Last Updated: September 5,2022
If you are located anywhere other than the United States, this General Privacy Notice applies to you. If you are located in the United States, please scroll down to view the U.S. Privacy Notice.
1.GENERAL PRIVACY NOTICE (WORLD EXCEPT US)
Hi. We’re CDE Entertainment Ltd. (“we,” “our,” or “us” – for contact details see below under Section 13), an independent controller.
Please take the time to read this Privacy Notice, as it explains how we process and protect your personal data (referred to as “personal information” in some jurisdictions).
3.HOW & WHEN WE COLLECT YOUR PERSONAL DATA
From the moment you begin interacting with us, we are collecting personal data. Sometimes the personal data we collect is provided by you and sometimes it is collected automatically.
You give us data if and when you: register or update a user account with us, use our paid-for services, play one of our games, enter one of our tournaments, apply for a job with us, attend an interview or assessment, opt-in to receive our marketing messages, subscribe to our mailing lists, call us, email us, live chat with us online, chat to us in-game, make a purchase from us, enter one of our prize draws or competitions, answer one of our surveys, fill in a form, conduct a search or post content on our website, interact with other users on our online services, register to attend our events, ‘follow’, ‘like’, or post to or interact with our social media accounts.
We collect your data automatically if and when you: access our website pages, interact with other users on our online services, open an email from us, login to a user account that you register with us, play our games online, live chat with us, message us or other users in-game or make a purchase from us.
4.TYPES OF PERSONAL DATA WE COLLECT
Depending on the specific services you use and how you interact with us, we may collect various types of personal data as further described in this section.
a) Contact Details: Your name, address, telephone number and email address.
b) Account Profile Data: Your name, email address, birth date, gender, username and password.
c) Financial Data: Your bank account number, credit/debit card details, currency, amount paid, electronic payment processor details and billing address.
d) Identifiers Relating to You: Your birth date, IP address, login information, social media username(s), browser type and version, Internet service provider, date and time of access request, time zone difference to Greenwich Mean Time (GMT), access status/HTTP status code, data volume transferred, websites from which you come to our website, websites accessed through our websites, time zone setting, browser plug-in types, geolocation information, operating system and version, cookies and cookie IDs, Google AdID, Apple IDFA and other unique device IDs.
e) Data On How And When You Use Our Websites: Your URL clickstreams (the path you take through our site), products/services you view or purchase, page response times, download errors, how long you stay on our pages, what you do on those pages and other actions.
f) Data On How You Purchase And Use Our Games And Services: Your gaming platform, game version, mobile and hardware identifiers, device event information, crash reports, language or subtitle options, game scores, game metrics, achievements, rankings, play time, feature usage, player performance and progression, purchases, time zone, timestamp, session duration, wish lists, challenges or gifts sent to other players and number of friends on the platform.
g) Survey Data: Any data that you decide to provide to us when you complete one of our surveys.
h) Application Data (only when you apply for job roles with us): Name, email address, employment history, references, education history, results of pre-employment screening and background checks, relevant experience, achievements, skills and qualifications and the outcome of any interviews or tests that are part of the recruitment process.
i) Data Recorded At Live Events: Photographs and videos (including audio) of you.
j) Personal Data Provided To Us By Third Parties: Game Platforms: Nickname, username, user ID, friends list, email address, geolocation, language, user preferences, date of birth and games you have played. Mobile Platform Providers and App Stores: Username, device ID, purchase history and geo-location. When you log in with your Facebook account: Account ID, email address and friends playing the same game. When you link a user account that you register with us to a Game Platform Account: Account ID, nickname, user ID, email address and our games which you are playing.
k) What about special categories of data / sensitive data?
If you have been selected to participate in an accessibility-related player research group, we may ask for health data related to your accessibility needs for the purpose of analysing accessibility as it relates to our game development. Otherwise, we do not actively collect any “special categories of data” about you (data that is intended to identify your racial or ethnic origin, political opinions, religious/philosophical beliefs or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health data, or data about your sexual life or orientation). The same applies to personal data relating to criminal convictions and offences or alleged offences. Please don’t send us your unsolicited special categories of data or post them anywhere on our services.
l) What about children’s data?
You must be at least 14 years old to use any of our services or games, as we do not target our games to children under 14 and do not knowingly collect any personal data from any person under 14. If you think we have unintentionally collected personal data from someone under the age of 14, please let us know by contacting us at the email address at the end of this document.
5.WHY & HOW WE USE YOUR PERSONAL DATA
We will use your personal data only for certain specified reasons and only when we have a lawful basis to do so. Which of the following reasons is applicable to you depends on the type of relationship we have with you and how we interact with you. For example, we will not use your personal data for the purpose of processing payments unless you’ve made, or attempted to make, a purchase from us.
a) Registering your account
When you sign up to use our services or register a user account with us, we will use the details you provide on your account registration form to process your registration and provide the services you’ve agreed to receive.
If you are located in the EU/EEA or the UK, our legal basis for this use of your personal data is: performance of contract.
b) Keeping our websites and gaming services running
Providing you our games and services online, access to our websites, login authentication, age verification, remembering your settings, processing payments, populating leaderboards, hosting and back-end infrastructure and keeping our websites and services secure.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data are: performance of contract, to comply with our legal obligations, and legitimate interests to keep our services running.
c) Enabling you to communicate with other users
Certain parts of our websites and online services enable you to communicate and interact with other users. We will use personal data you have provided us to enable these interactions and communications on our websites and online services.
If you are located in the EU/EEA or the UK, our legal basis for this use of your personal data is: performance of contract.
d) Processing payments
We will use your personal data to process payments for our goods and services. If your bank provides account update services and you have registered your payment card number or expiry date in our systems, we may automatically update this information when it changes.
If you are located in the EU/EEA or the UK, our legal basis for this use of your personal data is: performance of contract.
e) Targeted advertising
Through cookies, clear GIFs, web beacons and tracking pixels we will use your personal data to deliver relevant advertisements and offers to you and measure the effectiveness of the advertising and offers. These technologies connect your behaviour across different websites, mobile apps and devices and enable tailored advertising to be served to your game, web browser, or mobile device. Please also see below under Section 8 regarding cookies and our Cookies Notice (links below).
If you are located in the EU/EEA or the UK, our legal basis for this use of your personal data is: your consent.
f) Social media
We will use your personal data to communicate with you if you message us, respond to our posts, “like” our posts, tweet or retweet us or otherwise interact with us directly on social media platforms. We also analyse social media postings and trends to understand customer sentiment about our games and services.
If you are located in the EU/EEA or the UK, our legal basis for this use of your personal data is: our legitimate interests in promoting our brand and communicating with interested individuals.
g) Anti-cheat, anti-tampering, fraud, and unauthorised and unlawful activity detection, prevention and investigation
We use the personal data you provide us and the personal data we collect about you to enforce our rules and policies, protect our customers and business, maintain the competitive integrity of our games, and investigate and respond to fraudulent, unauthorised or illegal activity on or related to our current or future services. We may also use your information for machine learning behavioural predictions to detect and prevent fraudulent activities on our services.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data are: our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so.
h) Community and customer support
When you use our communities or customer support, we will use your personal data for handling enquiries or complaints, troubleshooting and solving technical issues over live chat, phone, email and in-game chat, making necessary changes to our products and services and monitoring your participation in our forums and all parts of our services that allow you to publicly post information or interact with other users.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data are: performance of contract, our legitimate interests to provide you with customer service, our legitimate interests in providing the correct products and services to our website users or to comply with our legal obligations.
i) Improving and continually developing our games, services and websites
We carry out surveys and analytics and research on in-game data collection and related metrics to understand how our customers are playing games and the effectiveness of our marketing campaigns. We also use your personal data to undertake player segmentation (profiling), cheat detection and prevention, machine learning (we sometimes use carefully selected third parties to do this on our behalf), general management of our websites, traffic optimisation and heat mapping (including through the creation of animated representations) of your usage of our websites.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data are: performance of contract; consent or our legitimate interests in learning about the types of people who are interested in our games, websites, and services; to keep our games, online services, and websites updated and relevant; and to develop our business, understand how our customers play our games, and inform our marketing strategy.
To evaluate your suitability for a role that you have applied for we will use your personal data to verify your application details, academic qualifications and work experience, perform background checks, review and audit our recruitment processes and its outcomes and identify any future employment opportunities that you may be suitable for.
If you are located in the EU/EEA or the UK, our legal basis for this use of your personal data is: performance of contract or our legitimate interests to recruit new employees or contractors.
k) Contests, prize draws, and tournaments
When you participate in our contests, prize draws, tournaments or other promotional events we run from time to time, should you decide to participate in them, we will use your personal data to process your entry as well as to communicate with you and award and send you certain prizes or rewards, either digitally or physically, if you have qualified to receive them. In some cases our promotional events may have a “leaderboard,” entry list, or similar element, in which case we may display your name or other information you submitted on such a publicly accessible list. Some contests, prize draws, and tournaments will also involve publicly displaying your entry in media throughout the world.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data are: your consent or performance of contract.
l) Live Events
When you attend or join our live events, we may photograph you and record videos in which you, your appearance, or your voice may be recognisable.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data are: consent or our legitimate interests if you are a guest at the event or consent or performance of contract if you are a contestant.
m) Digital marketing and advertising
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data is: consent and to the extent consent is not required our legitimate interests to provide you with marketing communications or advertising where we may lawfully do so.
n) Direct marketing
Where you have consented, we will use your personal data to send you communications about our services, products and features that you have agreed to receive directly via email. We also use machine learning to predict the effectiveness of direct marketing campaigns for our customers and to tailor campaigns and direct marketing communications, including through purchase history and game play behavioural analysis.
If you are located in the EU/EEA or the UK, our legal bases for this use of your personal data is: your consent.
o) Participation in investigations and proceedings (including judicial proceedings)
Under very specific circumstances, we will process your personal data and share it with third parties (including law enforcement bodies) in order to respond to or investigate fraudulent, unauthorised or criminal (or potentially fraudulent, unauthorised or criminal) activity on or related to our systems, services, or events, including the unauthorized disclosure of non-public information related to current or future services. We may also be required by law to disclose your personal data to the police or to another law enforcement, regulatory, government or other public body in your country of origin or elsewhere, including upon receiving a legally valid request to do so. We may also be required by law to disclose your personal data to third parties in response to a court order, subpoena, or other compulsory process.
If you are located in the EU/EEA or the UK, our legal bases for this is legal obligation or legitimate interest.
6.WHAT THE DIFFERENT LEGAL BASES MEAN
This section explains what the legal bases we rely on for processing your personal data actually mean (as applicable in your local jurisdiction).
You have provided consent for us to process your personal data for a specific purpose (if you are located in the EU/EEA Art. 6 (1) a GDPR). You have the right to withdraw this consent at any time.
b) Performance of Contract
We need to process your personal data for us to fulfil our contractual relationship with you or in order to take steps at your request prior to entering into a contract (if you are located in the EU/EEA Art. 6 (1) b GDPR).
c) Legitimate interests
We need to process your personal data for our legitimate interests, or the legitimate interests of a third party, e.g., in conducting and managing our business and our relationship with you, except when such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular when the data subject is a child (if you are located in the EU/EEA Art. 6 (1) f GDPR). When we use your personal data for our legitimate interests, we take into account any potential impact that such use may have on you.
d) Legal obligation
We have a legal obligation under applicable law to process your personal data (if you are located in the EU/EEA Art. 6 (1) c GDPR).
7.KEEPING YOUR PERSONAL DATA SECURE
We treat your personal data with care and take reasonable steps to protect it, including the use of physical, technical and administrative safeguards to protect your personal data from unauthorised access, use or disclosure.
For this reason, we secure access to all transactional areas of our websites and apps, restrict access to your personal data, secure and tokenise transactional information and regularly monitor our systems for possible vulnerabilities and attacks.
If you believe your personal data has been breached, please contact us at the email address at the end of this document.
8.RECIPIENTS WITH WHOM WE SHARE PERSONAL DATA
Depending on the purpose for which we collect your personal data or the nature of our interaction with you, we may use third parties to process some of your personal data (for example, we engage third parties to process information about your purchases and use of our games). We require that these third parties use only the information they need to perform their specific services as specified in our contract with them. If we stop using any such third party’s services, we require that your personal data held by them is either securely and permanently deleted or rendered irreversibly anonymous. In all cases, we apply measures to keep your data safe and your privacy protected.
We share your personal data with third-party IT companies who support our website, online services and other business systems, payment services providers who process your payments for goods and services, fraud detection, investigation and prevention companies who help us detect, investigate and prevent cheating, abuse, fraud, tampering or other unauthorised use of or disclosure of non-public information about our current and future services and direct marketing companies who help us manage our electronic communications with you.
We may share your personal data with Google, Facebook and other third-party advertising partners so they can show you our products and services that might be of interest to you while you are on a social media platform, browsing the internet or playing our mobile games (see above under Section 4(e)). For example, if you provide us with your email address we may share it with Facebook so that you can receive tailored advertising from us when you use Facebook, and so that other users of Facebook who share similar interests to you can also receive tailored advertising from us.
We may share your personal data with governmental authorities, courts, external advisors, and similar third parties that are public bodies or with other (private) third parties as required or permitted by applicable law (see above under Section 4(o)).
10.WHERE YOUR PERSONAL DATA IS PROCESSED
We are a global organisation, so we sometimes will share your personal data with our other offices, or with other third parties and suppliers, who are located outside your country and the European Economic Area (“EEA“) or may have relevant operations outside of your country and the EEA, such as in the USA, where the data protection laws may provide a different level of protection compared to the laws in your jurisdiction.
When it is necessary for us to transfer your personal data out of the EEA and/or the UK, we will do so only when the transfer is authorised under applicable law, including when the transfer is made to a country the European Commission has deemed to have adequate data protection laws. The countries which provide an adequate level of data protection from a European data protection law perspective currently include Andorra, Argentina, Canada, Faeroe Islands, Guernsey, the State of Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland and the Eastern Republic of Uruguay. With regard to data transfers to other recipients outside the EEA we provide appropriate safeguards, in particular, by way of entering into data transfer agreements adopted by the European Commission (e.g., based on standard contractual clauses) with the recipients or taking other measures to provide an adequate level of data protection, where this is required under applicable law.
11.HOW LONG WE KEEP YOUR DATA
We store personal data as long as necessary to fulfill the respective purposes. When we no longer need personal data to comply with our contractual or legal obligations, we will securely destroy or irreversibly anonymise your personal data. We will deviate from this general policy only if we have to fulfill legal or official obligations (e.g., statutory retention obligations, including statutory retention periods which can result from commercial and tax law—for example, in the EU or Germany, the retention periods are typically between six and ten years for contracts, notifications and business letters) or if we need it to preserve evidence within a statute of limitation.
12.YOUR RIGHTS OVER YOUR PERSONAL DATA
Under applicable data protection law, you have the right, in addition to the right to withdraw your consent at any time (the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal), to make a complaint to a data protection supervisory authority. In addition, you may be entitled to the following rights (though these rights may be restricted by national law). To exercise your rights, please contact us using the contact details provided under 14 below.
a) Your right of access
You may have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, if that is the case, to request access to the personal data. The right of access includes, among other things, access to the purposes of the processing, the categories of the personal data is being processed, and the recipients or categories of recipient to whom the personal data is being disclosed. However, this right is not unrestricted as the rights of other persons may limit your right of access.
In certain circumstances, you have the right to receive a copy of the personal data processed by us. For further copies requested by you, we charge a reasonable fee, where relevant calculated on the basis of administrative costs
b) Your right to rectification
You have the right to request that we rectify information you think is inaccurate or complete information you think is incomplete. This right always applies.
c) Your right to erasure
You have the right to request that we erase your personal data in certain circumstances.
d) Your right to restriction of processing
You have the right to request that we restrict the processing of your personal data in certain circumstances. In that case, the data concerned will be marked and only processed by us for certain purposes.
f) Your right to data portability
Subject to certain conditions, you have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and the right to transmit that data to a different controller without hindrance from us.
g) Right to object
Subject to certain conditions, you have the right to object at any time to the processing of your personal data by us on grounds arising from your particular situation, and we can be required not to process your personal data any longer.
If personal data is processed for direct marketing purposes, you have an additional right to object at any time to the processing of personal data in relation to you for the purpose of such marketing. This also applies to profiling where this is connected to direct marketing. In that case, we will no longer process the applicable personal data for these purposes.
13.CHANGES AND UPDATES TO THIS PRIVACY NOTICE
As our services and products change from time to time, you should expect this Privacy Notice to change as well. We reserve the right to amend this Privacy Notice at any time, for any reason. We will make all reasonable endeavours to notify you of any changes. We may also email periodic reminders of this Privacy Notice of any material changes to this Privacy Notice. Nevertheless, you should check here regularly to see the current Privacy Notice that is in effect and any changes that may have been made to it.
14.ANY QUESTIONS? CONTACT US
You made it to the end! We hope you enjoyed reading this Privacy Notice and we commend you on your dedication to understanding how we handle your personal data and your rights to control it. If this Privacy Notice hasn’t answered all your questions, or if you have any comments or ideas about how we can make this Privacy Notice even better, or if you wish to file a complaint, or make any request authorized by this Policy, please don’t hesitate to contact us at the following mailing address or email:
For CDE Entertainment Ltd.:
CDE Entertainment Ltd.
100 New Bridge Street
United Kingdom, EC4V 6JA
PrivacyNotice [at] cdeentertainment.com
1.PRIVACY NOTICE (US)
Hi. We’re CDE Entertainment Ltd.
This Privacy Notice describes how CDE Entertainment Ltd. (collectively “Company,” or “we,” “our,” or “us”) collect, use, and share information about you when you use our various products and services (collectively, the “Services”). This Privacy Notice applies if you are accessing the Services in the United States or if you are visiting a website where this Privacy Notice is posted. This Privacy Notice does not apply to information collected by third parties that may interact with our Services (e.g., a social media plug-in such as a Facebook like button), or to our data collection activities outside of our Services (e.g., through websites that support specific products, which may have different privacy policies). It also does not apply to information collected through the Services if you are located outside of the United States. For all other locations outside of the U.S. please see our General Privacy Notice.
By using our Services, you consent to this Privacy Notice and the Terms of Service associated with the applicable Service and our collection, storage, sharing and use of your information and data, and other activities, as described. If you do not agree to this Privacy Notice, do not continue to use the Services, and in the case of mobile applications, uninstall the mobile applications immediately.
For personal data transferred from the United Kingdom, the European Union, and Switzerland, we will provide appropriate safeguards, such as through use of standard contractual clauses.
2.The Types of Information We Collect from You and How We Collect It
Depending on the specific Services you use and how you interact with us, we may collect various types of information. This information includes information that can be used to identify you personally.
Sometimes you choose to provide this information to us and other times we collect it from you automatically. For example, you may choose to provide us certain information if you register or update a user account with us, use our paid-for Services, apply for a job with us, subscribe to our mailing lists or agree to receive marketing messages from us, call us, email us, live chat with us online or in-game, make a purchase from us, enter one of our competitions or sweepstakes, respond to one of our surveys, post in our forums, conduct a search or post content on our websites, chat or interact with other users on the Services, register to attend our events, or “follow,” “like,” post to, or otherwise interact with our social media accounts. And we collect your information automatically when you browse or use our websites, chat or interact with other users on the Services, receive an email from us, login to a user account that you registered with us, play one of our games, live chat with us online or in-game, or make a purchase from us.
Here are some examples of the types of information we may collect from you when you use the Services, including in the past 12 months.
– personal details – e.g., your name, address, telephone number, email address, and birthday.
– financial information – e.g., your bank account number, credit/debit card information, and billing address.
– account profile data – e.g., your username, password, password hints, and other information related to your account registration.
– information relating to the browser or device you use to access the Services – e.g., IP address, login information, browser type and version, time zone setting, browser plug-in type, operating system and version, Google AdID, Apple IDFA, or other device information that uniquely identifies the device or application you are using.
– information on how you use our websites – e.g., your URL clickstreams (the path you take through our websites), products/services you view or purchase, webpage response times, download errors, how long you stay on our webpages, and what you do on those webpages.
– information about the location of your device – e.g., precise location data with your opt-in consent (such as latitude/longitude) and imprecise location data (such as data derived from an IP address or that indicates a city or postal code).
– information on how you purchase and use our games and products – e.g., the gaming platform you are using, game version, mobile and hardware identifiers, device event information, crash reports, language or subtitle options, game scores, game metrics, achievements, rankings, play time, feature usage, player performance and progression, purchases, timezone, timestamp, session duration, challenges or gifts sent to other players, and number of friends on the platform.
– information we receive when you interact with third-party platforms – e.g., game consoles (nickname, username, friends list, email address, geolocation, language, and date of birth) or mobile platform providers and app stores (username, device ID, purchase history, and geolocation).
– employment information (only when you express an interest in working for us or apply for job roles with us) – e.g., name, address, email address, phone number, employment history, references, education history, results of pre-employment screening and background checks, relevant experience, achievements, skills and qualifications, and the details and outcomes of any interviews or tests that are part of the recruitment process.
Information You Disclose Publicly: The Services may permit you to submit content on various public channels like blogs and message boards, as well as through gameplay. We or others may store, display, publish, or otherwise use this content in perpetuity, and may or may not attribute it to you. Please note that we do not control who will have access to information you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Please think carefully before sharing any information on the Services.
Information Third Parties Provide about You: We may, from time to time, supplement the information we collect directly from you on our Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor content and ads to you, and to offer you opportunities that may be of interest to you.
Third-Party Logins: The Services may include the option to register or log in to an account using Facebook, Google, Steam, or another third-party service. By doing so, you may provide us with access to certain information from your social media profile, such as your name, email address, photo, gender, birthday, location, friends, people you follow/who follow you, content you post, or posts you like. Please be aware that these third parties are not subject to this Privacy Notice, and we are not responsible for their practices. You should review the applicable third parties’ privacy policies before using their tools to interact with the Services.
Tracking Technologies: We use various technologies to collect information from you, including as follows:
– Log Files. A log file is a file that records events that occur in connection with your use of the Services.
– Cookies: A cookie is a data file placed on your device when you visit the Services. Cookies may be used for many purposes, such as remembering you and your preferences, supporting our security features, and bringing you relevant advertising. Please review our Cookies Policy (available at http://www.cdeentetainment.com/cookies ) for more information.
– Embedded Scripts: An embedded script is programming code that is temporarily downloaded to your device and used to collect information about your interactions with the Services, such as the links you click on.
– Pixels: A pixel (also known as a web beacon) is code embedded in a website, video, email, or advertisement that sends information about your usage to a server. When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a third party to place or read cookies on your browser. Pixels are used in combination with cookies to track browser activity. We may incorporate pixels from third parties that allow us to track our conversions, bring you advertising both on and off the Services, and provide you with additional functionality, such as the ability to connect our Services with your social media account.
– ETag or entity tag: A feature of the cache in browsers, an ETag is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. ETag tracking may generate unique tracking values even where you block HTTP, Flash, and HTML5 cookies.
– Location-Identifying Technologies: GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device.
– App Technologies: There are a variety of technologies that may be included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include third party SDKs, which are code that send information about your usage to a server. These SDKs allow us to track conversions, bring you advertising, and provide you with additional functionality, such as the ability to connect your social media account.
For more information on analytics, advertising, related tracking technologies, and your choices, please visit the Ads and Analytics and Your Choices sections below.
3.How We Use the Information We Collect from You
We may collect and use your information for business and commercial purposes in accordance with the practices described in this Privacy Notice. The purposes for collecting and using your information, including in the past 12 months, include:
– to provide you the Services, including by authenticating your login information, verifying your age, remembering your settings, and hosting and providing backend infrastructure for our websites and games;
– to improve or develop the Services, including by optimizing traffic, conducting in-game data collection, analytics, and research (including profiling and the use of machine learning), preventing and detecting cheating, managing landing pages, and heat mapping our websites;
– to provide customer support, including troubleshooting and resolving technical issues over live chat, phone, email, or in-game chat;
– to provide you information that you have requested or agreed to receive, such as electronic newsletters, special offers, or promotional materials;
– to process payments or transactions;
– to process your registration of a user account with us;
– to communicate with you when you message us, respond to our posts, “like“ our posts, tweet or retweet us, or otherwise interact with us on social media platforms;
– to process your entry into contests, sweepstakes, surveys, or other promotional events that we run from time to time, should you decide to participate in them (in some cases our tournaments may have a “leaderboard“ element, in which case we may display your name on a publicly accessible leaderboard);
– to deliver relevant advertisements or offers to you (or people like you), and to measure the effectiveness of these advertisements and offers;
– for Services that allow you to communicate with other users, to enable those communications;
– to enforce our rules and policies and protect the competitive integrity of our games;
– to investigate and respond to fraudulent, unauthorized, or illegal activity on the Services;
– to monitor your participation in our forums and all parts of the Services that allow you to post information or interact with other users;
– for internal business purposes;
– for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Notice.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.
4.How We Share Your Information
We share information we collect in accordance with the practices described in this Privacy Notice. The categories of parties with whom we share information, and have shared information in the past 12 months, include:
Service Providers. We use service providers to help support and operate the Services or to perform certain functions on our behalf. If we share your information with service providers, we will only provide them with information they reasonably need to perform their specific services for the purposes we specify in our contract with them, although we may permit them to use information that does not identify you for other purposes. If we stop using their services, we will require that any of your information that they hold be securely and permanently deleted or de-identified so that it does not identify you. In all cases, we will apply measures to help keep your data safe and your privacy protected.
Here are some examples of the types of service providers with which we may share your information:
– information technology companies who support our websites, online services, and other business systems;
– direct marketing companies who help us manage our electronic communications with you;
– payment processors who facilitate purchases from us and help protect against fraud;
– fraud detection and prevention companies who help us prevent cheating, abuse, fraud, tampering, or other unauthorized use of the Services;
– applicant-tracking providers who process your application to a job opening we have posted online;
Analytics and Advertising. We may share information with vendors and other parties for analytics and advertising related purposes. For example, we share information with analytics companies who help us analyze how you use the Services, and ad partners like Google and Facebook, so that they can show you products or services that might interest you. These parties may act as our service providers, or in certain contexts, independently decide how to process your information.
Business Partners. We may share your information with our business partners for various purposes. Here are some examples of the types of business partners with which we may share your information:
– console or platform providers who allow you to purchase, access, or play our games;
– companies who help us develop the Services or make them available to you;
– companies who administer or help sponsor contests, sweepstakes, or surveys you enter into.
Third-Party Locations and Services: When you are on the Services, you may be directed to other sites or services that are operated by third parties outside of our control. For example, if you click on a link displayed on the Services you may be taken to a different site. We may share information at your request or direction. We are not responsible for the data collection and privacy practices employed by these third parties. We encourage you to pay attention when you leave our Services and to review the privacy policies of any third-party locations you go to.
Administrative and Legal Disclosures: We may disclose your information to third parties: (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (ii) to satisfy any applicable law, regulation, subpoena, or governmental requestor legal process, or any legal process in connection with a court proceeding or arbitration, if in our good faith opinion we are required or permitted to do so by law; (iii) to investigate potential violations of policies or terms applicable to the Services; (iv) to protect the safety, rights, property or security of the Services, our staff, users, or any other third party; or (v) to detect, prevent, or otherwise address fraud or threats to security.
Business Transfers: We may share your information with our affiliate companies within and outside of the United States. In the event some or all of our company will be acquired by another party, we may share your information with the acquiring party.
Consent: We may share your information for other purposes if we have disclosed that purpose to you and you have consented to it.
De-identified Information: We may share aggregated information that does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law.
5.Ads and Analytics
There are various ways in which you can exercise choice and control over the information you provide to us on the Services. Here are some examples:
Limit the Information You Provide to Us: You can stop all prospective collection of information on our Services by uninstalling and ceasing to interact with the Services. You can also decline to provide information we request from you, although doing so may prevent you from using certain parts of the Services (e.g., you will not be able to create an account with us if you do not provide your email address and other information we need to process your registration). With respect to our mobile applications, you may use the standard uninstall process supported by your device, the app, or the marketplace or software through which you acquired the app to stop all prospective information collection through the app.
Change Your Communications Preferences: You may cancel or modify the email communications you receive from us by following the instructions contained within our promotional emails or, where applicable, by logging into your account and adjusting your settings. This will not affect subsequent access to the Services. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and service announcements, and you will continue to receive these transactional account messages even if you opt-out of receiving our promotional email communications.
Interest-Based Advertising Opt Outs: Some of the advertisers and parties that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising, visit http://www.aboutads.info/choices for website opt-out choices and http://www.aboutads.info/appchoices for mobile app opt-out choices. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any opt-out options or programs of any other parties or the accuracy of their statements regarding their programs.
Cookies: You may also be able to manage cookies by changing your browser settings. For certain websites that display a cookie banner at the bottom of the page, you may also have the option to control certain types of cookies by using this banner. Some features of the Services may not function properly if you choose to disable cookies, and some types of cookies may not be disabled using browsers. In some instances, especially with respect to mobile apps, we may require you to uninstall/not use the Services rather than have a poor experience from disabling cookies. Please review our Cookies Policy (available at http://www.cdeentertainment.com/cookies) for more information.
Location Data: For our mobile apps, you can turn off our collection of precise location data through the settings on your device. You can stop collection of all location data through a particular app by uninstalling that app.
App Technologies: For our mobile apps, you can reset your mobile ad Id through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074. For information on how to do this on Android devices, visit www.google.com .
Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, unless and until the law is interpreted to require us to do so, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com/.
Accounts and Forums:
You may review, correct, update, or request the erasure of account information you have provided to us by contacting us by email at one of the addresses listed in Section 11 below. We may require additional information from you to allow us to confirm your identity and properly respond to your request. Nothing in this Privacy Notice is intended to limit any additional rights you may have under local law.
Please note that it is not always possible to completely remove or delete all of your account information from our databases and residual data may remain on backup media. Also, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
You may remove content you have posted on our forums by logging into your account, directly accessing your post, and using the editing tools in our forums (if available). Should you wish to edit or remove any content you have publicly posted, you may contact us with your specific removal request. Please note that we are not required to remove your posted content or information if it has been de-identified or if we are required by law to retain it.
Your Nevada Privacy Rights:
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us by email at one of the addresses listed in Section 11 below.
7.Your California Privacy Rights:
This section describes the various rights California residents have over their personal information under the California Consumer Privacy Act of 2018 (“CCPA”) and how you can invoke these rights with us.
Notice of collection
Consistent with the “The Types of Information We Collect from You and How We Collect It” section above, in the past 12 months, we have collected the following categories of personal information enumerated in the CCPA (“CA Personal Information”):
– Identifiers, including name, postal address, email address, and online identifiers (such as IP address).
– Customer records, including phone number, billing address, and credit or debit card information.
– Characteristics of protected classifications under California or federal law, including gender.
– Commercial or transactions information, including records of products or services purchased, obtained, or considered.
– Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
– Geolocation data.
– Employment and education information.
– Inferences drawn from the above information about your predicted characteristics and preferences.
Sharing CA Personal Information for Business Purposes.
We collect and use these categories of CA Personal Information for the business purposes described in “How We Use the Information We Collect from You” above.
Sharing CA Personal Information for Commercial Purposes.
We do not generally sell information as the term “sell” is traditionally understood. To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Notice, such as those disclosed in the “Ads and Analytics” section above, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review “How We Share Your Information” above for further details about the categories of parties with whom we share information.
Your California consumer rights
You have the right to know certain details about our data practices in the past 12 months. In particular, you have the right to request copies of the following from us:
– The categories of CA Personal Information we collected about you;
– The categories of sources from which the CA Personal Information was collected;
– The categories of CA Personal Information we disclosed for a business purpose or sold;
– The business or commercial purpose of our use of your CA Personal Information;
– The categories of third parties with whom we share your CA Personal Information; and
– The specific pieces of CA Personal Information we have collected about you.
You also have the right to request that we delete your CA Personal Information.
To exercise any of these rights, please submit a request by email to one of the addresses listed in Section 11 below. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests.
Your right to opt-out of the “sale” of CA Personal Information
To the extent we sell your CA Personal Information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your CA Personal Information by us to third parties at any time. Please submit a request by email to one of the addresses listed in Section 11 below or by phone at 800-715-2450.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Your right to non-discrimination
You have the right not to be discriminated against in service or price if you exercise your privacy rights.
Shine the light
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To submit a request, please write us at the email or postal address set out in “Questions or Complaints” below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
8.International Transfers of Information
Please be aware that information we collect may be transferred, processed, stored, and used internationally, including in the United States, Canada, the United Kingdom, Sweden, and other countries in the European Union. The data protection laws in these countries may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement. By using the Services, or providing us with any information, you consent to the transfer to, and processing, usage, sharing, and storage of your information, including personal data, in other countries as set forth in this Privacy Notice.
For personal data transferred from the United Kingdom, the European Union, and Switzerland, we will provide appropriate safeguards, such as through use of standard contractual clauses.
You have the right to ask us not to process your personal data (or not to provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you.
We do not knowingly collect or store any personal information as defined by the Children’s Online Privacy Protection Act (“COPPA”) from children under the age of 13 without verifiable parental consent, as required by COPPA. There may be instances, such as a sweepstakes, contest, or promotion, in which we collect personal information from a child in order to contact a parent and complete prize fulfillment in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
If you are a parent or guardian of a child under the age of 13 (or different age as may apply in your jurisdiction) and believe he or she has disclosed personal information to us without your consent, please contact us at the addresses stated in section 11 below. We will delete the child’s personal information from our records as soon as possible.
10.Keeping Your Information Secure
We understand how important data security is to you, and we have implemented various policies, processes, and technical measures to help protect and secure your information. That said, no data transmission is guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us. Please take care when transmitting information online, including through the Services, and make sure to keep your passwords and account information secure at all times. In the event we become aware of a data breach involving unencrypted notice-triggering information in our possession, we will notify you as may be required by applicable law.
If you have any questions, wish to file a complaint, or wish to make any request authorized by this Policy, please contact us at the following mailing address or email:
For CDE Entertainment Ltd.:
CDE Entertainment Ltd.
100 New Bridge Street
United Kingdom, EC4V 6JA
PrivacyNotice [at] cdeentertainment.com
This Privacy Notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at one of the email addresses stated above.
12.Changes to this Privacy Notice
We reserve the right to change this Privacy Notice. Any changes to this Privacy Notice will be effective as soon as we post them. However, if you have registered an account with us we may ask you to opt-in upon sign-in if we make material changes, to the extent required by applicable law.