Digital Castle Entertainment
Privacy Policy

Introduction

Digital Castle Entertainment (DCE) is committed to protecting the privacy and security of your personal data. DCE collects different types of information from you when you use our mobile, online and downloadable products and services (together, the "Products").

This Privacy Policy explains how we collect, use and protect your personal data when you use our Products or interact with us.

By using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.

The data controller is responsible for collecting and using your personal data. To comply with data protection legislation, the data controller will be DCE with whom you contract for a Product.

We reserve the right to update this Privacy Policy from time to time by changing it as it applies to your use of any of our Products. We want you to enjoy using our Products and urge you to follow common sense whenever disclosing personal data – in our Products or elsewhere.

Summary

Our Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it. The key points of our Privacy Policy are provided below.

1. Information We collect and receive

We collect personal data about you and the devices you use to access and interact with us and our Products. We collect:

(a) Registration information: you give us when you sign up to access our Products

(b) Billing information: provided by you and/or third party stores

(d) Feedback / surveys / user research: your questions, suggestions or views on our Products

(e) Third party information: information about your use of our Products that is shared with third party platforms and services connected with our Products

(f) Information from publicly available online sources: information about your use of our Products that is shared with third party platforms and services connected with our Products

(g) Information about your use of our Products: information we collect when you use our Products

(h) Competitions: information you provide to us when you participate in our competitions

(i) Social media plug-ins: information that is collected when you utilize third party social media plug-ins relating to our Products

(j) Anti-cheat and anti-hacking technologies: information that helps us to ensure our Products are used in a fair and lawful manner

(k) LiveOps software: information that is processed by third party LiveOps tools when you use our Products

(l) User Acquisition/Attribution and Core / Custom / Lookalike Audiences: information that is collected to help us acquire new users for our Products and to build Core, Custom and Lookalike Audiences

2. Our Use Of Collected Information

Collected information may be used in the following ways:

(a) Registration Information:

(i) to create your profile and so you can access our Products;

(ii) to identify you when you sign-in;

(iii) to give you access to your user preferences;

(iv) to contact you for your views on our Products;

(v) to notify you of changes or updates to our Products; and

(vi) for marketing purposes, based on your communication preferences.

(b) Billing Information:

(i) to verify your purchase of our Products and process any refunds;

(ii) to reply to any queries and questions and to resolve problems;

(iii) to carry out analysis and research to develop our Products; and

(iv) to protect you and our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.

(c) Technical and Device Information:

(i) to provide you with an optimal experience.

(ii) to understand how you interact with our Products

(iii) to provide Products you request.

(iv) to measure and analyze the use and effectiveness of our Products.

(v) to understand which of your devices are using our Products and playing our videogames.

(vi) to provide safe and fair gaming environments.

(vii) to customize and optimize the targeting of our advertising both within our Products and across our websites;

(viii) to operate and improve our Products; and

(ix) to fix errors.

(d) Feedback / Surveys / User Research:

(i) to reply to your questions or queries.

(ii) to record comments and information which you provide on our gaming forums;

(iii) to conduct analysis and research to improve and develop our Products.

(e) Third Party Information:

(i) to enable us to provide tailored offers to you.

(ii) to facilitate sharing on social networks; and

(iii) to facilitate your gameplay.

(f) Information From Publicly Available Sources:

(i) to understand the community sentiment about our Products.

(g) Information About Your Use Of Our Products:

(i) to track the performance of our Products;

(ii) to communicate with our platform operators and partners; and

(iii) to improve our advertising and targeting systems.

(h) Competitions:

(i) to verify your identity;

(ii) to distribute prizes to you.

(i) Social Media Plug-Ins:

(i) to allow you to easily share our content via social media platforms.

(j) Anti Cheat And Anti Hacking Technologies:

(i) to detect illegal or malicious activity in our Products.

(k) Liveops Software:

(i) to provide certain in-game features and functionality.

(l) User Acquisition / Attrubution And Core / Custom / Look A Like Audiences:

(i)to acquire new users for our Products, to measure the performance and effectiveness of our marketing campaigns and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.

We use the personal data we collect for the following purposes:

(a) Registration Information:

Your registration information enables us to provide you with access to our Products and to supply the Products. This is necessary for the purpose of performing the contract we have with you. It helps us to authenticate your access, to contact you for your views and to notify you of important changes or updates to our Products.

Where we have your consent and in accordance with your stated communication preferences, we may also contact you for marketing purposes to let you know by email, telephone, mobile or in-app messaging about our other products and services.

If you choose to sign-up for our Products using third party services such as your Facebook account, Facebook may share your personal data with us subject to Facebook's privacy policy and the privacy settings of your Facebook account. This may also enable Facebook and us to link your activities with your personal registration information at their site, and may include notifying your friends about your activities whilst using our Products. If you sign-up via third party services you should visit the third party website and review their privacy policy and your registration profile or account to understand how your data is processed by them and to find out what your options are.

If you no longer want us to use your personal data in this way or generally change your mind about receiving marketing communications, you can unsubscribe at any time, either by using the unsubscribe option in the communication you receive or by changing your communication settings. By unsubscribing from marketing communications, you will be opted out of our e-mail/marketing tracking pixels. Please note that we will retain a record of the user information when you unsubscribe from our marketing information for the legitimate purpose of ensuring that we do not contact you further in this way, during the period of your objection, if relevant.

(b) Billing Information:

This information will enable us to verify your purchases with third party stores and to contact you in order to assist with resolving any problems with your purchases and to process any refund payments that you may be due.

We will also use and analyze information on transactions on your account for our legitimate interests by data matching or statistical analysis so that we can administer, support, improve and develop our business and to help us detect and prevent fraud, or other illegal activities, or acts prohibited by our terms of service or any policies applicable to our Products.

(c) Technical And Device Information:

We analyze information about how you engage with our Products to understand how our Products are used and to provide you with an optimal gaming experience, such as by rolling out performance-optimizing software updates for our Products. We use anonymous data to analyze and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals. This allows us to deliver you personalized content, helps us understand the features of our Products that appeal to you and allows us to manage advertising, amongst other things.

When you interact with or visit our websites, we may automatically collect information about you such as the type of internet browser or mobile device you use, any website from which you have come to any of our Products and your IP address and your operating system, which are automatically recognized by our web server.

We use internet log files to monitor traffic on our Products, resolve technical problems and to detect and prevent fraud. We use these technologies to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of advertising or marketing on our websites. In some cases, working with third-party partners, we use this information to send you ads for our Products based on your interests.

We also use technical and device information to operate and improve our Products, enable online matchmaking, facilitate sharing, measure our effectiveness, set up and maintain accounts, identify and fix errors and to help keep online content fair and safe and to resolve related disputes.

(d) Feedback / Surveys / User Research:

We share information obtained from your use of our Products with third parties to provide you with an optimal experience, to facilitate use of our Products as advertised and to enable you to play our Products on various gaming platforms.

We also receive data about you and your use of Products from Platform Operators. This data includes but is not limited to:

(i) sales data so that we can track the sale and performance of our Products; and

(ii) gameplay data related to your interactions with our Products, including player performance statistics, in-game actions, character options and other similar in-game data which helps us to improve certain aspects and features within our Products.

We may also work with advertising networks that serve advertisements into our Products, or the websites and products of third parties. Some of those advertisements may be personalized to your interests based on your activity and technical information and/or use data contained within the cookies which are stored on your device, with your consent.

Certain Products are currently supported by third party advertising partners that serve advertisements (“Third Party Advertisers”), including behavioral, location or interest based advertising (“Interest Based Advertising”) within our Products.
These Third Party Advertisers use technology to serve the advertisements and link to them directly into our Products. They may automatically receive your device ID, IP address or geo-location data when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content you see. See also our Cookies Policy.

We may also provide functionality within our Products which enables you to upload gameplay footage to YouTube. If you choose to use this feature, we will receive and store an authentication token from Google so that the feature will operate properly. The use of this functionality is governed by YouTube’s Terms of Service: https://www.youtube.com/static?template=terms. Further information about the protection of your privacy can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en-US. You can also view and modify your permissions via Google’s security settings: https://myaccount.google.com/permissions.

(f) Information From Publicly Available Sources:

We will use and analyze this data for our legitimate interests so that we can collect information about how you use our Products, how you engage with our marketing campaigns and to gain an understanding of community sentiment about our Products. We may use third party analytics providers who collect this data on our behalf. Where possible, we will ensure that any personal data that is collected for these purposes is anonymized.

(g) Information About Your Use Of Our Products:

This information enables us to track the performance of our Products, develop new Products and communicate with our Platform Operators and partners. It also enables us to better understand our users and improve our advertising, targeting and measurement systems. We will only provide tailored advertising where we have your consent. Any information we use to inform and enhance our business strategies is fully anonymized.

(h) Competitions:

(i) Social Media Plug-ins:

Once your data has been shared with the social media platform (acting as a joint controller of your data), your interactions with these features are governed by the privacy policies of the relevant platform. More information about their privacy practices can be found at the following links:
https://www.facebook.com/about/privacy/.

(j) Anti Cheat And Anti Hacking Technologies:

DIGITAL CASTLE may utilize anti-cheat and/or anti-hacking technologies to help us to detect illegal or malicious activity and to take the appropriate actions if such activity is detected.

The anti-cheat/hacking technologies within your Product may require you to download certain data to your device. If you disable or otherwise tamper with these technologies, the Product may not operate properly and you will be in breach of the applicable end user license agreement.

(k) Liveops Software:

If you play a Product that utilizes LiveOps software, that third party software will collect certain personal data about you as required by that service. This personal data will be processed and stored in accordance with the third party’s privacy policy (as notified to you before your data is collected, most commonly when the Product first launches).

(l) User Acquisition / Attrubution And Core / Custom / Look A Like Audiences:

We use various forms of marketing to acquire new users for our Products, working with a variety of third-party partners to deliver our marketing campaigns and serve advertisements on external websites and social media platforms. As part of this, we may share certain data with our user acquisition and attribution partners.

If you have consented to this type of marketing, you will receive targeted ads when you use the internet or play our Products (our Custom Audience). Other users of those platforms who share similar interests to you may also receive targeted ads about our Products (our Lookalike Audience). Other users may receive ads about our Products depending on their age, location, gender and language (our Core Audience).

Further information about the protection of your privacy can be found in the relevant partner’s privacy policy. You can disable the remarketing functions by visiting the following links:

Platform privacy policy:

Facebook: https://www.facebook.com/about/privacy/

Google: https://policies.google.com/privacy?hl=en-US

Optout: https://about.meta.com/actions/promoting-safety-and-expression/

https://support.google.com/google-ads/answer/9606827?hl=en

You will need to log in to the social platform to administer your advertising preferences.

We will only collect and process personal data about you where we have a lawful basis. As stated throughout this Privacy Policy, our lawful bases include consent (where you have given consent to, say, receive updates and marketing emails), contract (where processing is necessary for the performance of a contract with you (e.g. to supply the Products you have requested)) and “legitimate interests”.

3. When We Share informaiton

We may share the information we collect about you (subject to the necessary security, contractual and transfer safeguards). These are some of the partners we may share your personal data with:

(a) DIGITAL CASTLE companies within the wider DIGITAL CASTLE group;

(b) Third party platform operators such as Apple, Google Play and other partners who carry out various activities and services to support our Products (collectively, the “Platform Operators”);

(d) New owners or re-organized entities and their advisors in the event of a business restructure, sale, purchase or joint venture affecting our business; and

(e) Law enforcement agencies/authorities, when we are under a duty or are authorized by law for law enforcement purposes.
Your personal data may be transferred to other countries where DIGITAL CASTLE or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access our Products, but we will ensure that we rely on appropriate safeguards.

In delivering our Products to you, we may share your personal data with:

• Companies within the DIGITAL CASTLE group (which means DIGITAL CASTLE Entities which are our parent and affiliated companies, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy.

• Third parties in order to undertake various activities or services on our behalf in supporting our Products. This includes payment processing providers facilitating credit and payment card transactions, website and application support and hosting providers for online videogame services and software downloads and providers for the delivery of promotional, digital advertising or other communications, such as MailChimp.

• If our business enters a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their advisors.

• We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organizations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings.

4. Security And Data Retention

Your privacy is important to us and we place great importance on the steps we take, including technical and organizational measures to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.

Your personal data will be kept by DIGITAL CASTLE for the duration of your relationship with us and for as long as you use our Products and may be retained for a period after this time if it is necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws.

We place great importance on the steps we take, including physical, technical and organizational measures, to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.

Where you have chosen a password which allows you to access any of our Products, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We will not be liable for any unauthorized transactions entered into using your personal data, including but not limited to your username, and/or password. If you suspect unauthorized access, you should change your password, using a strong password immediately.

Your personal data will be retained by us for the duration of your use or access to our Products and may be retained for a period after this time as necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce any obligations in our agreements, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings.

We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.

We will take appropriate steps to seek to destroy or permanently de-identify personal data at the point this information is no longer needed by us for our business or legal purposes.
For more information about exercising your rights with respect to our data processing activities, or if you no longer wish to use our Products, see details below about your choices and rights.

5. Your Choices And Rights

You have options and choices over how we use your personal data. You may be required to register or sign in to use or access some of our Products, and may need to provide personal data to create a user profile which is associated with your use of our Products.

If you wish to amend the personal data that you use to access our Products or would like us to correct, erase, restrict, object to, or move your personal data, you can make a request through our CONTACT US on our website.

You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of our Products at any time. If you need to sign in to access certain Products, you can update and amend your key contact information directly.

We respect the rights you may have under applicable law to request access to your personal data and where applicable, to request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal data, to seek to object to the further processing under certain circumstances of your information or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information.

6. Children’s Information

Protecting the privacy of young children is especially important to DIGITAL CASTLE. For that reason, DIGITAL CASTLE does not knowingly collect or maintain personal data or non-personally identifiable information from users under 13 years of age, other than as permitted by law in support of our internal operations.

If DIGITAL CASTLE learns that personal data of users under the age of 13 has been collected, other than for support of our internal operations, DIGITAL CASTLE will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal data about your child who is under 13 years of age, you may contact us using the details provided below.

7. Californian Privacy Notice

The Californian Consumer Privacy Act 2018 (the “CCPA”) and the Californian Shine the Light law provides Californian residents with certain rights regarding the processing of their personal data.

Our customers who are residents of California have the following rights under the CCPA:

(a) The right to request the deletion of their personal data;

(b) With respect to the collection of personal data, the right to request, not more than twice in any twelve (12) month period, the following:

(i) the categories of personal data we have collected about you; (ii) the categories of sources from which the personal data is collected;

(iii) the business or commercial purpose for collecting or selling your personal data; (iv) the categories of third parties with whom we share your personal data; and (v) the specific pieces of personal data we have collected about you;

(c) With respect to the sale and/or disclosure of personal data, the right to request, not more than twice in any twelve (12) month period, the following: (i) the categories of personal data that we have collected about you; (ii) the categories of your personal data that we have sold and the categories of third parties to whom the personal information was sold, by category or categories of personal data for each third party to whom the personal data was sold; and (iii) the categories of personal data that we have disclosed about you for a business purpose;

(d) The right to opt-out of the sale of your personal data; and

(e) The right to not be discriminated against for exercising any of the above-described rights.
To exercise any of your rights under the CCPA, you can contact us, providing your name, email, and street address. We may ask you for other information to verify your identity. Any information we receive from you to verify your identity will solely be used for such verification purposes.

Californian Shine The Light Law

The California Civil Code Section 1798.83 (“Shine the Light”) permits our customers who are Californian residents to request, once per calendar year, the following information from us: (i) a list of the kinds of personal data that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and (ii) the names and addresses of all of the third parties that received your personal data from us for direct marketing purposes during the preceding calendar year. For inquiries regarding our disclosure policy, please contact us as described below in Section 8 “Your questions and how to contact us”. Requests must include “California Privacy Rights Request” in the first line of the description and should include your name, street address, city, state, and ZIP code.

8. Your Questions and how to contact Us

If you have any questions or comments about this Privacy Policy you can contact us.

If you have any questions or comments about this policy or our practices you can contact us through our CONTACT US page on our website or you can also contact our data protection officer at info@digitalcastle.com

Digital Castle Entertainment Privacy Policy