PRIVACY AND DATA POLICY
Last Updated: January 2022
This privacy and data policy (“Privacy Policy”) is applicable and has effect in respect of software and products made available by us, all games, and related online services (including online network play connectivity and interactivity) (together the "Game(s)"), as well as any other online features relating to the Games and our website. Together the Game(s) and the Website are referred to as the “Online Services”.
The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. We are dedicated to protecting and respecting your privacy. We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.”
Please read this Privacy Policy carefully as it contains important information about the following:
This Privacy Policy should be read together with our terms of use as it forms a part of it.
The Online Services may contain hyperlinks to services owned and operated by third parties. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We recommend that you shall review the third party privacy policies as they have their own policies pertaining to the information collected. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
To ensure you are aware about the changes, you shall check this page from time to time. Where appropriate we may notify you of changes through the Games. Any changes to the Privacy Policy in future will be posted on this page.
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To help us improve the Online Services and fix any problems We may process non identifiable Analytics so that we can analyse and improve our Games and Online Services. This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Online Services and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level. We use third party providers Fabric (for crash analytics), AppsFlyer and Tenjin (user attribution and analytics), Game Analytics and AppOnboard (for analytics). Fabric, AppsFlyer, Tenjin, AppOnboard and Game Analytics may collect analytics on our behalf and in accordance with our instructions, and their applicable privacy notices. If you would like to find out more about the way Fabric, Tenjin, AppsFlyer, Game Analytics and AppOnboard collects and processes this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://docs.fabric.io/android/fabric/data-privacy.html, https://www.appsflyer.com/privacy-policy, https://apponboard.com/legal/privacy-policy/,https://www.tenjin.io/privacy/, https://gameanalytics.com/privacy |
To provide our Games to you The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games. We will use information about you (including Basic Information, Third Party Log In Information and Analytics) for delivering our Games to you under the terms of use agreed between us. |
To prevent fraud and illegal activity Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content. We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations. |
For advertising purposes We may process Advertising Data to show you advertisements for third party services. The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may withdraw it at any time. We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks :
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above. |
To improve the monetisation via in-app purchases We will not pass your information on for these purposes unless you give your consent or you have given it already. After you have given your consent, you may withdraw it at any time. This can be achieved by withdraw consent by disabling his or her account, or further requesting to be deleted by sending a support request to Skillz as set out in their privacy policy. Skillz may process information (including Skillz Information) to understand how users use our TENS Tournament, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within the game. This processing is necessary for us and Skillz to pursue our legitimate interests of improving the game and increasing the amount of revenue generated via in-app purchases. |
We use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy In order to identify users who are cheating in the Games, your personal information is processed via automated decision-making methods. Users maybe blocked from the Games and/or the Online Services who are determined to be cheating following an automated decision process. The users will be notified of the outcome in such instances and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the the Online Services and/or Games. |
We may collect and process the following information which may include your personal data.
Information provided by you when using the Games (“Basic Information”) We will collect the following information from you when you play our Games:
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Information collected for the purposes of providing analytics (“Analytics”) We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics. Personal data we may collect includes the following:
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Information used for the purposes of serving advertisements (“Advertising Data”) Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:
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Information about you collected from third parties (“Skillz Information”) When you access the game TENS Tournament we use a third party provider Skillz Inc (“Skillz”) based in the United States that enables players to participate in online real-money based competitions. Skillz collects fees, hosts player accounts, and distributes pay outs. It collects phone number, shipping address, credit card information or Paypal user name, first and last name and Social Security Number to participate in cash tournaments and withdraw funds. This information is used to verify your identity when you withdraw cash from your account and by us and certain third party service providers to monitor for fraudulent activity and verify that you can legally participate in cash tournaments and withdraw funds. For more information, please see Skillz privacy policy at http://corp.skillz.com/privacy-policy/ |
Information about you collected from third parties (“Third Party Log In Information”) When you access the Games via a third party social media provider such as Game Center, or Twitter, Facebook, we may collect and store non-personal and personal information which is available on that third party social media provider, such as your Facebook or Twitter name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook cookies within the Games. To ensure that the Games connect to the correct account from Facebook, we sometime also receive technical data. |
We will share your information with third parties only in the ways that are described in this Privacy Policy 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 customers, or others. Required by law: In addition, 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). Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, 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. Skillz: where you play TENS tournament game, the Skillz Information may be shared with our partner Skillz for the purposes described in section 4. 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. |
You can withdraw the consent by changing your advertising settings on your phone or device or by deleting the Game at any time.
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 without undue delay, and within one month at the latest.
Ask for a copy of data we are processing about you and have inaccuracies corrected You have the right to request a copy of the personal information we hold about you and to have any inaccuracies rectified. We will use reasonable efforts to the extent required by law to correct, supply, or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to). |
Obtain 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 IT system provider if you prefer. If you request, we will supply you with the relevant personal data in CSV format. If we are processing data to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to transfer, move, or copy your personal data to other IT systems. |
Object to us processing data about you You can ask us to stop processing, to delete or restrict, your personal data if:
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Make a complaint to a Supervisory Authority
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We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases contain encrypted and anonymised information only, are password protected and limited to essential employees only.
Please be aware that, no security system can avoid all potential security breaches, although we strive to provide standard and reasonable security for information we process and maintain.
You can opt-out by changing your advertising and notification settings on your device directly in case you do not wish to receive notifications from us or be served with targeted advertisements.
It is possible that your personal information may be transferred outside of the EEA by Ad Networks or to Skillz. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.
Where we transfer your information outside of the EEA, we have agreements in place along with those parties which includes standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data.
Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. We do not use our Online Services to knowingly solicit information from or market to children under the age of 13.