Most of the information that we collect about you comes directly from you when you use our Services. Broadly, the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted, and purchases made) and may include information that you submit or when you allow us access when you connect to your social network accounts through our Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.
In more detail, depending on which of our Services you interact with we may collect and process the following types of information:
- details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our websites, what device you use to access our games and services or details regarding profile visits, as further set out in “Playing socially”);
- information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us or if you invite your friends to use our games and Services;
- the content of messages sent using our chat and messaging systems;
- if you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence;
- your interactions with us on our social media channels;
- information we collect via cookies and other similar technologies, as explained further below;
- If you choose not to connect your social media accounts, the information that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:
- the type of device(s) you are using to play our games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, a specific player ID, and the country or region that you are playing in; and
- how you play our games and interact with our websites or other Services (such as which of our games you are playing, your progress through the games, session time and duration, number of attempts at each level and purchases made).
In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by us. We do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.
When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you.
We may from time to time ask you for your consent to collect other information from you or your device. For instance, we may invite you to allow us to access your contacts to enable us to invite them to play our games with you. If we do this or something similar, we will tell you what information we would like to collect, why we need it and what we’ll use it for.
We, our suppliers and group companies, may use this information (amongst other things):
- to enable us to provide our games and ervices to you, to ensure that any purchases you make are verified on our servers and activated in the games, and to provide you with player support if you need it;
- to enable us to optimise our games for you and for the device that you are using, as well as to deliver customised in game events, offers and promotions;
- to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our terms of service or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service.
We may also share your information with third party publishers who develop and provide games and other Services to you on our behalf.
We also analyse and use the information that we collect on an anonymised or aggregated basis for product development, to analyse the performance of our games, to troubleshoot and to improve and optimise the games to ensure the best player experience for our players as a whole.
Providing and optimising our Services
We use your information to enable us to provide our websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.
We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.
Analytics and Research
Social and Community
We may operate a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
Promotions and Competitions
Crime and fraud prevention
We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.
We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.
Unless you opt out as explained below, we and our third-party partners use information collected about you to send you marketing communications about other Curioso Games games and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.
We may use the information that we hold about you to promote our Services in a number of ways. This might include:
- advertising within third party websites, apps and Internet-connect devices;
- showing you promotions for other Curioso Games games in the games you play; or
- sending you marketing materials by email.
We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:
- ad identifiers and other non-personal information collected from your device (for more information, see below);
- the games you play and information about how you interact with our games and Services;
- your age, country or region, and gender; and
- other information that we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
When we market our games in media published by other companies, we use various third-party marketing partners to assist us on our behalf, and we may share information which we have collected about you with such third parties for these purposes.
Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for Curioso Games’ games or Services, they will serve you with an ad for our Services while you are using other websites and services.
You can exercise choices over the direct marketing we send you in the following ways:
- you can withhold your consent for us to send you direct marketing emails by opting out when we collect your email address or by electing not to share your email address with us when you first create an account using your Facebook details;
- you can remove yourself from receiving email marketing from us at any time by simply clicking the unsubscribe link in any direct marketing email we send to you or sending an email to email@example.com; and
- to disable interest-based advertising (see below on how to adjust your preferences for interest-based advertising).
You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you may see advertising for our Services, but that advertising will not be targeted using your personal information.
To provide our games, Websites and interest-based advertising, we may use ad identifiers, cookies and similar technologies, which may be used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third-party advertising partners to:
- recognise you and your device;
- provide interest-based advertising to you;
- allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
- allow our payment processors to process your payment instructions; and
- enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications. Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.
You can choose to prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings. If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services.
Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests. We will also still use your device’s ad identifier to serve you with ads; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us).
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the “Contact Us” section below.
Your rights include:
- Right of access. You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at firstname.lastname@example.org and we will correct it as soon as we can.
- Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a WiFi network.
- Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
- Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see “Legal Bases” below).
- Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
You must be over a certain age to play our games and use our Services, depending on where you live. For the full list of age restrictions by country, please see below. We do not knowingly collect or solicit personal information from or direct or target interest-based advertising to anyone under the ages set out below, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.
- as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you);
- where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors);
- where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
- as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of Curioso Games, our users, or others; and
We may also share your information with our service providers if necessary to enable them to provide services to us.
We take appropriate security and technical measures to protect your information from unauthorised access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following:
- Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our games, customer services, chat functionality and third party social network connectivity;
- Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;
- Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimisation of our games and other Services; and
Location of storage
We store your information on servers that we control which are primarily based in the European Economic Area (EEA). We may also use servers and engage providers that are located outside the EEA in order to process and store your information and to provide services to us.
We may transfer your information to affiliated entities or third parties to jurisdictions outside the UK or the EEA. Please note that these countries outside of the UK or EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of UK or EU model clauses) to allow the transfer of your information across borders outside of the UK or EEA.
1) via email to email@example.com; or
2) in writing to Curioso Games Ltd, Westminster House, 10 Westminster Road, Macclesfield, Cheshire, SK10 5BX.