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PRIVACY POLICY
TEAM17 DIGITAL LIMITED PRIVACY POLICY FOR APPLE ARCADE GAMES
21st of June 2023
Team17 Digital Limited and its group companies (collectively the “Company,” “we,” “us” and “our”), respects the privacy rights of our users and is committed to protecting the information collected through our products and services. This policy applies only to Team17 Digital Limited Games on Apple Arcade, referred below as the “Game”.
This privacy policy (the “Privacy Policy“) explains what personal data we may collect about you when you use or access the Online Services and how we collect, store, disclose, transfer, protect, and otherwise process that information for the purposes of operating and providing the Game.
Unless defined herein or the context requires otherwise, terms used in this Privacy Policy have the meanings given to them in the General Data Protection Regulation (GDPR) (EU) 2016/679.
WHO THIS PRIVACY POLICY APPLIES TO
This Privacy Policy applies to all users of our Games on Apple Arcade across all supported Apple devices (iOS, iPad, MacOS, TvOS).
OUR RELATIONSHIP WITH THE APPLE ARCADE
In addition to us, Apple will also be a controller in respect of your personal data. The information you provide when registering with the Apple Arcade as well as your use of the Apple Arcade will be personal data of which Apple is the controller.
WHAT DATA WE COLLECT
The Game collects “Personal Data” as you play the game in order to track game progression, to allow save game data across Apple devices and register achievements (‘Game Progress Data’). The data we collect cannot be used to identify you, but it will relate to you.
• Game Progress Data is the only Personal Data that the Game collects. This Game Progress Data is stored on Apple services such as iCloud and Game Center for game saves and progress and Game Center for achievements, and its use is governed by Apple’s policies.
• The game collects the Game Center ID for the purpose of achievements, game saves, and for cross save for the same account across different Apple devices.
• We do not store personal or gameplay data on our servers. The data is collected and stored on Apple Services such as iCloud and GameCenter.
• We do not use any other third-party analytics services for collecting or storing any data and we do not use cookies or similar tracking technologies to track user activity when you play the Game.
• The Game does not request access to data from any other Apps on your device.
• The Game transmits transient player data to game servers for app functionality and analytics to improve performance and gameplay
How to Access and Control Your Personal Information
You may decline to store data in iCloud or to send data to Game Center. To turn off iCloud data storage, you must turn off iCloud in Apple Settings for our game. To stop sending data to Game Center, you must sign out of Game Center in Apple Settings.
Where We Store and Process Personal Data
The Game collects data and stores it on Apple services such as iCloud for Game saves and Game Center for achievements. We do not store personal data on our servers.
Our Policy Towards Children
We do not knowingly collect personal data from children under 13 years old (or older, if applicable law provides for different protections). If we become aware that a child has submitted information to us, we delete this information immediately. We encourage parents and guardians to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet. Parents should give their consent to allow their children to access and use the Game. Once consent is given, the The Game collects, uses, and discloses data from children in the same way as for other users, as described in this policy. Game use of children’s data is limited to support internal operations of the Game. If you are a parent, you can decline to have that data collected from your child by turning off iCloud for our game and signing your child out of Game Center.
USER GENERATED CONTENT AND PUBLIC MESSAGING
If one of our games allows for user generated content (“UGC”) or features any form of public communication channels (such as forums) then you should be aware that any personal data you submit in the course of these public activities can be read, collected, or used by other users of these public communication channels, or viewers/users of your UGC and could be used for any purpose (for example, to send you unsolicited messages). Accordingly, to the fullest extent permissible by law, we shall have no responsibility for the controlling or processing of such data. If you post a video, image, photo, or other content through public communication channels or UGC for public view, you should be aware that these may be viewed, collected, copied, and/or used by other users without your consent. If your screen name or an ID contains your real name, then that name will be made publicly available on leaderboards and elsewhere. Therefore, you are strongly encouraged not to disclose personal data while using our games or use personal data to identify yourself while using our games. You are responsible for any public information or content you post using our games.
HOW DO I ASK A QUESTION OR FILE A COMPLAINT?
For all questions or complaints about this Privacy Policy, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance by contacting our Data Protection Officer via email at dataprotection@team17.com or by writing to Team17 Digital Ltd, 3 Red Hall Avenue, Paragon Business Park, Wakefield, West Yorkshire, WF1 2UL. If you are a Team17 Online Services user located in the European Union, please indicate that in your email or letter.
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).
In the process of receiving and responding to such requests, we may collect personal data about you, such as your name, e-mail address or any other personal data contained in the body of your e-mail message. We only use such information for the purpose of responding to or dealing with your questions and/or comments or to provide customer support. In most cases, your message is deleted immediately after we’ve resolved your inquiry; however, in some instances, copies of your requests may be kept on file for our records, for quality control purposes, or to provide ongoing support services you have requested.
If we have actual knowledge that the person with whom we’re communicating is a child under the age of thirteen, we delete the child’s e-mail address and message immediately after responding.