PRIVACY AND DATA POLICY
ISSUED BY CHUCKLEFISH LIMITED
Last Updated: 10 February 2020
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed and/or published by Chucklefish Limited. (“Chucklefish” / “we“ / “us”). Our registered office is at 64 Southwark Bridge Road, London, SE1 0AS.
We are a company registered in England, with company number 07664836.
Together the Game(s), the Website and Communities are referred to herein as the “Online Services”.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal information you have provided to us.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information, which may include your personal data.
Information provided by you when using an Online Service
We will collect personal information from you when you use our Online Service or when you contact us for support:
This may include:
Information about your gaming and activity
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
This also includes the use of ‘cookies’.
The following cookies are used on the Websites:
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. To opt out of being tracked by advertising providers you can access a general opt out at http://www.networkadvertising.org/managing/opt_out.asp
Information about you collected from third parties
We may collect information which you make available to us via your various profiles, including your Steam account.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Games to you
To enable operation of the Game
To enable in Game purchases
If you make purchases through the Online Services, your order and Submitted Information may be processed so that you can access these features within the Games.
To provide the Communities and Preventing Spam
Certain Content Information and Submitted Information which you supply through our Online Service will be shared with other users of the Online Service. In some cases you may be able to select specific recipients (for example if you are sending a forum post, or a private message, to a particular forum or individual) then only those recipients will receive it, however in all other cases, your information may be made publically available.
We may make your Content Information and Submitted Information available to forum moderators. Moderators are crucial to the Communities and help make them the place that they are. Moderators are directed to only act in accordance with our instructions and to adhere to the moderator rules.
Spam is a problem for many forums and websites. In order to minimise this we use Stop Forum Spam to check that any new registration is not spam. In order to do this certain information is provided to Stop Forum Spam for the sole purpose of checking that it is not spam. You can find out more about how Stop Forum Spam use this information on their website available here: https://stopforumspam.com/privacy
To respond to your enquiries and requests for support
As part of this we may share this Submitted Information and Content Information with the developers of the Games that we publish.
For advertising purposes
We may process Submitted Information, Analytics and Content Information to show you advertisements for third party services. Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not Chucklefish.
Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data.
Our Online Services integrate with AdSense, Google Analytics and GG Software. Analytics data will be processed and tracked by those third party services, and you can find out more about the way they use this information at the following locations:
To keep you up to date
We use your Submitted Information to send you emails in order to keep you informed of news and products. To do these we use our internal process and may use Mailchimp. You can find out more about how they process personal data here:
4. DATA SHARING
Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Chucklefish, our customers or others.
Digital Content Stores: The Games are made available to download via Steam and we may disclose your personal information to Steam for the purposes of making the Game available and facilitating any in-Game payments made through Steam.
Analytics: On occasion we may also disclose your personal information for the purpose of improving and optimising our Online Services to deliver a better experience for our users.
Social media: We may disclose your personal information to social media platforms, including without limitation Facebook or Twitter, such as where you connect your account for an Online Service with your social media account.
5. AUTOMATED DECISION MAKING
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
Where you have linked your Steam account to any of your social media accounts, you can unlink these at any time by adjusting your settings in Steam.
You can also remove access in your social media settings. If you are using an iOS device, you can opt out of personalised adverts by visiting https://oo.apple.com
We will obtain your consent to collect your information to be used for marketing purposes that require consent. If you prefer that we do not use your data in this way, let us know by writing to email@example.com or by checking boxes on the forms we use to collect your data.
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay and within one month at the latest.
To make a request, please let our Data Protection Officer know via firstname.lastname@example.org
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
You can download a copy of your Game account information by following the instructions in your account settings.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing or delete your personal data if:
Obtain a machine-readable copy of your personal data, which you can use with another service provider
If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems. If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services. If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
8. DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Online Services; any transmission is at your own risk
11. INTERNATIONAL DATA TRANSFERS
12. CALIFORNIA RESIDENTS & CCPA
If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.
Please see above for:
- categories of personal information collected about you in the last 12 months (see paragraph 2);
- categories of sources from which the personal information was collected (see paragraphs 2 and 3);
- purposes for collecting personal information (see paragraph 3);
- categories of third parties with whom we share personal information (see paragraph 3 and 4);
- categories of personal information we have disclosed within the last 12 months (see paragraphs 2 and 4); and
- specific pieces of personal information we hold about you (see paragraphs 2 and 8).
We do not knowingly sell the personal information of minors under 16 years of age, except with affirmative authorisation in the case of those aged between 13 and 16.
You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit proof that they have been authorized by you to act on your behalf and proof of their own identity.
You have the right to:
- request access to your personal information;
- request deletion of your personal information;
- opt-out of the sale of your personal information; and
- not be discriminated against for exercising any of your rights under the California Consumer Privacy Act of 2018 (CCPA).
To make a verifiable consumer request, please contact us by email at email@example.com. We will attempt to verify your request within seven (7) days and may verify your request by asking for proof of identity, such as your device ID and/or user ID.
All questions, comments or enquiries should be directed to Chucklefish at firstname.lastname@example.org. We will endeavour to respond to any query or questions within two business days.
© 2020 Chucklefish Limited. All trade marks are the property of the relevant owners. All rights reserved.
- May 2018: Updated to accommodate GDPR
- Feb 2020: Updated to accommodate CCPA