Updated: May 23rd, 2023
1. AN OVERVIEW ON DATA PROTECTION
Hello there, thank you for being part of our journey!
The following information will provide you with an overview of how we collect your data as well as the purposes we use this data for when you use our games and other services (“Services”).
The term ”Personal Data” (or “Data”) comprises all data that can be used to personally identify you, either directly (such as your first and last name, your email address or your telephone number), or indirectly (such as your PlayTag ID or game data).
We are processing your Data as a controller under EU data protection laws:
Business ID: 3158943-6
Address: Aleksanterinkatu 11
If you have any questions about or suggestions on how to improve our data protection, you can contact us here.
2. COLLECTION AND USE OF YOUR DATA
Other Data is automatically collected when you play our Games and use our Services. In order to make our Games and Services better and more impactful, we may also collect information about your perception of our Games, how you liked them, and what kind of impact, if any, they have had on you.
In order to fully play our Games or use our Services, it is necessary to provide the data listed below. Without this Data, we are not able to provide our Games or Services in their full extent to you.
We may collect and use your Data when you:
a) Take a new PlayTag into use and create an Account
When you take the PlayTag into use, we collect the time, date and location of its registration. When you first play our Games, we may automatically generate a user ID (“Player ID”).
b) Use our Games or Services
When you use our Services, we may automatically collect your:
- Game data such as achieved game levels, rewards, completed events, virtual currency and statistics including the playtime or the use of the various features as well as the data associated with any bugs and malfunctions with either the Game or the PlayTag.
- Data on the locations (“Hubs”) where you have played our Games
- User preferences and settings, such as PlayTag configuration and other customisations.
We collect this Data to provide you with access to our Games, to save your progress, rewards and unlocked content, and to improve your experience and the security of our Services.
c) Contact our Player Support team
If you send support requests to our Player Support team by email, we collect and process the Data from your request and Data from your account, such as your Player ID, game data, and technical data. We collect this Data to appropriately respond to your requests.
The Data sent by you to us via contact requests remains with us until you request us to delete, revoke your consent to the storage or the purpose for the Data storage lapses. Mandatory statutory provisions in particular statutory retention periods remain unaffected.
3. STATISTICS, ANALYTICS AND DISCLOSURE OF DATA
To improve the features and design of our Games and Services, we may analyze all collected data. The analyses of your usage Data are usually conducted anonymously; i.e. the patterns cannot be traced back to you.
We use third-party analytical tools in connection with our Games and Services. Any Data transferred outside the EU and the European Economic Area is done in accordance with the European Commission’s decision on the adequacy of privacy protection. We have assured that all the third parties follow the latest EU regulation on data transfer mechanisms, and that these partners process your Data only according to our specific instructions.
The third-party sub-processors that the Games or Services may use are Cloudflare, Github (Microsoft), Bitbucket (Atlassian Inc.), Google Cloud, Google Firebase, Hubspot, Heroku (Salesforce), Amazon AWS, Aiven Oy, Sentry, Mixpanel, Sendgrid (Twilio), Messagebird, getdbt, Datadog, Auth0, Office 365 (Microsoft), Google Workspace, and Plausible.
4. DELETION OF YOUR DATA
Unless the law specifies a different retention period, we will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs. If Data must be kept for legal reasons, they are blocked and no longer available for further use.
5. BASES OF DATA PROCESSING
We may use your Data in the following circumstances:
- Our legitimate interest (or reasonable expectations of users), to offer you the best possible user experience, such as to ensure the security of the Games and Services, or to respond to your requests and questions.
- If it is required to comply with a legal obligation or document compliance with legal obligations.
- Your consent to offer you products, services or personalized content depending on your user profile.
We define “Child” as players under 13 years of age. To permit the Child’s registration in our Games and Services, parents or legal guardians ("Parents") must provide verified consent. Verifiable parental consent is required for the collection, use, or disclosure of a Child's Personal Data. We won’t collect, use, or disclose any Personal Data from a Child if their parent or guardian does not provide such consent. We may ask a Child to provide a Parent’s email address in order to request this consent, and the Parent’s email address will be deleted if consent is not provided within a reasonable time.
Parents can provide and verify their consent through our website Where Parental consent is required, we recommend that Parents monitor the Child’s game activity and use of the Service.
In a situation where the Child does not have their own registered PlayTag or the Parent is not present or to give consent, we only gather Data that is absolutely necessary for providing the Game or the Service for the Child. In this situation we as the Child to create a unique player nickname, and we ask them to provide us with a phone number, either their own or their Parent’s. The nickname is required to identify a unique player in case they return to the play the Game in any of our Hubs. The phone number is collected to ensure that all lent PlayTags can be recovered back to us once the Game session is finished.
7. YOUR RIGHTS
- Obtain a copy of your Data – “Right of access and data portability”:
- At any time, you can request a copy of your Data. You may also consult the Data, use it yourself or transfer it to another service provider.
- Correct your Data – “Right to rectification”
- You have the right to correct your Data when it is inaccurate or incomplete (for example, change your address).
- Delete your Account – “Right to erasure (right to be forgotten)”
- You can request the closure of your Account and the deletion of the associated Data.
- Limit the use of your Data – “Right to restriction of processing”
- You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.
- Give and withdraw your consent – “Right to object and withdraw your consent”:
- At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers) by email request to firstname.lastname@example.org.
We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service, or charge different prices to players that choose to exercise their rights.
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority. In Finland, the authority in question is Tietosuojavaltuutetun toimisto, PL 800, 00521, Helsinki.
Last updated: May 23rd, 2023