Effective Date: December 12, 2019
this document explains:
email: contact [at] netspeakgames [dot] com
1.1: About Us.
We are Netspeak Games (incorporated and registered in England and Wales with company number 11862950) of 1 Baker’s Yard, London, EC1R 3DD, England as well as the Netspeak Games group of companies (“Netspeak Games”).
All of our video games, our websites, user accounts, customer and technical support, wikis, blogs, social media services and other products and services - “Netspeak Games Services” for short.
1.4: What about children?
We recognise we have a special obligation to protect personal information 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 information 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 information about your child, please contact us via email: contact [at] netspeakgames [dot] com
1.5: What about GDPR?
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).
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: 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/processors. 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. Steam, 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 processor once a transaction takes place but we will not receive any of your actual payment details.
2.3: What about cookies?
We currently do not collect cookies on our website.
3: WHERE IS YOUR INFORMATION STORED?
We will store your information in Europe where possible. We will do our best to keep this information secure. No information security system is perfect so please remember to be careful.
Where will your information be stored?
All information we hold is stored on our secure servers which we own or license from appropriate third parties. We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.
4: HOW IS YOUR INFORMATION 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 information be used?
We may use the information above in order to (for example)
A) Perform our agreement with you: provide the Netspeak Games Services to you, including: to carry out our obligations arising from any contracts between you and us; 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.
C) Comply with our legal obligations: where we are required to do so by law; and comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
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; and send you push notifications on mobile devices where you have agreed to this.
4.2: Will we ever share any of your information with other parties?
A) We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
B) We may engage third party service providers in the course of providing the Netspeak Games Services to you (e.g. data storage, server hosting, customer and technical support, game analytics, advertising etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.
C) We may work with third party service providers (e.g. ad network and measurement services) to display advertising on the Netspeak Games Services and to manage our ads on third party sites. 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) We may share your information within the Netspeak Games company group for the purpose of providing the Netspeak Games Services.
F) No, Seriously, we will never share your information with third parties for their own marketing purposes without first obtaining your consent.
5: HOW YOU USE YOUR INFORMATION AND THIRD PARTIES?
You have the option to share your own personal information with other parties, in which case it will be governed by those parties’ own privacy policies – make sure to take a look at them.
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. 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?
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).
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 Baker’s Yard, London, EC1R 3DD, 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: contact [ at ] netspeakgames [ dot ] com.
8.2: Are there any other documents you should read?
Well done for making it to the end! Phew!