Effective Date: August 1, 2022
You must be at least 13 to play Sunshine Days
Legally, we cannot and will not knowingly collect personal data about children below 13 without parental/guardian involvement.
If you do not understand this page, please ask your parent or guardian to explain it to you.
We collect information about you in different ways, for example, when you play Sunshine Days or use this website.
When you register to play Sunshine Days we’ll ask you for information about you.
We will need to use information we have about you to allow you to play - this means we might need to share your information with people and companies who help us run Sunshine Days and our website, and who might be based around the world. People around the world might also see the username you use when you play Sunshine Days.
You (or your parent or guardian) can tell us if information we store about you is wrong or if you think we should delete some of your information or stop using it in a certain way. You can also ask to see your information at any time.
If you are worried about how we handle your information, you or your parent (or guardian) can also email us at support [at] netspeakgames [dot] com and speak to your national data protection authority.
this document explains:
This Privacy Policy explains to you how your personal information is collected and stored and what happens to it regarding the Netspeak Games Services. Because we know legal wording is not much fun, we have included a short and informal summary of each section (but the full version is the legally binding one). If you have any queries you can contact us here:
email: support [at] netspeakgames [dot] com
We recommend that you use display names that do not identify you.
1: WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS
This Privacy Policy explains the different kinds of information Netspeak Games can collect from you when you're using the Netspeak Games Services. Legally, we cannot and will not collect personal information about children below 13 without parental/guardian involvement. We will comply with applicable privacy laws, including the EU’s GDPR.
1.1: About Us.
We are Netspeak Games (incorporated and registered in England and Wales with company number 11862950) of 1 Giltspur Street, London, EC1A 9DD, England as well as the Netspeak Games group of companies (“Netspeak Games”). We are a controller in connection with personal data we hold about you. This means that we are responsible for the security of the personal data and the decisions we make regarding the personal data. We are registered with the Information Commissioner’s Office with registration number ZA564684.
1.2: Which services does this Privacy Policy apply to?
All of our video games, our websites, user accounts, customer and technical support, wikis, blogs, social media services and other products and services including our newsletters and promotion materials that we may send to you, from time to time
1.3: What information does this Privacy Policy apply to?
Specifically, this Privacy Policy governs personal data (or, in the USA, personally identifiable information), which we collect from you when you are using the Netspeak Games Services ("personal data" means information which, on its own or in combination with other information, can be used to identify you).
1.4: What about children?
We recognise we have a special obligation to protect personal data obtained from children. Legally you must be at least 13 years old to use the Netspeak Games Services (but this might be older depending on whether or not a particular Netspeak Games Service has a required minimum age rating). We do not knowingly collect personal data from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal data about your child, please contact us via email: support@ netspeakgames.com
1.5: What about GDPR?
We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal information contained in this Privacy Policy which is used by Netspeak Games in connection with the Netspeak Games Services, Netspeak Games is the data controller under EU data protection legislation.
2: WHAT INFORMATION IS COVERED?
We may collect certain information when you use the Netspeak Games Services such as your name and email address (more information below). We do not receive or store your payment details.
2.1: What information might we collect from you?
When you sign up for, download, use or play the Netspeak Games Services then we will collect certain information from you. The information that we collect varies depending on the particular Netspeak Games Services used, but this may include:
A) Technical Details. When you use, play or access the Netspeak Games Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any console device identifier; your operating system, browser type or other software; and your hardware or other technical details.
B) Your Activities. When you use, play or access the Netspeak Games Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences; in-game purchases; achievements; scores; gameplay statistics; time spent playing; and your geographical location data.
C) Your Communications. If you contact us (e.g. via email or call for customer support) or post in chat sessions, forums, on our social media pages, apply for a job, take part in market research, or other areas of the Netspeak Games Services, we may collect and maintain a record of your contact details, the content of your communications and other personal data you submit to us.
D) User Accounts and Newsletters. To access certain Netspeak Games Services (e.g. our games or website) you may need to create a user account. Or if you sign up to a newsletter, you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable Netspeak Games Services (e.g. when you sign up for a newsletter) and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.
E) Third Party Accounts. In certain circumstances you may be able to log into certain Netspeak Games Services via third party accounts (e.g. Facebook, GitHub, Twitter). If you choose to do so, you are asked to share certain information with us (the exact information will depend on the particular third party account displayed to you on the permissions page when you attempt to log in, but may include your name, location, gender, birth date, email address, photo, profile URL and friends list).
F) Advertising. We may receive personal data about you as part of our marketing and advertising efforts including as part of receiving information about how successful our marketing and advertising efforts are on different apps and online platforms. We and third party advertising service providers may collect the following information about you and your device, some of which amounts to personal data about you: gameplay information: your use of the game, for example, your actions within the game, your progress within the game, your preferences, your in-app purchases and your session time and metrics third party platform information: your use of third party social media and other online platforms device identifiers: IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, any user IDs issued by us about you and other similar unique identifiers device information: this refers to technical information about your mobile device such as: device type and model, CPU, system language, memory, OS version, Wi-Fi status and time stamp zone. Social media and other platforms. We may receive personal data about you such as opinions and comments you make via social media, when you interact with our accounts on social media and other online platforms, for example, when you post something on our LinkedIn page or when you tag us on one of your posts.
Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.
2.2: How do we collect personal data?
Sunshine Days
We mostly collect personal data directly from you. You will provide us with your personal data when you use the Netspeak Games Services. You will provide us with your personal data when you register for an account and when you use your account to play Sunshine Days.
You can play our game on an iPhone or an Android phone. When you register to play and play our game on your phone we might receive personal data about you from Apple and Google.
Advertising and marketing strategy
We may also receive personal data about you as part of our advertising campaigns, for example, via social media platforms such as Facebook and any services we receive to understand and improve our advertising campaigns. We use Adjust as our advertising partner. Adjust collects and provides us with a number of device and advertising identifiers and information in the form of aggregated data reports to help us understand how our marketing strategy is performing and to promote Sunshine Days to you and potential new players.
Social media
We may also receive your personal data through social media and other online platforms such as Twitter, Instagram and Discord when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, and when you otherwise provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Twitter or when you provide information about you on the Sunshine Days Discord channel.
Correspondence and other third parties
We may also collect your personal data through any platforms you use to contact us and to be part of the Netspeak community, for example, when you communicate with us via our Discord forum or when you email at. We may also collect your personal data from other individuals who may, for example, mention you in any communications they send to us or make available about you on social media and other platforms. We may also receive personal data about you from other entities within our group of companies. We may also receive personal data about you from any other types of organisations listed in the section titled ‘Will we ever share any of your personal data with other parties?’ below.
2.3: What about the storage of payment details?
The processing and storage of payment details is a matter for the relevant platform and the applicable payment methods/payment service providers. Netspeak Games will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g., Apple’s App Store or Google Play) via the user account you have associated with that platform account. If you make in-game purchases within a Netspeak Games game or product, we are notified by the payment service provider once a transaction takes place but we will not receive any of your actual payment details.
3: WHAT ABOUT COOKIES AND OTHER SIMILAR TECHNOLOGIES?
Website: We currently do not use cookies or other similar technologies on our website.
Sunshine Days: We use different types of technologies on Sunshine Days which collect, store and read data on your mobile device.
We currently use the following types of technologies on Sunshine Days:
Necessary
Those that are necessary for the operation of the game, including allowing you to interact with our game and to recall selections as you move between different parts of the game and which enable core functionality such as security, credentials authentication, network management and accessibility and to determine changes in information you provide to the game.
Performance (analytics)
Those that analyse the use of our game, for example, to help analyse how players use our game. We use this information to identify trends and improve our game.
Functional
Those that are used to provide certain functionalities within our game and to remember choices you make so we can personalise the content of the game for you.
Advertising (targeting)
Those that are used to deliver advertisements about our game within third party websites and apps. You will be able to reject any non-necessary technologies via a banner when first downloading Sunshine Days. You might also be able to prevent your device identifier to be used for certain advertising activities via the settings of your device.
4: HOW IS YOUR PERSONAL DATA USED?
We will use your information to run, maintain and improve the Netspeak Games Services as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may share information with partners in order to run our services.
4.1: How might your personal data be used?
In accordance with data protection laws, we will only process your personal data if we have a lawful basis for doing so.
In respect of your personal data, these bases are: if it is necessary to provide services to you under the performance of a contract we have with you if we are required to do so in accordance with legal obligations if you have given your consent if it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests.
The following is a list of the purposes for which we process your personal data, and the lawful bases on which we carry out such processing.
A) Perform our agreement with you: provide the Netspeak Games Services to you, to carry out our obligations arising from any contracts between you and us; to facilitate logging in and playing Sunshine Days, to allow you to participate in interactive features of the Netspeak Games Services when you choose to do so and provide you with chat functionality and other communication systems, receiving and responding to correspondence, for account verification purposes, to display in-game profiles or display names and leader boards, to make event/content related information available to you and to make information about changes to the Netspeak Games Services available to you.
B) For our legitimate commercial interests: advertising: to engage with players and potential players including providing advertising on third-party websites and platforms (legitimate interests of promoting our offerings, including commercial interests in expanding our business) to understand when players have interacted with advertising and been directed to the Netspeak Games Services, especially our websites (legitimate interests of understanding the success of advertising campaigns) to carry out surveys (when these surveys do not contain any direct marketing or when we have obtained soft opt-in) (legitimate interests of improving the Netspeak Games Services) to analyse statistics that provide us with an understanding of the level of success of our marketing campaigns (legitimate interests of better understanding our marketing campaigns) administering the Netspeak Games Services and monitoring: the performance of the Netspeak Games Services; to prepare and analyse statistics relating to the use of our game by you and other users, testing, to investigate complaints, to seek and analyse feedback and to further develop the game (legitimate interests of ensuring our games are as enjoyable as possible to ensure that the Netspeak Games Services are presented in the most effective manner for you and your device(s) (legitimate interests of ensuring Netspeak Games Services are as enjoyable as possible disclosure of gameplay results to third-party services to consolidate and publish (legitimate interests in assisting the administration of our game). to administer, maintain, protect and improve the Netspeak Games Services and to protect Netspeak Games and Netspeak Games Services users, including carrying out activities involving development, analytics, traffic patterns, addressing hacking, cheating and other harmful activities (legitimate interests of running our business, provision of administration and IT services, including network security); to run our everyday operations: to allow communications between members of staff and the transfer of personal data between members of our corporate group in connection with the provision of the Netspeak Games Services and to engage with third party suppliers and business contacts (legitimate interests of running our business); receiving and responding to correspondence (legitimate interests of ensuring a good user experience (when outside the performance of a contract with you)). To administer a corporate change: to administer a sale or possible sale of the whole of or part of our business or the restructuring of our business (legitimate interests of facilitating any such possible or actual transaction or restructuring).
C) Comply with our legal obligations: where we are required to do so by law, for example, to comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive or to respond to a data subject request you may submit.
D) Based on consent: provide you with marketing information about products or services that you request from us or which we feel may interest you where you have asked us to do so or have opted-in for and send you push notifications on mobile devices where you have agreed to this.
We may also process your personal data for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.
In certain circumstances, you may be obliged to provide us with your personal data under a statutory or contractual requirement. This might include, but is not limited to, personal data we require to enter into an agreement with you; for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation. Failure to provide us with personal data required under a statutory or contractual requirement may prevent us from entering into or performing our obligations under a contract with you.
4.2: Will we ever share any of your information with other parties?
We may share your personal data with other parties. We describe the circumstances in which we share your personal data with other parties below:
A) other players, our game allows you to interact with other players and allows the sharing of information about your character and their adventure with other players
B) third party service providers in the course of providing the Netspeak Games Services to you and operating our business, for example, organisations that provide us with technology related services such as data storage, server hosting, customer and technical support as well as game analytics, advertising etc) which may require them to access your information on our behalf. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) and activities carried out for their own purposes will be covered by their own privacy policies.
C) third party service providers providing us with marketing campaign related services (e.g. ad network and measurement services) such as Adjust to display advertising on the Netspeak Games Services and to manage our ads on third party sites and social media platforms (e.g. we may share your personal data with Facebook to create Facebook Lookalike Audiences). We may share certain information (such as your email address, country of residence and your age) with third parties so that we can better target ads and content to you. You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device and you may be able to opt-out from the collection of information by some of our advertising partners.
D) providers of operating systems you play our game on, such as Apple and Google.
E) We may share your personal data within the Netspeak Games company group for the purpose of providing the Netspeak Games Services.
F) Social media and other online platforms such as Twitter, Discord and Instagram which we use to communicate with you or to share photos and text that you share via your profiles on these sites, for example, when we reshare a post that you are mentioned in via our profile on a social media site.
G) external professional advisors who need to access such information for the purpose of advising us.
H) law enforcement bodies which may have any reasonable requirement to access your personal data, for example, in order to assist with any investigations, when we bring a claim or defend ourselves against a claim that requires the disclosure of personal data.
I) potential purchasers of our business or investors in it (including in the event of insolvency).
4.3: International transfers
Some of the parties we share your personal data with might be based abroad. When your data is transferred internationally, we are required to ensure you are afforded equivalent protection in respect of your personal data to that provided in the UK and the EU.
Generally, we will put in place appropriate safeguards when making international transfers, for example, by using specific contractual clauses which have been approved by the European Commission and/or the UK government together with supplementary measures if we deem it necessary in the circumstances, for example, further contractual commitments, enhanced security and assessments of transfer risk.
5: INFORMATION YOU MAKE PUBLICLY AVAILABLE
Please remember that any communications you have via the Netspeak Games Services may reveal details about you. Also, any information you post publicly will be publicly available to other people. We have no control over your use of any otherwise private personal data which you make available, or the activities of other users or other third parties to whom you give or make available your information or content. PLEASE DO NOT SHARE ANY SENSITIVE INFORMATION (FOR EXAMPLE, INFORMATION ABOUT MEDICAL CONDITIONS) ON ONLINE FORUMS OR OTHERWISE MAKE IT AVAILABLE TO US OR OTHER PARTIES VIA ANY POSTS OR COMMUNICATIONS. The Netspeak Games Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.
6: DATA RETENTION
We retain your information for as long as needed to provide the Netspeak Games Services to you or longer where permitted by law.
How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. We will retain your personal data only for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any contractual requirements or other legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the purposes for which we process the personal data, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, whether we can achieve those purposes through other means and the applicable legal requirements. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all Netspeak Games Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.
7: YOUR RIGHTS
You have rights about how your personal information is used, which can vary depending on where you live. If you have any questions, please contact us at contact [ at ] netspeakgames [ dot ] com.
7.1: Can you ask us to stop processing your personal information?
You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications.
7.2: What are your rights?
Depending on where you live, you may have additional privacy rights. For example, in the EU and the UK you have the following rights. If you have any questions about your rights, or you wish to exercise any of these rights, please email contact@netspeak.com. We may require you to provide forms of identity should you wish to exercise one of your rights below. You have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain Netspeak Games Services may no longer function properly, be completely unavailable to you (even services that you have paid to use).
Access: to access and obtain a copy of your personal data we have about you.
Rectification: if the personal data we hold about you is incorrect, you have the legal right to ask us to rectify/correct your personal data.
Erasure: you may have the legal right to contact us to request that we delete your personal data from our system if there is no compelling reason to continue processing.
Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below).
Objection: You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.
You may object to receiving direct marketing at any time.
Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.
Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email support@netspeakgames.com to withdraw consent for the processing of your personal data.
Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the Information Commissioner’s Office (https://ico.org.uk/). If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.
Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data
7.3:
Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Netspeak at 1 Giltspur St, London, EC1A 9DD, England. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.
7.4: Who should you contact if you would like to exercise these rights?
If you would like to exercise any of these rights or have any queries regarding them, please contact: support [ at ] netspeakgames [ dot ] com.
8: OTHER
We can change this Privacy Policy, but if we do we will put the changed version online. Please feel free to contact us if you have any questions with regards to the changes at support [ at ] netspeakgames [ dot ] com.
8.1: Will we ever change this Privacy Policy?
Possibly, but if we do we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on you as of the date of publication (i.e. the new “Last Updated” date). You are welcome to contact us if you have specific questions about the changes at support [ at ] netspeakgames [ dot ] com. If you do not agree to those changes, regardless of whether you email us then unfortunately you must cease using all Netspeak Games Services.
8.2: Are there any other documents you should read?
We'd also like to remind you that our Terms of Use has more information about how we operate the Netspeak Games Services : https://netspeakgames.com/terms-of-use/
Well done for making it to the end! Phew!