ISSUED BY LOCKWOOD PUBLISHING LIMITED
Last Updated: 22 May 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games (including Avakin Life) and other products developed by Lockwood Publishing Limited (‘Lockwood’ / ‘we’ / ‘us’). Our registered office is at 12 Mansfield, Office Suite 0.3, Hamilton Court, Mansfield, Nottinghamshire, NG18 5FB. We are a company registered in England, with company number 06242481.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
Information provided by you when using the Games
We will collect the following information from you when you play our Games:
Contact information provided by you when using the Forums, Bug Reports or Support Centre
We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Forums or Support Centre.
This may include:
Information used for the purposes of serving advertisements
Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:
Information collected for the purposes of providing analytics
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
Information about you collected from third parties
(“Third Party Log In Information”)
When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook cookies within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.
Content created by our users which we host and display on the Forums and in the Support Centre
When users submit their own User Content to the Forums or Support Centre, this content may contain personal and non-personal information. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide our Games to you
To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Games and Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Online Services and (iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.
To respond to your enquiries and requests for support and to enable you to use the Forums
To acquire new users and engage current users
To improve the monetisation of the Games
We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via purchases of content within or associated with the Games.
For advertising purposes
We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.
The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually.
We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games. We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may withdraw it at any time.
We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks:
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
To prevent fraud and illegal activity
We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations. This may include, in respect of processing chat logs, transferring that personal data to Two Hat Security Ltd, based in Canada, who process that information on our behalf to identify such unlawful activity.
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).
4. DATA SHARING
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Lockwood, our customers, or others.
Digital Content Stores: Where the Games are downloaded though Google Play and/or iTunes, we may disclose your personal information to Google and/or Apple respectively for the purposes of facilitating any in-Game payments made through these platforms.
Support Centre: We use a third party platform provider called Helpshift to manage any support requests, queries and issues raised by users via the Support in-game. Further details about the way in which Helpshift may collect and process your information can be found in their terms at https://www.helpshift.com/legal/privacy/ .
5. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly. You can opt-out from analytics by contacting us at firstname.lastname@example.org or in the games, Settings->Manage my Data.
You can withdraw your consent by changing your advertising settings on your device or by deleting the Game at any time.
6. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know by sending an email to email@example.com
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
Obtain a machine readable copy of your personal data, which you can use with another service provider
Make a complaint to a Supervisory Authority
7. Data Retention
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are encrypted, password protected and limited to essential employees only.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
10. INTERNATIONAL DATA TRANSFERS
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
If you would like to find out more about these safeguards, please let us know by writing to firstname.lastname@example.org.
All questions, comments or enquiries should be directed to email@example.com. We will endeavour to respond to any query or questions within three business days.
© 2018 Lockwood Publishing Limited. All trade marks are the property of the relevant owners. All rights reserved.