PRIVACY POLICY
1. Introduction
1.1 We are committed to safeguarding the privacy of our service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We collect data during the usage of our apps. Insofar as this data is not strictly necessary for the provision of our services, we will ask you to consent to our use of data collection when you first use our apps.
1.4 Our apps incorporate privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive targeted advertisements and provide user data which may be used to improve future delivery of our services. You can access the privacy controls from inside the app.
1.5 In this policy, "we", "us" and "our" refer to Five Aces Publishing Ltd. and New Star Games Ltd. [For more information about us, see Section 10.]
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our services ("usage data"). The usage data may include a unique advertising identifier for your device, geographical location, device operating system, referral source, duration of usage, screen views and interface navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is analytics tracking platforms provided by Upsight, Inc. Flurry, Inc., Google LLC, Apple Inc., Skillz Inc, The Fyber Group and Ogury Ltd. This usage data may be processed for the purposes of analysing the use of our services. While we may seek additional consent, the legal basis for this processing is our legitimate interests, namely monitoring and improving our services.
3.3 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through third parties such as Google LLC, Apple Inc. or Skillz Inc. ("transaction data"). The transaction data may include your location details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our business.
3.4 We may process information that you provide to us for the purpose of subscribing to in-app notifications ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications. The legal basis for this processing is consent.
3.5 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.
3.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.9 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose usage data and notification data to our suppliers or insofar as reasonably necessary for providing in-app advertising and for sending in-app notifications, which may be tailored for individual users.
4.4 Financial transactions relating to services are handled by our payment services providers, Google LLC, Apple Inc. and Skillz Inc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at
• https://www.apple.com/uk/legal/privacy/en-ww/
• https://policies.google.com/privacy
• http://corp.skillz.com/privacy-policy/
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 Some of our advertising and analytics suppliers are situated in the United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to the United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Usage data will be retained for a minimum period of six years following 25 May 2018, and for a maximum period of fifteen years following 25 May 2018.
(b) Notification data will be retained for a minimum period of six years following 25 May 2018, and for a maximum period of fifteen years following 25 May 2018.
(c) Correspondence data will be retained for a minimum period of six years following 25 May 2018, and for a maximum period of fifteen years following 25 May 2018.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of transaction data will be determined based on the business and legal requirements of our payment services providers, Google LLC, Apple Inc. and Skillz Inc.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8.
9. Our advertising service providers
9.1 We use AdRally via Upsight and via Fusepowered to publish interest-based advertisements in our apps. These are tailored by AdRally to reflect your interests. To determine your interests, AdRally may track your interactions with multiple ads using your device’s unique identifier. You can view Upsight’s Privacy Policy here: https://www.upsight.com/pricing/privacy-policy/. You can view Fusepowered’s Privacy Policy here: https://www.fusepowered.com/privacy/.
9.2 We use AdMob by Google to publish interest-based advertisements in our apps. These are tailored by AdMob to reflect your interests. To determine your interests, AdMob may track your interactions with multiple ads using your device’s unique identifier. You can view AdMob’s Privacy Policy here: https://policies.google.com/privacy.
9.3 We use Ogury (also known as AdInCube) to publish interest-based advertisements in our apps. These are tailored by Ogury to reflect your interests. To determine your interests, Ogury may track your interactions with multiple ads using your device’s unique identifier. You can view Ogury’s Privacy Policy here: https://www.ogury.com/privacy-policy/. You can view AdInCube’s Privacy Policy here: https://storage.googleapis.com/adincube-resources/doc/Privacy_policy.pdf.
9.4 We use Fyber to publish interest-based advertisements in our apps. These are tailored by Fyber to reflect your interests. To determine your interests, Fyber may track your interactions with multiple ads using your device’s unique identifier. You can view Fyber’s Privacy Policy here: https://www.fyber.com/privacy-policy/.
10. Our details
10.1 This website is owned and operated by New Star Games Ltd. Apps are owned and operated by Five Aces Publishing Ltd. and New Star Games Ltd.
10.2 You can contact us by email, using [email protected].
