Privacy Policy

Effective Date: 16th December, 2022

This Privacy Policy applies to games, websites and related services from Iterative Studios AB ("Us", "we" or "our"), which we here collectively call the Service.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Data Controller

Iterative Studios AB is the Data Controller for processing the personal data mentioned below.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

1. Collection and storage of personal data and the purpose of their use

When you use the Service, the processing of your personal data will apply to the scope stated below:

Data processed by us

To ensure the proper performance of the game-experience, provide technical support, and to enforce the Terms of Service, we collect the following (personal) data:

Data you intentionally provide if you contact us electronically (i.e via email).
Unique device identifier generated from the device (depending on the platform), including but not limited to:
- iOS
  - ID for Vendors (IDFV), or if that fails for any reason, ID for Advertisers (IDFA).
- Android
  - Android ID (SSAID)
- Steam
  - Steam ID
Display name (changable)
Character name
PlayerId (automatically generated)
Log-in data (date and time, approximate geolocation based on IP address, device model, device OS)
IP address
Registration date
Game-specific data, characters, game progress, combat history, achievements
Presence in game
Business events such as transactions made in the game
Resource events such as the acquisition or spend of game virtual currencies by the Player

If you voluntarily register a game account, the following additional (personal) data is processed:

Data processing's legal basis for the is Art. 6 (1) lit. b, f GDPR. Our legitimate interest is derived from the purposes listed above for data collection.

The collected data is transmitted to and stored on servers in the EU.

Data processed by third-party services

All the services listed below collect user information on different levels. The information collected might be both technical and/or behavioural.
This Privacy Policy does not cover the way these companies store and use the acquired information, nor do we have control over this. Please refer to the Privacy Policy of the respective service provider to examine them in detail.

1) Unity

To build the game and monetize, we use Unity (including Unity Analytics), a game engine provided by Unity Technologies, Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark.

The following (including, but not limited to) personal data may be collected, stored, used, processed and transferred by Unity:

Device type
Country
Device language
In-game behavior and purchases
IP address
Apple’s Advertising Identifier (IDFA)
Google Play advertising ID

For more information regarding personal data collection and how to exercise your rights for services provided by Unity Technologies, please refer to the Unity Privacy Policy to examine them in detail: https://unity3d.com/legal/privacy-policy.

2) Firebase

We use Firebase to serve push notifications to mobile devices and analyze user behavior and crash reports, which is a service provided by Google.
We have implemented this Analytics tool to help us understand how the game is being used in order to help us improve the game and plan for future game releases.

Firebase may collect the following (personal) data:

IP addresses
instance ID:s (a unique, random ID created by your device for each app installed)
Player progress
Any in-app purchases
Device type
Operating system
Language settings
Play session lengths
Broad geographic information like your country and city.
Design events used to track Player behavior in the game, which can refer to any aspect of the game’s design, including, but not limited to, level or character design, bonuses, social interactions, etc.

Firebase Cloud Messaging uses instance IDs to determine which devices to deliver messages to.

You can find further information and regarding your rights in this respect in the privacy statements of Google Firebase: https://firebase.google.com/support/privacy/.

The collected data is stored in the EU, and relies on Standard Contractual Clauses for relevant data transfers.

Data processing's legal basis for the is Art. 6 (1) lit. b, f GDPR. Our legitimate interest is derived from the purposes listed above for data collection.

3) MAS

To display advertisements in the game, we use MAS, an advertisement platform provided by Yodo1 (Room A, 22/F Southtex Building, NO.51 Tsun Yip Street, Kwun Tong, Kowloon, Hong Kong)

The following personal data may be collected, stored, used, processed and transferred by Yodo1:

Identity Data
Contact Data
Technical Data
Transaction Data
Behavioural Data
User Content Data

For more information regarding personal data collection and how to exercise your rights for services provided by Yodo1, please refer to the Yodo1 Privacy Policy to examine them in detail: https://gamepolicy.yodo1.com/privacy_policy_en.html.

Data processing's legal basis for the data above is Art. 6 (1) lit. b, f GDPR. Our legitimate interest is derived from the purposes listed above for data collection.

The collected data is transmitted to and stored on servers from third party ad networks worldwide.

4) Consent Manager

We have integrated the consent management tool "consentmanager" (www.consentmanager.net) from consentmanager AB (Håltgelvågen 1b, 72348 Västerås, Sweden, info@consentmanager.net) on our website to obtain consent for data processing and use of cookies or comparable functions.

With the help of "consentmanager" you have the possibility to give your consent for certain functionalities of our website, e.g. for the purpose of integrating external elements, integrating streaming content, statistical analysis, measurement and personalized advertising.
With the help of “consentmanager” you can grant or reject your consent for all functions or give your consent for individual purposes or individual functions.
The settings you have made can also be changed afterwards.
The purpose of integrating “consentmanager” is to let the users of our website decide about the above-mentioned things and, as part of the further use of our website, to offer the option of changing settings that have already been made.
By using “consentmanager”, personal data and information from the end devices used, such as the IP address, are processed.
The legal basis for processing is Art. 6 Para. 1 S. 1 lit. c) in conjunction with Art. 6 para. 3 sentence 1 lit. a) in conjunction with Art. 7 para. 1 GDPR and, in the alternative, lit. f).
By processing the data, consentmanager helps us (according to GDPR this is the responsible party) to fulfill our legal obligations (e.g. obligation to provide evidence).
Our legitimate interests in processing lie in the storage of user settings and preferences with regard to the use of cookies and other functionalities.
"Consentmanager" stores your data as long as your user settings are active.
After two years after making the user settings, the consent will be asked again.
The user settings made are then saved again for this period.
You can object to the processing. You have the right to object to reasons arising from your particular situation.
To object, please send an email to info@consentmanager.net.

For more information regarding personal data collection and how to exercise your rights for services provided by consentmanager AB, please refer to the consentmanager Privacy Policy to examine them in detail: https://www.consentmanager.net/datenschutz/

5) Facebook

To track user activity connected to advertisements in the game, we use Facebook, an advertisement platform provided by Meta (1 Hacker Way, Menlo Park, California , U.S.)

The following personal data may be collected, stored, used, processed and transferred by Meta:

Identity Data
Contact Data
Technical Data
Transaction Data
Behavioural Data
User Content Data

For more information regarding personal data collection and how to exercise your rights for services provided by Meta, please refer to the Meta Privacy Policy to examine them in detail: https://opensource.fb.com/legal/privacy/

Data processing's legal basis for the data above is Art. 6 (1) lit. b, f GDPR. Our legitimate interest is derived from the purposes listed above for data collection.

The collected data is transmitted to and stored on servers Meta servers worldwide.

2. Visibility of data

Apart from the Data Controller and the Third party services mentioned in clause 1, your data can be viewed by others in the following situations:

Other players
Social features are a component of the Service. Other players and users may, see your account/character display name and scores or achievements.

3. Duration of personal data processing

The personal data which is processed according to clause 1, is processed for as long as your account is active or as long as needed to provide you the Service. If you delete your account, processed personal data will be erased.

4. Forwarding data

Unless stated otherwise under clause 1, your personal data will not be transferred to any third party for any purpose other than those listed below.

We shall forward your personal data to third parties only

if you have given your explicit consent, in accordance with Art. 6 (1) lit. a GDPR
if under Art. 6 (1) lit. f GDPR the transfer is necessary to establish, exercise or defend legal claims, and there is no reason to assume that you have an overriding interest, which must be protected, in the non-forwarding of your data
in the event that there is a legal obligation to forward the data under Art. 6 (1) lit. c GDPR and
if this is legally permissible and necessary according to Art. 6 (1) lit. b GDPR for the processing of contractual relationships with you.

5. Your rights and options

You have the right:

pursuant to Art. 15 GDPR, to demand information about your personal data we have processed. In particular, you can obtain information about the purposes of the processing, The categories of personal data concerned, the recipients or category of recipients to whom your data have been or will be disclosed, the envisaged period for which the data will be stored, the existence of the right to request to rectify , erase, or restrict of the processing, or to object to it, the right to lodge a complaint in front of a supervisory authority, the source of your data, if these have not been collected by us, and on the existence of automated decision-making, including profiling, and any other meaningful information about their details or the logic involved;
pursuant to Art. 16 GDPR, to demand the immediate rectification or completion of inaccurate personal data stored by us;
pursuant to Art. 17 GDPR, to demand the erasure of personal data stored by us, unless their processing is necessary for exercising the right of freedom of expression and information, to comply with a legal obligation, for reasons of public interest, or for the establishment, exercise or defence of legal claims;
pursuant to Art. 18 GDPR, to demand the restriction of the processing of your personal data in cases where you contest the accuracy of the data, where the processing is unlawful yet you oppose the erasure of the personal data, where we no longer need the data but you still require them to establish, exercise or defend legal claims, or where you have objected to the processing of the data pursuant to Art. 21 GDPR;
pursuant to Art. 20 GDPR, to obtain your personal data that you have provided to us in a structured, commonly used and machine-readable format and to demand the transfer of these data to another controller;
pursuant to Art. 7 (3) GDPR, to withdraw your consent at any time, which will mean that in future we may no longer carry out the data processing that was contingent upon this consent and
pursuant to Art. 77 GDPR, to lodge a complaint with a supervisory authority. In general, you can contact the Data Protection Authority of your usual residence or place of employment.

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).

It’s important to note that this does not opt you out of seeing ads – you will still see ads in your apps. What does happen is that every time we serve an ad to you it’s like I’ve never seen you before, so we will show you our best-performing ad at that moment – which will likely be the same ad that we showed you last time, which can lead to a very repetitive and less interesting experience. We might also show you ads for apps you’ve already downloaded.

Opt-out of marketing emails

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.

6. How your data is protected

Security Safeguards

In order to help ensure a secure and safe player experience, we am continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

International Data Transfers

The Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by me. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

7. Age limits

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use the Services. If you are under 13, please do not send any data about yourself to me, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact me.

8. Updates to This Privacy Notice

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page.
Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

9. Contact us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at privacy@iterativestudios.com.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.