Privacy policy

GDPR – Privacy-By-Design and Record of Processing Activities

We are committed to a lawful, fair and transparent processing of personal data, adhering to the EU General Data Protection Regulation (GDPR). This file documents our general privacy-by-design considerations (articles 5, 25 and 26 GDPR) and records our processing activities.(article 30(1) GDPR)

Personal Data Processings: Player data

Creation date / last update: 11 July 2020

Contact email: pocketplaystudios@gmail.com

* Not formally a DPO under the GDPR.

Note that the below uses the “you” and “us” pronouns in paragraphs nrs. 1 o 11 to allow inclusion without modification in our information notices provided to data subjects.

1. We process the following (categories of) personal data
When you play our games, connect to a social networking site through our games, register an account, enter a promo code, or place an order, we process the following personal data when you consent:
· Your IP address, and the country,

· Your device type (for example, iPhone 7, Samsung Galaxy S7) and operating system version.

· Your Game Center ID (for iOS games) or Google Play ID (for Android games).

· When you connect to Facebook or Game Center, or other social platforms, we access your profile, including your username and friends list.

· For analytics, most, when you installed and played the game, your progress throughout the game, and events that are connected to your game-play. We generally cannot identify you with this data, but treat it the same as personal data.

· For advertising, We may use collected IDFAs to (re)target users on advertising platforms.

2. What (purposes) do we use the data for
We use this personal data to perform analytics for our games and allow third-parties to sell, buy and deliver advertizing in those games that display advertizing.
We use social network data to show you personalized content. For example, we might show a high score list with only your friends in it, or show your name or avatar on an in-game object.

3. What is our legal basis for the processing
For both analytics and advertising we base the processing of personal data on the legitimate interest of our company . For analytics, this is our ability to analyze how players progress through our games to make them better, and to know our player-base on an aggregate level. For advertising, this is our ability to be able to off-set development costs and risk with advertizing income.
For the third-parties we use, their legitimate interest is to be able to offer us their services, and for advertising third-parties and advertisers to be able to show you advertising.
4. Where do we obtain the data from (sources)

We obtain the data from our third-party services providers:

Google Analytics

Firebase

Admob

Applovin

Facebook Audience Network

Unity Ads

5. How long and where do we store data

We store the personal data that we collect for up to a year, and only aggregate data after that time, except for email addresses for our newsletter. Aggregation data means that we can no longer look at data for individual players.
When a third-party service provider is a controller, they may keep data as well, either for a shorter or longer period.

6. What safeguards have we taken to protect data


Taking into account the nature, scope, context and purpose of the processing, we have taken the following technical and organizational measures:
· Access to our database and user accounts with third-party service providers is protected with access control.
· Access to the database is limited, not all staff in our organization have full access.
· Data sent from our games is encrypted in transit where technically possible.
We do not actively monitor the security of our databases and need to rely on our processors to notify us of any data breaches.

7. Who we share data with

We share data with the following third-parties. These are either controllers, or processors acting on our behalf.

Google Analytics

Firebase

Admob

Applovin

Facebook Audience Network

Unity Ads

Apple and Google may also collect data when you use their app stores to install our games.

8. How to contact us

You can contact us with any questions:

Web: https://puzzly.in
Mail: pocketplaystudios@gmail.com