Privacy Policy

Home Privacy Policy

Last updated: 29th of May, 2018

The privacy policy explains what data we collect, use, store and share about you with third parties. This privacy policy applies to all Splinter Games games and the Splinter Games Website (named “products & services” from now on.

1. What information does Splinter Games collect ?

Here are the categories of information that are used across our products and services:

1.1 Voluntary provided information

At the moment we do not collect, store or process any voluntary provided information as we do not ask for anything that could identify you.

The contact forms and in-game feedback e-mails that you use are the only ways such information (your name, e-mail address) reaches us and is part of the functioning of the internet e-mail infrastructure. We do not store, use or process those information for anything other than direct communication regarding the subject you have chosen to contact us for.

We do not have any newsletter services that would use your e-mails provided through the above mentioned means.

1.2 Automatically collected or generated information

When you use our products and services there will be several types of data generated and stored across other devices or servers. While we do not store any of the following types of data, nor we process it to personally identify you, our services use it for improved or added functionality. However, certain information can be analyzed and correlated by third parties to identify you, which is totally out of our control.

1.2.1 Website data

This data is used during your interactions with any of our websites.

Cookies are text files stored on your computer that are used by the websites to identify you and provide streamlined functionality. Functionality might be (but ar not limited to) remembering your login/password data so you don’t enter it at every visit on a website, remembering which articles you’ve red in order to highlight new ones, etc. We do not have any direct access to cookies and you can delete them using your web browser.
Web analytics data (most common provider: Google Analytics) – this helps us understand user behavior across the website. We do not store this data, nor do we access any thing apart from aggregated forms that will not identify any particular user.

1.2.2 Product behavior data

Our games use several tools to understand player behavior and improve the quality of experience by its analysis. These tools collect information about each player and may fall into the following categories:

Behavior analytics – we specifically track user behavior in our games to improve the game experience such as (but not limited to) levels played, levels completed, levels failed, scores,etc.

Additionally, each tool we use may collect automatically data like the following:

Session start and end times, successive application
Device type and operating system
IP address, device identifiers
Broad geographic location such as country or city (based on IP)

Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Here are the third party tools we use for these purposes:

Fabric– user behavior analytics – privacy policy
Unity Analytics – user behavior analytics – privacy policy
Game Analytics – user behavior analytics / error logging – privacy policy
DeltaDNA – user behavior analytics – privacy policy
Facebook Analytics – user behavior analytics – Privacy Policy
Google Crashlytics – application crash debugging – privacy policy

We can look at aggregated forms of these data in each service’s provided dashboard, but we do not store , download or process this data independently.

1.2.3 Advertising data

The games that use advertising for monetization use tools that collect data automatically to identify users for serving advertisement. Apart from some of the data collected from above, the services may collect something called advertising identifiers.

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for interest based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple you can opt-out this by choosing “limit ad tracking” option from privacy settings. On Google Android you can opt-out by choosing “Opt-out of interest based ads”. Advertising IDs are non-permanent, non-personal identifiers, 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.

We do not access any of this information. Our software only requests an ad of a certain type (banner, full screen or video) and it is served to the user without our further involvement. Identifying a user it beyond the ability of our applications and our data access.

Advertising providers that we currently use:

Google Adwords – privacy policy
Unity Ads – privacy policy
Vungle – privacy policy
AdDuplex – privacy policy

1.2.4 Information from third party sources

At the moment we do not collect information from any third party sources, such as social media accounts, profile pictures, friends data, etc.

1.2.5 Platform data

Every platform we use to distribute our games has its own data collection policy that is mandatory in order to have our games reach your device. By platforms we understand software distribution services such as:

Android
Apple iOS
Windows Phone
Windows Store

Each of these platforms will store and process your information as part of their terms of service that you have agreed with. Additionally these platforms may process application usage data such as downloads, launches, session time and other such data that is accessible to us via the store dashboards.

This information is critical to both financial reporting as well as user and application research.

1.3 Special information

We do not collect, request or process, nor we plan to any sensitive information such as race, political orientation , sexuality, religion,etc. We just make video games.

2. How we use the information

The information above is used as follows:

Website data – used automatically by the website(s) to improve the quality of your experience.
Product behavior data – we look at the user behavior for research purposes directly involved to improving our product quality. For example we use this data to find out whether most users get stuck on a certain level , meaning it is too difficult, so we change it to allow you to experience more of the game. Also we use crash data to analyze possible causes of software failure , in order to remedy them.
Advertising data – this is used exclusively by our advertising partners listed above to serve you ads. We do not use nor access any of the user data generated by our ads partners. However our advertising partners may use this data to serve your customized ads experiences according to your preferences or for various other requirements. For example an advertising provider may choose to use your IP to prevent you from seeing too many ads in a certain period of time, or to make sure you don’t see the same ad multiple times.

3. Advertisement

We at Splinter Games use advertisement as a way to provide our products at a low cost. By serving ads in our games we create another source of revenue which enable us to continue developing and improving our products.

As stated in the previous sections, our Ad & Marketing partners may use and collect some of your information in order to:

serve advertisements tailored for your preferences
prevent you from seeing the same ad multiple times , from seeing too many ads in a certain period of time or for example from seeing an ad to the game you’re already playing.
create an advertisement profile based on the ads you’ve clicked on

This information is listed in the sections above and usually consists in IP address, Advertising identifiers, device identifiers, applications you’re serving the ad from and ads you’re clicking.

We also advertise our games on other apps by asking ad networks to serve its to audiences that will be interested in them (determined using preferences and target audiences).

For these purposes the Advertising IDs are used by the ad networks for a number of purposes (see our partners listed above) including for example to:

measuring ad effectiveness (looking at aggregated views, clicks and installs it generates through its advertising in other publishers’ games);
not showing adverts for a game,if a player is already playing the game
Marketing games to a group of potential players. We may provide Facebook or Google with a certain list of requirements that need to be matched by the network’s advertising ID. For example we may want to advertise our games to 25 year-olds in Russia. The ad services will target user who match this criteria and serve them our ads.
Ad networks to keep track what games you have used to market you similar kind of games.

You can opt out of interest based advertising on mobile applications by changing the privacy settings of your device and selecting “limit ad tracking” (Apple iOS) or “opt out of interest based ads” (Android).

4. Legal basis for processing personal information

The legal basis depends on each individual piece of information collected.

At the moment the only direct personal identifying information that may come in our posession is voluntarily submitted by you to us through e-mail.

By using our products (games) you consent to the collection and processing of the information required by our user research and our other partners (listed above) .

Also, as part of the platform you are playing our games on, you understand that we need to integrate platform services and technology in order for us to be compliant with them. For example we need to intergrate Apple iOS, Google Android , Windows Phone, Windows Store technology in order to function on those platforms. These platforms may have themselves data collection and processing that is required for each user.

We also process data on the legitimate interest of our products . For example by conducting user behavior research, crash reporting , or serving advertisements.

We have a legal obligation to process some personal data in cases such as financial and tax purposes, especially concerning things such as in-app purchases or advertiser payout for tax purposes.

5. Who do we share your information with ?

We only share information with our advertising, platforms and data collection partners listed above based on each partner’s terms of service.

We do not store or process any information on our own systems that is not voluntarily provided by our users.

We will however share information to legal authorities to comply with existing law as required.

6. How do we keep your data secure

All the data security is handled by our partners listed above as part of their terms of service.

We do not store any personal data on our systems excepting for your directly sent e-mails, and we take all security measures to ensure your e-mails are safe.

7. International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Our e-mail servers are located in the United States and our partners operate around the world. Each partner may have its own server infrastructure and/or data centers. This means that whenever you use our services some of your data may travel around the world based on the physical location of each data center.

We continuously strive to keep up to date with the latest APIs provided by our partners that ensure the latest forms of data protection technology. We do this to ensure that the latest safeguards are in place to comply with both our partners security standards and the data protection regulations.

8. Data retention

The data retention is covered under each of our partner’s terms of service. Splinter Games does not store any data excepting for directly addressed e-mails which are provided with your explicit consent when sending them to us.

Data is provided to our partners through their proprietary SDKs (software development kits) for storage and processing on their servers. Data will be stored according to the legitimate interests of the products. For example, if you want to make an annual report, you need to hold certain data at least one year.

Certain data such as data related to finances and taxes may be stored for longer times according to legal requirements.

9. Your data protection rights

You have the following data protection rights:

To access, correct, update or request deletion of data that we store about you.
To object to processing of your personal information. Since we are collecting the minimum amount of data required for the operation of our services, requests of restriction will mean also restricting access to our products and services.
to opt-out of marketing communications. Right now we do not offer any marketing communications such as newsletters. But when we’ll do, you have the right to opt out of it.
If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.You can control and limit the nature of personal information that we collect and process about you in a number of ways. For example, you can disconnect your social media account from our games or control your social media privacy settings to limit the information shared with us. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. You could also limit or disable the use of cookies (or similar technologies).We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10. Age restrictions

While we do not have products specifically targeted for minors under 13 years old, some of our products and services may end up being used by them.

We do our best to comply to all age restrictions requirements, associations and rating agencies (PEGI, ESRB,etc) by providing correct and complete information about our products.

However, if we’ll detect any behavior such as communication from children we will take reasonable measures to remove them from our records.

11. Updates to this privacy policy

We will update this privacy policy according to changing legal, technical or business requirements. As our privacy policies update we will take measures to inform you about the changes. To always stay up to date please check back to this page from time to time.

12. How to contact us

Data controller: Splinter Games SRL, CP 90 Oficiul Postal 2 Sector 1, Bucharest. Email: privacy@splintergames.com

Please make sure to also review the data privacy policies of our third party data partners as listed in the first sections of this policy.