Breakshot Games Limited

Privacy and Data Policy

PRIVACY AND DATA POLICY

Last updated: October 2020

Introduction

Thank you for playing our games and choosing to be a part of our community!

These terms apply to the use of games and other products developed by Breakshot Games Limited (‘BSG’ / ‘we’ / ‘us’ / ‘our’). Our registered office is at C/O Hillier Hopkins LLp First Floor, Radius House, 51 Clarendon Road, Watford, United Kingdom, WD17 1HP. We are a company registered in England and Wales under company number 12536507. BSG is the controller and responsible for your personal data.

This privacy and data policy (“Privacy Policy”) aims to give you information on how BSG collect and process your personal data through your use of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games including our website (the “Website”) and related services. Together the Game(s), the Website and related services are referred to as “Service”.

If you have any questions or comments about this Privacy Policy, please contact us at support@breakshotgames.com

This Privacy and Data Policy describes:

The ways we collect personal data about you and why we do so
How we use your personal data, and
The choices you have about your personal data and how the law protects you.

We may periodically update this Privacy Policy by posting a new version on breakshotgames.com. Your continued use of the Service after the effective date of the update will be subject to the new Privacy Policy.

Contacting Us

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, please contact us in the following ways (we encourage you to primarily contact us via email so we can reply to you more quickly):

Post: ATTN: Legal, Breakshot Games Limited, C/O Hillier Hopkins Llp First Floor, Radius House, 51 Clarendon Road, Watford, United Kingdom, WD17 1HP
Email: support@breakshotgames.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority, for data protection issues (www.ico.org.uk) (or your domestic equivalent). We would, however, appreciate the chance to deal with your concerns before you approach the ICO (or domestic equivalent) so please contact us in the first instance.

Third Party Links

The Service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect use, store and transfer different kinds of personal data about you, listed below.

Data you provide us.

Contact information (such as email address, postal address and telephone numbers) – we call this Contact Data
Name, player name, date of birth and password (if applicable) – we call this Identity Data
Profile information (such as profile photo) - we call this Profile Data
Your messages to the Service (such as chat logs and player support tickets)
Financial Data (such as bank account and payment card details)
Transaction Data (such as details about payments to and from us and details of products and services you have purchased from us)
Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically.

Data about your account and game progress – we call this Usage Data
Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
Data about your device, such as device name and operating system, browser type and language
Data we collect with cookies and similar technologies (see more below)
General location data – we call this and the above three bullet points Technical Data
Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service – this is Usage Data
In most cases, we also create a BSG-specific ID for you when you use the Service and this forms part of your Profile Data. Data we collect from Third Party Analytics, Advertising and Other Tools or Services which is generally Marketing and Communications Data.
Data we receive if you link a third party tool with the Service (such as Facebook, WeChat or Google)
Demographic data (such as to determine the coarse location of your IP address)
Data to fight fraud (such as refund abuse in games or click fraud in advertising)
Data from platforms that the games run on (such as to verify payment)
Data for advertising and analytics purposes so we can provide you a better Service

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences

Why Do We Collect Your Data

To make the Service work.

To perform the contract to provide the Service, we process data necessary to:

Create accounts and allow you to play our games and use our Service
Operate the Service
Verify and confirm payments
Provide and deliver products and services you request
Send you Service-related communications
To make the Service more suitable for our players. To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to:
Update and develop player profiles
Develop and improve the Service and player experience
Manage our relationship with you
Provide social features as part of the Service
Customize your Service experience
Respond to your comments and questions and provide player support
Provide you BSG offers in the Service as well as in other websites and services, and by email
Send you related information, such as updates, security alerts, and support messages
Enable you to communicate with other players

To show personalized advertisements. To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to:

Track the content you access in connection with the Service and your online behaviour
Deliver, target and improve our advertising and the Service (for information on how to opt-out from personalized advertisements, see section ‘Your rights and options’ below).

To keep the Service safe and fair. Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the Breakshot Games Terms of Service. In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:

Analyze and monitor use of the Service and its social features
Moderate chats either automatically or manually
Take action against fraudulent or misbehaving players
To analyze, profile, and segment.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Law basis for processing
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your service including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Create and maintain accounts which allow you to play our games and use our Service	(a)Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) To respond to your player support requests	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business, the game and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant gaming and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a)Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b)Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional Offers from Us

We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us or the relevant third party at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Who Can See Your Data

Apart from BSG, your data can be accessed by others in the following situations:

Other Players and Users.
Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
Partners working for BSG. BSG has partners to perform services for us. These partners process your data only at and according to BSG´s instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal insurance and accountancy services.
HM Revenue & Customers, regulators and other public authorities. In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
Advertising, Social Media and Analytics Service Providers. BSG works with a number of other analytics and ad serving providers within our mobile apps, websites and elsewhere online. These partners can use cookies, web beacons, and other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. We encourage you to check their privacy policies to learn more about their data processing practices. If you wish to limit behaviourally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out will take effect. For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS). The following is a list of these service providers and their privacy policies:

Google: https://policies.google.com/privacy

Unity, including Unity Analytics: https://unity3d.com/legal/privacy-policy

OneSignal: https://onesignal.com/privacy_policy

International Data Transfers

Our 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 if applicable, or Brazil’s GDPL.

Your Rights and Options

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before or during your withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You must allow a reasonable time for your withdrawal to take place. The amount of time may depend on technical matters and may not depend fully on BSG. BSG will decide, and if possible, inform you of the time needed for the withdrawal.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us via support@breakshotgames.com. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

Cookies And Similar Technologies

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

How Do We Protect Your Data

Security Safeguards.

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. Please remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Service is at your own risk.

Data retention.

We retain your data for as long as your account is active or as reasonably necessary to fulfil the purpose for which it was collected, including as needed to provide you the Service and for satisfying any legal, regulatory, tax, accounting or reporting requirements. We will for example periodically de-identify unused game accounts and we regularly review and de-identify or delete unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

AGE LIMITS

The Service is not intended for and 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 our Service. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data to us. 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 us.