ISSUED BY LOCKWOOD PUBLISHING LIMITED
Last Updated: November 2021
1. Introduction and General Terms
Telephone: +44 01158577740
• 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.
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.
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
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);
• 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
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
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
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;
• 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 provider, we may collect and store personal and non-personal information which is available on that third party provider, , provided that you have expressly agreed to the use of third party cookies within the Games. We will also receive technical data in order to ensure the Games connect to the correct 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.
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
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:
• 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
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.
If you provide it, we will use your telephone number to strengthen the account security
Taking part in activities outside of Avakin Life via Social Channels
When you take part in activities outside of Avakin Life, we might collect information about you and your public profile on social medias like profile picture, your voice, your unique id/name and messages you sent to us.
3. Why We Collect Information About You
To provide our Games to you
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
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, 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 increase security of your account
If you provide your telephone number to us, we will use it to send messages with security codes for new logins. This way, your account will have increased security and lower chances for hackers to gain unlawful access to your account.
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.
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 to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes,Google Play and the Amazon App Store).
To use your content in our Marketing campaigns
We might contact you to get your consent to use the content you created in Avakin Life for marketing purposes. This content will then be promoted by Lockwood on our social media channels or via our Marketing partners.
4. Data Sharing
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, 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 email@example.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 firstname.lastname@example.org.
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
After 6 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.
9. International Data Transfers
Whenever we transfer your personal data outside of the UK or 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 UK Government and the European Commission whichever is relevant.
• Where we use certain service providers, we may use specific contracts approved by the UK Government and the European Commission, whichever is relevant, which give personal data the same protection it has in the UK and Europe.
• Where we use providers based in the US, we may transfer data to them if the transfers are based on Standard Contractual Clauses approved by the relevant supervisory authority, EEA EDPB or UK ICO.
If you would like to find out more about these safeguards, please let us know by writing to email@example.com.
10. Your California privacy rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.
All questions, comments or enquiries should be directed to firstname.lastname@example.org. We will endeavour to respond to any query or questions within three business days.
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