ISSUED BY LOCKWOOD PUBLISHING LIMITED
Last Updated: September 2019
INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games (including Avakin Life) and other products developed by Lockwood Publishing Limited (‘Lockwood’/‘we’/‘us’). Our registered office is at 9a Beck Street, Antenna Media Centre, Nottingham NG1 1EQ. We are a company registered in England, with company number 06242481.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. 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 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.
We 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: your mobile device’s unique device ID (Device ID) and a unique ID attributed to your device to enable us to send you notifications;your mobile device’s location (if you agree to provide it when using the Games);your Facebook ID and email address;your IP address;your user preferences; andinformation related to your gameplay, including the actions you take, copies of chat logs between you and other players, your progression through the game, and the virtual items you collect or use.|
|Contact information provided by you when using the Forums, Bug Reports or Support Centre (“Contact Information”) We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Forums or Support Centre. This may include: your email address; your name; your password; country; the make, model and operating system of your device; the mobile network operator linked to your device.|
|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: the make, model and operating system of your device; properties of your device, such as screen size and orientation, audio volume and battery; the mobile network operator linked to your device; the Games played; the country, time zone and locale settings on your device (i.e. country and preferred language); network connection type and speed; IP Address; MAC address; the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.|
|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: your Device ID and Facebook ID; your user ID (which is generated by us and allocated to you when you first play our games); your device operating system & version; your device make and model; game play statistics and events; purchase transaction types and spend you have made using virtual items in the Games; the country of your Device; a record of where you found a link to install our software; advertisements viewed and clicked; and identification of crashes and defects.|
|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 Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook 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. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.|
|Identification and address information (“ID and Address Information”) If you provide it, we may process information to verify your identity, confirm your telephone number and send you items in the post. Personal data we may collect includes the following: Identification such as ID cards, passports, driving licences, certificates and other materials; Your mobile telephone number; Your physical address; Photographs of your face if you provide them.|
|Content created by our users which we host and display on the Forums and in the Support Centre (“User Content”) When users submit their own User Content to the Forums or Support Centre, this content may contain personal and non-personal information. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.|
|To help us improve the Online Services and fix any problems We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Games and Online Services. This processing is 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.|
|To acquire new users and engage current users We may process information (including some Advertising Data and Analytics) in order to pursue our legitimate interests to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer.We may also process this information to pursue our legitimate interests of acquiring new users for our Games as part of which we use unique links to let us know where our users have come from. We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you. In particular, we may use some third parties to support us with online marketing. We provide limited information about you to the relevant social media platform through their tools (in particular, Facebook Custom/Lookalike Audiences) such as your name and email address so the social network can find users with similar characteristics to you, who may also be interested in our games. This processing is carried out only if you have given your consent. You may withdraw your consent at any time.We may also process your postal address, if you choose to provide it, in order to send you parcels if you have won a prize. We process this information in order to perform our contractual obligations to you.|
|To improve the monetisation of the Games We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via purchases of content within or associated with the Games.|
|For advertising purposes We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games. The information we collect about you may be used to pursue our legitimate interests, in particular to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. That information may be collected by the third party advertising networks linked to below. Once we receive it, we aggregate this information so that it does not personally identify you or permit you to be treated individually. We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games. We will not process your information for the purposes of targeted marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent for us to target advertisements based on your personal data 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: TapJoy (https://www.tapjoy.com/legal/#privacy-policy) MoPub (https://www.mopub.com/legal/privacy/) Adcolony (https://www.adcolony.com/privacy-policy/) Facebook (https://www.facebook.com/privacy/explanation) Unity (https://unity3d.com/legal/privacy-policy) IronSource (https://www.ironsrc.com/privacy-policy/ ) Applovin ( https://www.applovin.com/privacy/ ) Admob ( https://policies.google.com/privacy?hl=en ) Tap Research (https://www.tapresearch.com/legal/privacy-policy-en ) 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.|
If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly. You can opt-out from analytics by contacting us at firstname.lastname@example.org or in the games, Settings->Manage my Data.
You can withdraw your consent by changing your advertising settings on your 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.
To make a request, please let our Data Protection Officer know by sending an email to email@example.com
|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 corrected. We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).|
|Object to us processing data about you You can ask us to restrict, stop processing, or to 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 Lockwood 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;the personal data is processed in relation to the offer of a service to a child.|
|Obtain a machine readable copy of your personal data, which you can use with another service provider If we are processing data in order 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 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.|
After 5 years of inactivity, we will irreversibly anonymise all your personal data we hold about you which was collected through our Online Services.
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are encrypted, password protected and limited to essential employees only.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
If you would like to find out more about these safeguards, please let us know by writing to firstname.lastname@example.org.
All questions, comments or enquiries should be directed to email@example.com. We will endeavour to respond to any query or questions within three business days.
© 2019 Lockwood Publishing Limited. All trade marks are the property of the relevant owners. All rights reserved.