Privacy and Cookies Policy

Please read carefully

This document is about how Eight Pixels Square respects your privacy when you use or play any of the following services:

(i) our websites, including www.eightpixelssquare.com and any other eightpixelssquare.com or eightpixelssquare.com sub-domains (“Sites”);

(ii) any of our online or mobile games, products or services, including mobile applications on iOS, Android and any other applicable mobile platform; and

(iii) any of our games, products or services (including support services) which may be accessible via a web application, third party platform or social networking service (including Facebook).

We’ll call them together our “Services“. By using any of our Services, you confirm that you have read, understood and agree to this privacy and cookies policy (“policy”). If you do not agree to this policy, please do not use any of the Services. If you have any queries, please email us at privacy@eightpixelssquare.com. We may change this policy at any time in which case we shall notify you of any changes to this policy by noting this on our Sites or otherwise within our Services. The changes will apply to your use of our Services after we have given notice. If you do not wish to accept the new policy you should not continue to use the Services. If you continue to use the Services after the date on which the change comes into effect, your use of the Services indicates your agreement to be bound by the new policy.

1. Introduction

1.1 Eight Pixels Square are committed to protecting and respecting your privacy. This policy sets out the basis on which we will process information we collect from you, or that you provide to us. This includes personal information (meaning information which, on its own or in combination with other information, can be used to identify you) and non-personal information. Please read this policy carefully so that you understand how we will treat your information.

2. A quick word about children

We recognise we have a special obligation to protect personal information obtained from children. We do not and will not knowingly collect information from any unsupervised child under the age of 13. For children under the age of 13 wishing to use the Services, written permission or other verifiable consent is required from a parent or guardian (details of which can be obtained from privacy@eightpixelssquare.com). In some countries, prior written permission or other verifiable consent may be also required from a parent or guardian for children under 18 years of age, as indicated in our Terms of Service.

3. The Data Controller

For the purpose of the GDPR, the data controller is Mobile Gaming Studios Limited t/a Eight Pixels Square (Company Number: 08324771) of Derby West Business Centre, Ashbourne Road, Mackworth, Derby DE22 4NB, United Kingdom.

4. Information we may collect from you

4.1 We respect your right to privacy and will only process personal information you provide to us in accordance with the GDPR, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.

4.2 The kinds of information which we may process include:

(a) Your name;

(b) Your email address;

(c) Your user name, ‘high score’ name or any other name used to identify yourself in any Services;

(d) Technical or other details about any device which you use to access the Services, including: Internet and/or network connection (including your IP address); your Media Access Control (MAC); your device Unique Device Identifier (UDID) or equivalent; your operating system, browser type or other software; your hardware or mobile device details (including your mobile device type and number and mobile carrier details); or other technical details;

(e) Details of your use of our Services including, but not limited to: metrics information about when and how you use the Services; traffic data; and your geographical location data;

(f) Details about your use of social networking and our Services. This includes certain information from Facebook (including access to your friends list as well as aggregated non-personal analytics data about our users) in accordance with Facebook’s terms and conditions; and

(g) Other personal or business information required in order to help you with any queries or support matters you may need assistance with via our forums or customer support service.

5. How we collect information:

5.1 We may collect and process information about you through the following means:

1. Contact Information submitted via our Sites in relation to a potential job: We often advertise jobs on our Sites and any information you choose to provide us will be used to assess you as a candidate and undertake criminal record and/or checks with references. If you subsequently join us as an employee, we may create a file in respect of your employment which shall be kept secure and only used for purposes relating to your employment. We will, however, provide you with further details on this at the time of you becoming an employee.

2. Account Information: Personal information that you supply when creating an account to use our Online Services e.g., our support forums (namely your date of birth, e-mail address and username (which may or may not be personal information depending on the username that you choose));

3. User Support Information: If you contact us for technical or customer support, we will keep a record of your name, contact details (such as email address or telephone number), a record of your call and/or correspondence along with a note of the games or issues relevant to your call.

4. Contests, Surveys & Promotions Information: If you enter any of our on-line contests, promotions or loyalty programs, we will collect personal information (such as your name, email address, postal address, birthday and contact phone numbers) in order to register you in the contest, promotion or loyalty program.

5. Technical and Usage Information when browsing our Sites: When you access and use our Sites, we collect technical information such as details about your computer system and details of your use of the Sites including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access such as server log files and tracking technologies including cookies, IP addresses, browser information, the date and time spent on our Sites and other similar information. Some of this information is collected through Google Analytics. We may be able to use IP addresses to personally identify you to enforce our Terms of Service and/or block certain IP addresses from our Sites if we believe that there has been misuse of our Sites. We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Sites and to deliver a better and more personalised service. They enable us:

• To estimate our audience size and usage pattern.

• To store information about your preferences, and so allow us to customise our Sites according to your individual interests.

• To speed up your searches.

• To recognise you when you return to our Sites.

Further information on the cookies that we use is set out in paragraph 6 below.

6. Personal information received from a Social Networking Site (“SNS”): When you choose to link to any of our Services via any SNS, you grant us access to certain personal information from your profile with that SNS. The extent of the personal information that we access varies for each game and SNS and will also be governed by the “Privacy Settings” you choose when you establish your account with the SNS. Please note that we have no control over what “Privacy Settings” are available on the various SNSs and we therefore recommend that you review the “Privacy Settings” on such sites. We may have access to some or all of the following personal information when you link to our Services through an SNS: your name, your birthday, your email address provided to the SNS, your profile picture, your user ID number and the user ID numbers of your friends that are also connected to our games.

7. Personal information received from a Mobile Device: When you access our Services as an “app” or “application” through a mobile device, we collect your unique device identifier, various information collected via the use of certain SDKs and other similar technologies as indicated in paragraph 6, and other device identifier and technical information such as your Google Play ID or Game Centre ID.
   
   

6. Cookies and other similar technologies

We use the following cookies and other similar technologies on our website:

We use the following cookies and other similar technologies in our games:

6.2 You can block cookies on our Sites by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our Sites will issue cookies as soon you visit it. You can block certain features of the above cookies and other similar technologies as indicated in their privacy policies. Importantly, we will not use information collected from the above technologies to perform targeted advertising unless we have obtained your prior consent to do so.

6.3 For further information about cookies, including how to refuse cookies, please visit http://www.www.allaboutcookies.org.

7. How We Use Personal Information

7.1 The information collected above may be used by us as follows:

1. Contact Information submitted via our Sites in relation to a potential job: We use this information to assess you as a candidate and undertake criminal record and/or checks with references.

2. Account Information: We use this information to verify your identity and allow you to access the features of our Services that require such account registration (such as our support forums).

3. User Support Information: We use this information to respond to the particular support query that you have raised.

4. Contests & Promotions Information: We use this information to ensure that you are entered into the contest/promotion and to let you know if you are a winner.

5. Technical and Usage Information (including Cookies information): We use this information to monitor and analyse traffic to our Sites, to improve our Sites, to personalise your experience on our Sites, to resolve technical problems with our Sites and to report aggregate information to our advertisers

6. Personal information received from a Social Networking Site (“SNS”): We use this information to allow you to link to the SNS and, if we are permitted to do so under the GDPR and direct marketing legislation, we will use your e-mail address collected from the SNS to send information about products and services of ours that we consider that you might be interested in.

7. Personal information received from a Mobile Device: We use this to identify you as a player and to allow you to play our games, as well as to improve the functionality and service of our games. Where you give your consent, we also use the information collected via the use of certain SDKs and other similar technologies as indicated in paragraph 6 to serve targeted adverts to you, as opposed to adverts that may not be of interest to you.

8. For Promotional purposes: If you choose to receive promotional information from us, or we are otherwise permitted to provide such promotional information to you in accordance with direct marketing legislation, regarding other products, game features, enhancements, special offers, contests or competitions, we will use your personal information, or permit selected third parties to use your personal information, to provide you with such promotional information.  Please note, even if you have consented to receiving such promotional information from us, you may opt out of receiving such information at any time by emailing us at privacy@eightpixelssquare.com. Even if you have opted out of receiving promotional materials, we may still need to contact you regarding changes to the Services or in relation to requests you have made to us.

9. For our chat services: Where you choose to participate in our chat services, we record the “chat entries” between users for each session of game play. We will delete this information on a regular basis, and in any event within 90 days of recording it.

Please note that we may also provide our advertisers with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Finally, in addition to the above listed information, the Services allow users to post messages or photos, communicate with other users, post comments on message boards or send emails to other uses. We record these communications on our servers in order to protect the safety of other users. Please be aware that any personal information and/or photographs, videos or images that you provide through the online chat rooms, message boards, profiles or similar forums available on our Sites will be public information that may be read, viewed or used by other users of the Services. Any such personal information that you provide or post will not be private or confidential. You shall be solely responsible for any personal information, photographs or videos that you post to the forums available on our Sites and, where you provide any personal information about any other person or entity you represent and warrant that you have that person’s or entities consent to do so.

8. Grounds For Processing

8.1 We rely on the following processing grounds to collect and use the above listed information:

1. Contact Information submitted via our Sites in relation to a potential job: We rely either on legal obligation or legitimate interests depending on what information you supply to us. Some information will be required in order for us to fulfil our duties under applicable employment legislation, other information will be in our legitimate interests. It is in our legitimate interests and necessary to collect such items of personal information because this is necessary in order to assess whether you are a suitable candidate for our team. The items of personal information collected and for which we rely on legitimate interests, are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

2. Account Information: For the information that you submit to create an account that is not mandatory, we rely on consent. It is your choice as to whether to supply such information and you can still have an account without it. For the information that you supply that is mandatory, we rely on legitimate interests as it is in our legitimate interests and necessary to collect such information in order to create an appropriate account and help to e.g., ensure that you are who you say you are and not abusing the use of our support forums for example. The items of personal information collected and for which we rely on legitimate interests, are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

3. User Support Information: We rely on legitimate interests to collect this information as it is in our legitimate interests and necessary to collect such information in order to be able to respond to your support query in the most efficient way possible. The items of personal information collected and for which we rely on legitimate interests, are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

4. Contests & Promotions Information: We rely on consent to collect this information as it is your choice as to whether to participate in such contest or promotion.

5. Technical and Usage Information (including Cookies information): We rely on legitimate interests to collect this information as it is in our legitimate interests and necessary to collect such information in order to be able to carry out the technical support and management of our Sites that we need to do to make them run as efficiently as possible. The items of personal information collected and for which we rely on legitimate interests, are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

6. Personal information received from a Social Networking Site (“SNS”): We rely on legitimate interests to collect this information as it is in our legitimate interests and necessary to collect such information in order to allow you to sign-in to and use our games and make the game playing experience as efficient as possible. The items of personal information collected and for which we rely on legitimate interests, are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection. The only time we rely on consent is in relation to the use of your e-mail collected via the SNS where we obtain your consent where required under applicable direct marketing legislation to send you appropriate information about products and services that we consider you may be interested in.

7. Personal information received from a Mobile Device: With the exception of where we use such information to serve targeted adverts (where we rely on consent), we rely on legitimate interests to collect this information as it is in our legitimate interests and necessary to collect such information in order to be able to carry out the technical support and management of our games that we need to do to make them run as efficiently as possible. The items of personal information collected and for which we rely on legitimate interests, are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

8. Promotional purposes: We rely on legitimate interests except where we need to rely on consent under direct marketing legislation.

9. Chat services: We rely on consent as it is your choice as to whether to participate in the chat services.

9. Where we store your personal information, how it is kept secure and how long we store it for

9.1 The information that we collect from you may be transferred to, stored and processed at a destination outside the European Economic Area (“EEA”) (including the USA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services and the processing of your payment details. Where we transfer your personal information outside the EEA we have put in place appropriate adequacy procedures to ensure that such transfers are GDPR compliant. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy.

9.2 If you have a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. Please don’t share it with anyone.

9.3 All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our servers via any of our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9.4 We retain your personal information in accordance with our retention policy – if this is obtained in relation to you applying for a job, for 2 years after you end your employment with us, and if this is obtained in relation to you using any of our Services, for 2 years after your last active session. We will, however, retain a copy of your player save file for 6 years because this doesn’t contain any personal information and allows you to reactivate the game in question with your last progress applied should you wish to do so.

9.5 Please remember that any communications you have via our Services, including for example our games, may reveal your screen name, other details about you and the content of any communications by you to other users. We are not responsible for the activities of other users or other third parties whom you choose to provide your information to or otherwise interact with (whether via our Services or otherwise)

10. Disclosure of your information

10.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

10.2 We may disclose your personal information to third parties:

(a) In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.

(b) If we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.

(c) If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce and other agreements; or to protect our rights, property, or safety of our customers or others.

10.3 We may also share your non-personal information with third party partners who work with us to provide the Services to you (for example, third party developers who we’ve worked with to create one of our games). These include service providers assisting us with: (i) ad mediation; (ii) ad monetization; (iii) hosting and storing the information that we collect; (iv) providing support services; (v) marketing and mail campaigns; (vi) payment processing; and (vii) website analytics. The type of information that we provide to such service providers depends on the nature of the service that they are providing e.g., we would pass your contact information to receive a newsletter to our marketing and mail campaign service providers, we would pass your user support information to our support services provider, and we use certain third party processors to collect various items of information that comprise the Technical and Usage Information (as detailed more particularly in paragraph 6 above).

11. Third party sites

Our Services may, from time to time, contain links to and from the websites or services of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites or services may have their own privacy policies and that we do not accept any responsibility or liability for these policies, nor do we endorse such websites or services. Please check carefully before you submit any personal information to these websites or services

12. Push notifications and local notifications

We may, with your consent, send push or local notifications to your mobile device to provide game updates and other relevant messages. You can manage push and local notifications from the Options or Settings section within the relevant game. You may also be able to manage them from your device’s settings section for the relevant game.

13. Your rights

You can contact us using the details set out in paragraph 15 below if you wish to: (a) access a copy of the personal information that we hold about you; (b) correct any items of personal information that we hold about you; and/or (c) have any items of personal information that we hold about you erased or object to our processing of such items of personal information.

14. Changes to our privacy and cookies policy

Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

15. Contact

We welcome any questions, comments and requests regarding this policy, which should be addressed to privacy@eightpixelssquare.com. You also have the right to make a complaint to the ICO by contacting them at any time.