others.
3.6 Stores. We may also disclose your personal data, to the extent necessary, to application stores or platforms (such as the Apple App Store and Google Play Store) if that is required, for example, for fulfilment of an order you make (e.g. if needed to fulfil an App order) or in order to investigate or prevent fraud.
3.7 We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.
4. Data Retention
4.1 We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy.
4.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
5.1 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 Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Service visitors and customers.
5.2 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 data transmitted, stored or otherwise processed by us.
6. International Data Transfers
6.1 Where necessary, there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a national data protection regulator and/or those approved by the European Commission, such as the European Commission’s standard contractual clauses, or other appropriate measures.
6.2 If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at firstname.lastname@example.org.
7.2 If a parent or guardian becomes aware that their child has provided us with information without their knowledge or approval, they should contact us at email@example.com. We will seek to delete such information from our files within a reasonable time.
8.1 If you follow a link from the Services to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
8.2 We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.
8.3 All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.