Privacy Policy

ISSUED BY LOCKWOOD PUBLISHING LIMITED

Last Updated: November 2019

1. 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.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games including our websites (http://www.avakin.com or http://lockwoodpublishing.com) (the “Website”), our online forums (the “Forums”) and user support centre (the “Support Centre”).  Together the Game(s), the Website, the Forums and Support Centre are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at
Email: privacy@avakin.com
Telephone: +44 0115 993 2387

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use. These are linked below:

• In respect of the Game(s): http://www.avakin.com/terms-of-service.
• In respect of the Support Centre: http://www.avakin.com/support.

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 may make changes to this Privacy Policy in 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 through the Games.

2. Information We May Collect About You

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; and
• information 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;
• your 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);
• the network connection type and speed;
• the IP Address;
• the 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.

Influencer Program
(“Influencer”)

If you provide it, we may process information to contact you for a potential influencer role. Personal data we may collect includes the following:

• Your name;
• Your mobile telephone number;
• Your email;
• Your age;
• Your social media accounts (YouTube, Instagram, Facebook, etc);
• Your videos.

Research and Surveys
(“Surveys”)

If you decide to take part in any surveys, although most of the time the surveys are aggregate, we may process information to verify if you are in the correct target audience, provide statistical estimates of the players’ characteristics and insight into players’ experience and interaction with the game. Personal data we may collect includes the following:

• Name;
• Email;
• Age;
• Game statistics;
• IP addresses for unique surveys;
• Telephone recordings if the individual provides consent.

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.

3. Why We Collect Information About You

To provide our Games to you

We will use information about you (including Basic Information, Third Party Log In Information, Analytics and User Content) for delivering our Games to you under the terms of use agreed between us. 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.

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 respond to your enquiries and requests for support and to enable you to use the Forums

We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre or Forums or through privacy@avakin.com and so you are able to use the Online Services, in accordance with the terms of use agreed between us.

To acquire new users and engage current users

We may process information (including some Advertising Data, Influencer 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, Surveys 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. See all the third party advertising networks we work with here: https://avakin.com/avakin-life-advertising-partners.

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 at the link provided above.

To prevent fraud and illegal activity

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.

We may also process personal data where necessary for the purpose of preventing or detecting unlawful acts and the safeguarding of children and individuals at risk. This may include processing your username, playerID (a unique identifier assigned to your account) IP address and chat logs.

We process ID and Address Information in order to pursue our legitimate interests in ensuring that users who have been banned and dispute that ban meet applicable age thresholds.

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 reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.

We work with Apple, Google, Amazon and Facebook to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).

4. Data Sharing

We will share your information with third parties only in the ways that are described in this Privacy Policy.

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.

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.

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).

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 Lockwood, our customers, or others.

Digital Content Stores: Where the Games are downloaded though Google Play, Facebook Gameroom, Amazon App Store and/or iTunes, we may disclose your personal information to any of them for the purposes of facilitating any in-Game payments made through these platforms.

Support Centre: We use a third party platform provider called Helpshift to manage any support requests, queries and issues raised by users via the Support in-game. Further details about the way in which Helpshift may collect and process your information can be found in their terms at https://www.helpshift.com/legal/privacy.

Other Processors: Where we use other third party processors, details are available here: https://avakin.com/avakin-life-processors.

5. Consumer Control and Opt-out Options

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 of analytics by contacting us at privacy@avakin.com.

You can withdraw your consent by changing your advertising settings on your device or by deleting the Game at any time.

6. Your Rights in Relation to Personal Data Which We Process Relating to You

You have the following rights over the way we process personal data relating to you, as set out 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 dpo@avakin.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.

7. Data Retention

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.

After 5 years of inactivity, we will irreversibly anonymise all your personal data we hold about you which was collected through our Online Services.

Children

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. 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. If you believe that we might have any information from or about a child under 13 years of age please contact us at privacy@avakin.com or through our Support Centre in game.

8. Security

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.

9. International Data Transfers

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:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

If you would like to find out more about these safeguards, please let us know by writing to privacy@avakin.com.

Contact Information

All questions, comments or enquiries should be directed to privacy@avakin.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.