Privacy Policy

Effective Date: 29th December, 2019

This Privacy Policy applies to games, websites and related services from Kristoffer Gustafsson ("I", "me" or "my"), which I 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 my Terms of Service.

Data Controller

Kristoffer Gustafsson is the Data Controller for processing the personal data mentioned below.
If you have any questions or concerns about my use of your personal information, then please contact me 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 me

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 I have control over this. Please refer to the Privacy Policy of the respective service provider to examine them in detail.

1) PlayFab

To ensure the proper performance of the game-experience, provide competitive leaderboards and provide technical support, I use PlayFab, a backend platform provided by PlayFab Inc.
Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA.

PlayFab processes the following (personal) data:

If you voluntarily link or sign in with a third-party account (such as Google, Apple, or others), the following additional (personal) data is processed:

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. My legitimate interest is derived from the purposes listed above for data collection.

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

You can find further information and regarding your rights in this respect in the privacy statements of PlayFab: https://playfab.com/privacy.

PlayFab is certificated under the EU-US Privacy Shield Framework.

2) Unity

To build the game, advertise and monetize, I use Unity (including Unity Ads and 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:

Unity Ads may collect some behavioural information for you and share it with the advertisers.
If you wish to exercise your rights regarding the data collection and targeted advertisement by Unity, the first Unity Ad you see in the game explains how you can opt-out of data collection by Unity. You can opt-out then or at any time by clicking or tapping the “i” button (or Data Privacy icon)

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.

3) GameAnalytics

To detect, prevent and address technical issues and make the Service more suitable for players, I use GameAnalytics, a statistical analytics service provided by Game Analytics, Vesterbrogade 34, 1620 Copenhagen V, Denmark

GameAnalytics may collect the following (personal) data, if you have explicitly given your consent:

You can find further information and regarding your rights in this respect in the privacy statements of GameAnalytics: https://gameanalytics.com/privacy

The collected data is hosted by Amazon Web Services and Google both of which comply with the EU-U.S. Privacy Shield Framework.

The legal basis for the data processing is Art. 6 (1) lit. a GDPR, your consent. No data is collected without your consent. If the consent is withdrawn, data collection is stopped.

4) Firebase

I use Firebase to serve push notifications to mobile devices, which is a service provided by Google.

Firebase may collect the following (personal) data:

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. My legitimate interest is derived from the purposes listed above for data collection.

You can disable push notifications in the game settings, upon which no further data will be processed.

5) 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/

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 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

  

5. Your rights and options

You have the right:

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 I serve an ad to you it’s like I’ve never seen you before, so I will show you my best-performing ad at that moment – which will likely be the same ad that I showed you last time, which can lead to a very repetitive and less interesting experience. I 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 me 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, I 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 I 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, I take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that my 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, I strongly advise you to review the Privacy Policy of these websites. I 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

I 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 I learn that I have collected personal data about a child under age 13, I will delete that data as quickly as possible. If you believe that I might have any data from or about a child under the age of 13, please contact me.

8. Updates to This Privacy Notice

I may update my Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. I 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 me

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