HYPERBRAWL TOURNAMENT PRIVACY NOTICE
Date of Last Update: 17 September 2019
This privacy notice explains what happens to the personal data that you provide or that is collected from you when you play our game, Hyperbrawl Tournament (the "Game"), on the Apple Arcade.
We are, Milky Tea Limited, a company registered in England and Wales under company number 05771167. We are committed to protecting your personal data. You can contact us using the email address at the bottom of this privacy notice.
We are a "controller" in respect of personal data. This means that we are responsible for deciding how we process the personal data we hold about you. As a controller we are registered with the Information Commissioner's Office ("ICO") in the UK and our registration number is A8489038.
WHAT PERSONAL DATA DO WE COLLECT?
"Personal data" means information which identifies you as well as any information relating to you. The data we collect about you cannot identify you but it will relate to you. This data we collect is as follows:
We only receive very limited data about you and only when you access the multiplayer aspects of the Game. A unique player ID ("Game Center ID") relating to you will be created and stored in the Game (and by Apple). This Game Center ID on its own cannot identify you nor can it be used to identify you if coupled with any other data we hold about you. This process is called pseudonymisation and means that you cannot be identified from the data we hold about you.
In addition to the Game Center ID, a unique token will also be created about you which is held by, Exit Games Limited ("Photon"), our multiplayer partner. Photon processes your personal data on our behalf in order to provide multiplayer functionality in the Game. The data that Photon holds about you is also pseudonymised and it cannot identify you from the information it holds.
Photon will also collect your IP address for the duration of a match and store it in logs for an additional month. Photon requires your IP address in order to route network traffic to your game for multiplayer purposes.
The precise data collected about you and used by us and Photon (and Apple) is as follows:
Data that is gathered as a result of gameplay, such as scoring a goal or a players position in the arena. Gameplay Data is transmitted to Photon to allow for online play, keeping the networked games synchronized e.g. ball and player position. Gameplay data is also transferred to iCloud for save games and to Game Center for achievements and leaderboards.
USER GAME DATA:
Data about the players progression inside the game (i.e. a player's level) and their Game Center ID. User game data is transmitted to iCloud to enable your game progress and settings to be saved. The data is also transmitted to Game Center to enable achievement and leaderboard features. User game data is transmitted to Photon to communicate a player's progress to other players (i.e. a player's leaderboard position, rank, level and stats). Player’s Game Center ID will be used to identify who you as a player are playing against in a multiplayer game, via the Game Center public nickname.
Meta Data, indirectly gathered by Photon, is used by Milky Tea to identify the number of concurrent users playing the Game at any time and the servers hosting such users, although this information will be aggregated only and will not relate to identifiable individuals.
CUSTOMER SERVICE DATA:
Data which you provide to us when getting in touch with us. If you do not contact us then we will not collect this type of data.
WHY WE PROCESS YOUR PERSONAL DATA?
We will only use your personal data when permitted to do so in accordance with data protection laws, which means that we will only process your personal data where we have a lawful basis for doing so.
In respect of your personal data, these bases are as follows: (i) where the processing of your personal data is necessary to provide services to you under the performance of the contract we have with you; or (ii) where the processing of your personal data is in our (or a third party's) legitimate interests and your freedoms and fundamental rights do not override those interests.
The table below provides further details about the reasons we process your personal data and the lawful bases we rely on to do so.
TYPE OF DATA
Data listed above save for Customer Service Data.
To operate, administer and provide the Game.
Necessary for performance of a contract.
Data listed above save for Customer Service Data.
To allow multiplayer functionality via Photon, including matchmaking.
Necessary for performance of a contract.
Customer Service Data.
Responding to queries when you get in touch with us.
We may also process your personal data for additional purposes which are compatible with the purposes set out above. Where we do we will update this privacy notice and ensure we have a suitable lawful basis.
In addition, we will also use your personal data when we are required to do so by law. Where that is the case, our lawful basis is processing necessary for us to comply with a legal obligation that we are under.
Please also note that we may process Meta Data in order to better understand how our Game is used, specifically to manage Photon servers.This data is always anonymised and will not identify you.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Photon will hold and process personal data( about you as described in this privacy notice, specifically Gameplay Data, User Game Data, Meta Data and IP addresses. Photon use the following sub-processors to host the data it holds and to support its infrastructure: Amazon Web service, CommunitySift, Digital Ocean, Exceptionless, G-Core Labs, Google, Loggly, Microsoft Azure, Rackspace, Raygun, Softlayer, Stackify, Upcloud, Zumidian, Quatumengine, GMO Cloud and its group companies. Please note that these sub-processors will not access data of every individual and any data accessed by them will not be able to identify you.
We do not disclose your personal data to any other service providers. If this changes we will update our privacy notice and we will ensure that we have a contract in place with our service providers to ensure they keep your personal data secure and only process it in accordance with our instructions.
We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data. Examples of the type of situation where this would occur would be:
in the administration of justice;
where we have to defend ourselves legally;
to bring claims; or
to assist with investigations.
Finally, in the event of a reorganisation, sale or takeover we may need to disclose personal information to new entities within the group or potential acquirers and their advisers.
DO WE MAKE YOUR PERSONAL DATA AVAILABLE OUTSIDE THE EEA?
Photon will process your personal data in the US. Whilst this data does not identify you, we have put in place adequate measures to ensure the security of your personal data, namely standard contractual clauses.
FOR HOW LONG DO WE HOLD YOUR PERSONAL DATA?
Your Game Center ID and the unique token Photon uses will only be retained for your game session. Photon will also hold logs about gameplay for an additional month.
In determining how long we retain your personal data we will take into account the amount and nature of the information we hold about you.
CHILDREN’S PERSONAL DATA
As described, we are not able to identify you from the personal data that we hold about you. This will help us to keep data secure, including the data of any persons under 13 years old. If you are under 13 we recommend that you speak to your guardians and ask them to review this privacy notice before playing the Game. Personal data of persons under 13 years of age will be processed on the same lawful bases as set out in the table above.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
You have the following rights in relation to your personal data:
a right to access your personal data held by us;
a right to receive certain personal data in an accessible, machine-readable format;
a right to have inaccurate personal data rectified;
a right to object to processing where our lawful basis is that it is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
a right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to the paragraph immediately below, where you have objected pursuant to paragraph immediately above, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
where we have specifically requested your consent to process your personal data and we have no other lawful conditions to rely on you have the right to withdraw this consent;
a right to request the restriction of processing of your personal data which enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
a right to object to direct marketing, which can be done by opting-out of direct marketing via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only; and
a right to complain to the Information Commissioner's Office, although we ask that you contact us in the first instance if you have any concerns about the way we process your personal data so we can try to resolve the issue.
If you would like to exercise any of your rights then you can do so by contacting us. Please be aware that whilst we will try to accommodate any request you make in respect of your rights they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part. As the personal data we hold about your is pseudonymised we may be unable to fulfil these requests but we will notify you if this is the case.
Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request.
In addition to your right to request that your personal data is erased, there are also steps you can take.
Whilst we do not process your game data we will include functionality in our game for you to delete your game data. You may decline to store data in iCloud or to send data to Game Center. To turn off iCloud data storage, you must turn off iCloud in Apple Settings for our game. As a result, you will only be able to play in single player offline mode. To stop sending data to Game Center, you must sign out of Game Center in Apple Settings. As a result, you will not appear on leaderboards.
CHANGES TO THIS PRIVACY NOTICE
We may update this privacy notice from time to time to make sure it is up to date. When we do, we will revise the “last updated” date at the top of the privacy notice. We'll endeavour to make you are aware of material changes but we suggest you also check this page from time to time to ensure you are up to date with our latest privacy practices.
HOW TO CONTACT US?
If you have any queries in relation to your personal data or how it is processed by us, please email us at email@example.com. We will do our best to answer your query and will only use any personal data you provide as part of your query for the purposes of responding.