Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our games users; in this policy we explain how we will treat your personal information.

1.2 [We will ask you to consent to our use of cookies and personal data in accordance with the terms of this policy when you first play our games.] OR [By playing our games and agreeing to this policy, you consent to our use of cookies and personal data in accordance with the terms of this policy.]

2. Credit

2.1 This document is created to best of our knowledge.

3. Collecting personal information

3.1 We may collect, store and use the following kinds of personal information:

(a) [information about your computer and about your visits to and use of games (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and games navigation paths])];

(b) [information that you provide to us when registering with our games (including [your email address])];

(c) [information that you provide when completing your profile on our games (including [your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details])];

(d) [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including [your name and email address])];

(e) [information that you provide to us when using the services on our games, or that is generated in the course of the use of those services (including [the timing, frequency and pattern of service use])];

(f) [information relating to any purchases you make of our [goods] OR [services] OR [goods and/or services] or any other transactions that you enter into through our games (including [your name, address, telephone number, email address and card details])];

(g) [information that you post to our games for publication on the internet (including [your user name, your profile pictures and the content of your posts])];

(h) [information contained in or relating to any communication that you send to us or send through our games (including [the communication content and metadata associated with the communication])]; and

(i) [any other personal information that you choose to send to us].

[additional list items]

3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

4. Using personal information

4.1 Personal information submitted to us through our games will be used for the purposes specified in this policy or on the relevant games.

4.2 We may use your personal information to:

(a) [administer our games and business];

(b) [personalise our games for you];

(c) [enable your use of the services available on our games];

(d) [send you goods purchased through our games];

(e) [supply to you services purchased through our games];

(f) [send statements, invoices and payment reminders to you, and collect payments from you];

(g) [send you non-marketing commercial communications];

(h) [send you email notifications that you have specifically requested];

(i) [send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter)];

(j) [send you marketing communications relating to our business [or the businesses of carefully-selected third parties] which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications)];

(k) [provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information)];

(l) [deal with enquiries and complaints made by or about you relating to our games];

(m) [keep our games secure and prevent fraud]; and

(n) [verify compliance with the terms and conditions governing the use of our games [(including monitoring private messages sent through our games private messaging service)]].

[additional list items]

4.3 If you submit personal information for publication on our games, we will publish and otherwise use that information in accordance with the licence you grant to us.

4.4 Your privacy settings can be used to limit the publication of your information on our games, and can be adjusted using privacy controls on the games.

4.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

4.6 All our games financial transactions are handled through our payment services provider, [PSP name]. You can review the provider’s privacy policy at [URL]. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our games, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

5. Disclosing personal information

5.1 We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes set out in this policy.

5.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

5.3 We may disclose your personal information:

(a) to the extent that we are required to do so by law;

(b) in connection with any ongoing or prospective legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d) [to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling]; and

(e) [to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information].

5.4 Except as provided in this policy, we will not provide your personal information to third parties.

6. International data transfers

6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

6.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: [the United States of America, Russia, Japan, China and India].

6.3 Personal information that you publish on our games or submit for publication on our games may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

6.4 You expressly agree to the transfers of personal information described in this Section 6.

7. Retaining personal information

7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 Without prejudice to Section 7.2, we will usually delete personal data falling within the categories set out below at the date/time set out below:

(a) [personal data type] will be deleted [date/time].

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7.4 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:

(a) to the extent that we are required to do so by law;

(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

8. Security of personal information

8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

8.3 All electronic financial transactions entered into through our games will be protected by encryption technology.

8.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.5 You are responsible for keeping the password you use for accessing our games confidential; we will not ask you for your password (except when you log in to our games).

9. Amendments

9.1 We may update this policy from time to time by publishing a new version on our games.

9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

9.3 We may notify you of changes to this policy [by email or through the private messaging system on our games].

10. Your rights

10.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) the payment of a fee (currently fixed at GBP 10); and

(b) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].

10.2 We may withhold personal information that you request to the extent permitted by law.

10.3 You may instruct us at any time not to process your personal information for marketing purposes.

10.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.