This is the Privacy & Cookies Policy (the “PCP”) of Another Place Productions Limited (”us”, “we” or “our”). This PCP describes the ways in which we collect and use information about you when you visit our websites (including www.anotherplaceproductions.com and www.anotherplaceproductions.co.uk or otherwise use our services (together the “Services”), when you download one of our games (each a “Game” and together the “Games”) as an app and when you start playing the Games. For ease of reference, we refer to all such information as ‘personal data’ although not all information that we collect and use will personally identify you.

This PCP is intended to assist you in making informed decisions when using our Services or our Games. Please read this PCP carefully to understand how we use and protect any personal data that you provide to us.

1.    CHANGES TO THE PCP

By playing the Games or using the Services you agree to be bound by this PCP. We may change this PCP at any time. We shall deem your continued use of the Games or access of the Website as indicating your consent to such changes. We shall notify you of any material changes.

2.    CONTACTING US

a. For the purpose of the Data Protection Act 1998 (the “Act”), the data controller in respect of any personal data that you submit to us via our Games or through Website is Another Place Productions Limited, a company incorporated under English law (company number: 08608341) and whose registered office is at 1 Woodland View, Farncombe, Godalming, GU7 3TG, United Kingdom.
b. If you have any queries in relation to this PCP, please contact us at the following email address: privacy@anotherplaceproductions.com.

3.    COLLECTION OF PERSONAL DATA

a. What personal data do we collect? If you download one of our Games or our Services we may collect the following:

i. details of your name, the player name you create to identify you when you play the Games, your Gamecenter Tag, information about the device you are using (e.g. a smartphone or tablet device) and the country from which you have downloaded our Games or from where you are using our Services;
ii. analytical data on how you are progressing through the Games and Services, what you are unlocking within the Game and what character you are using;
iii. personal data in relation to your in-Game purchases (please see paragraph c) below);
iv. your IP address, MAC address or the internet browser which you are using when you play the Games;
v. personal data collected by our use of cookies and similar technologies – detailed in the tables below; and
vi. if you sign into our Games (or Services) via a social networking site like Facebook we will collect your social network ID, email address, information relating to your friends, profile picture, gender, language preference and geo-location. You may review what information we can access by changing your privacy features on such social networks.

b. How we use your collected information: We primarily use your personal data to enable us to provide the best service possible via the Game and for business management purposes. We may use your personal data to:

i. facilitate the improvement of the Games and Services and your experience of the Games and Services;
ii. provide technical support in relation to player enquires, resolving disputes and troubleshooting;
iii. prevent fraud or illegal activities; and
iv. share with third parties for the purposes as described in paragraph 4) below.

c. Your financial information: Your in-app purchases within the Games are handled through the platform on which you purchased the Game or through other payment processors (e.g. the Apple App Store, Google Play). Please note we do not retain any card or payment details.
d. People who make complaints about us: Any complaints we receive will be filed together with any relevant documents and we may retain details of the complainant, and other individuals identified in the complaint. We will only use this personal data to process the complaint and to check on our services and staff. We shall retain personal data in relation to a complaint for 6 years from the date it is resolved and keep such personal data in a secure environment. Access to it will be restricted on a ‘need to know’ basis.

4.    DISCLOSURE OF YOUR INFORMATION

a. Other than as expressly set out in this PCP or as otherwise required or permitted by law, we will not share, sell or distribute any of the personal data you provide to us without your consent.
b. We may disclose your personal data:

i. to any of our online partners who may serve adverts within the Games (please see further details on these adverts in paragraph 5) below). We may share your anonymised IP address and MAC ID with our partners to try and ensure that the ads you receive are relevant to you;
ii. as part of the Games your name will be used if you send a challenge to a friend and your User ID or name or Gamecenter Tag may be posted on a leaderboard of top scorers within the Games to be shared with other players and your social networks. You may also share elements of your performance or participation in the Games (e.g. your character) with other players and your social networks;
iii. in relation to the sale of some or all of our business, or its assets, to any third party, or as part of any business restructuring or re-organisation, but we will take steps to ensure that your data protection and privacy rights continue to be protected and can only, in any event, make such disclosures in accordance with applicable law;
iv. in anonymised form with data aggregators and service providers as part of an analysis of player metrics or sales performance of the Game and any in-game purchases;
v. to a person to whom disclosure is necessary to enable us to enforce our rights under this PCP; and
vi. to law enforcement agencies in compliance with law enforcement.

5.    THIRD PARTY WEBSITES AND ADVERTS

a. The Games may contain advertisements (including suggestions to play third party games) which link to websites/games that are operated by third parties. We do not control and accept no liability or responsibility for those websites and games and this PCP does not apply to those websites and games. Please consult the terms and conditions, PCP and any other terms of such third party websites to find out how they collect and use your personal information and to establish what they may use your personal information for.
b. We do not receive personal data that you submit to any third party website that you access from an advertisement contained in the Games. However we do receive statements on how many impressions of an ad our Game showed, how many ‘clickthroughs’, how many installs have occurred as a result (some of which we may get paid on) and in relation to video adverts the view completion data point.

6.    HOW DO WE PROTECT YOUR INFORMATION?

a. The personal data that you provide to us will be collected and processed by us or by a data processor appointed by us to undertake processing on our behalf. General information (but no personal data) may be stored on servers controlled by the Canadian company, Fuse Powered Inc in relation to how you play the Games. For example, levels you attain, missions completed, character up-grades and total in-game currency earned per play session.
b. We have put in place appropriate security measures to protect your personal data from access by unauthorised third parties and unlawful processing, accidental loss, destruction and damage. However, you hereby acknowledge that data transmission over the Internet is inherently unsecure and that we cannot guarantee the security of data you send over the Internet.
c. Your personal data will only be held by us for a reasonable period or as long as the law requires or permits.

7.    OUR POLICY TOWARDS CHILDREN: Our Games are intended for anyone who is legally entitled to own a device and access them and play them and for anyone who is legally entitled to make in-app purchases by the payment functionality the Games provide. However, we do not knowingly collect personally identifiable personal data in relation to children under the age of 13. If we discover we have collected personal data in relation to any children under 13 we shall take reasonable steps to delete such personal data.

8.    COOKIES

a. What are Cookies? Cookies are small text files that are placed on your device when you play a Game. Our use of cookies, or similar technologies, are detailed below in Section 9. Session cookies enable you to move from page to page within Games and any personal data you enter will be remembered but is deleted when you close your browser or after a short time. Persistent cookies allow us to remember your preferences and settings when you play the Games in the future, in different browser sessions.
b. Disabling Cookies: The use of the cookies described above improves the functionality of the Games and your experience using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Games, some of the features of the Games or the Games may not function properly. By continuing to use the Games, including using social networking media functionality, you consent to the relevant cookies being set on your device.
c. More information: To find out more abouthow cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.

9.    COOKIES WE USE

a. Cookies used in the Games

We do not currently use cookies in our Games or Websites, but we do use the following similar technologies: