MOBILE Games privacy policy

Updated 16 September 2019

This is the privacy policy for mobile games and applications that we make available from time to time (Applications, Apps). The Applications are operated and provided by Two Way Media Limited (we, us and our). For the purposes of the General Data Protection Regulation 2016 and the Data Protection Act 2018, we are the data controller and this policy sets out our commitment to protecting your privacy by explaining how we use and collect your personal information within our Applications and what controls you have.

Please read our policy or select from the different section headings below to learn more:

1. Personal information we may collect from you and how we use it

2. Data storage and international transfers

3. Information sharing

4. Security and safety

5. Your rights

6. Right of complaint to the Regulator for Data Protection

7. About Two Way Media Ltd

9. Changes to this Policy


1. Personal information we may collect from you and how we use it

Registration as a user

When you interact with our Apps, we do not require you to provide information that identifies you personally.  Instead, we collect and identify your device primarily using your mobile device advertising identifier, e.g. Apple’s iOS Identifier for Advertising (IDFA) or Google’s Android Advertising ID, as well as other identifiers.  

The information you submit

Information we may collect about you:

  • Details of any requests or transactions made by you within our Apps, to contact us or where you subscribe to our email newsletters.

  • Communications you send us directly either via email, letter, fax or phone to report a problem or to submit queries, concerns or comments regarding our Applications or their content.

  • Information from surveys, promotions and competitions we may from time to time run on the Apps, if you choose to respond to or participate in them and Opt In.

  • Details of your visit to the Apps such as how you navigate and use our content, and what links or promotional content you click on.

  • When you submit or click on an email, message or other form of communication from us, within our Apps, including information you post in the form of comments or contributions to discussions.

  • Through the app store, Facebook, Twitter, or any other social media site, or when you install any of our Apps or make a purchase.

Some examples of information

  • Email address used to contact us

  • Links you click on, including within Apps

  • Advertisements you click on

We collect the information that you provide to us, for example when you communicate with others or post, use messenger or chat services, upload or store content, contact our Technical Support team, or provide billing information.

Log Information. We automatically collect information about your use of our Services and your device, including your IP Address, device model, browser version, operating system type, operating system version, mobile network information, device settings, and software data.  

{Location Information.  We derive information about your general location (city, country) from your IP Address.  Game Circus does not collect precise location data, such as GPS coordinates, that could be used to pinpoint your physical location.  

Information from Cookies and Other Technologies. We collect information using web beacons, cookies, and similar technologies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, count visits, and understand how users interact with ads.  Web beacons are electronic images that may be used in our Services and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see âYour Choicesâ below.

Information from Others.  We collect information about you when we receive it from other users, third parties, and affiliates. For example, when you connect your account to third-party services or sign in using a third-party partner (like Google Play Game Services, iOS Game Center or Facebook), we collect information in accordance with the privacy policies and authorization procedures determined by those services.

Device information

How we might collect

  • We may collect certain technical information when you use your device, either smartphone, tablet, PC or Mac, to access or use our Apps.

Some examples of information

  • Device type

  • Operating system and operating version

  • Browser type

  • Mobile network information

  • Territory

  • HTTP header information

  • Your device's unique identifier, which is encrypted (excluding anonymous players)

  • In-app progress, including time, in-app purchases, purchases, game play history, in-game rewards, state of play etc.

This information helps us to provide an effective service through our Applications and to collect statistical information about how our content is used.

Log information and unique visitor numbers

How collected

  • When you use the Apps

  • On install or uninstall of the Apps

Some examples of information:

  • On install of an App, the IP and unique device details are encrypted and assigned an anonymous identifier tag.

  • The identity of your Internet Service Provider (ISP) or mobile network provider.

  • Registration details to the Apps.

  • Date and time the Apps are opened, including session length of play-time within the Apps.

  • Areas of the Apps you visited, including any links or features you used.

  • Browser type, language, click-stream data.

  • In-game registration details, including username and email (encrypted email address).

  • Statistical data about your interaction with our Apps.

Analytical tracking tools/code

The Applications use third party or in-game code/technology to collect information about access or use of any Application.

The in-game code/technology collects or stores pieces of information that may include a unique encrypted reference code that an Application transfers to your device to store and sometimes track information about you, which may be used to track performance of App directly with our server, synched with your account, or third-party analytical tools. Some last only for the duration of your session in an App and expire when you exit; others are used to remember you when you return to the Application and will last for longer.

We use in-game code/technology to:

  • enable you to save your state of play so you can return to a saved game without connection;

  • customise elements of the layout or content of the pages of the Application for you;

  • remember your game session so you can move freely within the Application; and

  • collect statistical information about how you use the Applications so that we can improve the content we provide.

List of analytic tools:

All Apps analytics are provided to us by (1) Google Firebase Analytics and Firebase BigQuery, each offered by Google (1600, Amphitheatre Parkway, Mountain View, CA 94043, USA), and (2) Facebook Analytics (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). Further information on privacy practices can be found at https://policies.google.com/privacy?hl=en, and f https://www.facebook.com/privacy/explanation.

Our Apps contain in-game advertising where the technology and code have been provided by 

Twitter, Inc., successor in interest to MoPub, Inc., and integrated into these Apps for the purpose of allowing the ad servers to run suitable advertisements within the App. For more information about these third parties and their technology, visit https://www.mopub.com/legal/privacy/.

By continuing to use the Application, you consent to our App device identifier settings.

What do we use the information for?

Some examples

  • To enable us to manage and maintain your account with regards to state of play, purchases and updates, including all associated devices linked to your account details.

  • To provide you with the functions and features of the Apps.

  • To enable us to ensure our content works with your devices and operates to the optimum performance of your device.

  • Ability to manage your in-game App rewards and any in-game achievements.

  • Ability to contact you to inform you of updates, or rewards and special offers, or new content and/or features.

  • Ability to fully provide you with all features of the Apps, including support sites, and customer support contact routes.

  • To provide you with the information, products or services that you request from us or which we feel may be of interest to you, where you have consented to be contacted by us for such purposes.

  • Where advertising is supported, to provide advertising that is tailored to your needs where possible.

  • Internal operations to allow troubleshooting, data analysis of App usage, testing, research and service improvements.

  • To report aggregate or match information to any advertisers or third parties associated with the Apps, or the management of the Apps (you cannot be identified from this information).

  • To associate any information you submit and device information, including associated devices linked to each user account, to help us better understand your use of the App and any of our associated Apps.

  • Ability to send you push notifications.

  • Ability to understand your in-game preferences.

  • To match, where relevant, data received from app stores and associated devices to your account.

  • To carry out any obligations arising from any contracts entered into between you or us.

2. Data storage and international transfers

Where your information is stored

All personal information we collect from you is stored on a secure Google Firebase server, which may be processed, transferred and/or stored outside of the European Economic Area (EEA). If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected. 

In addition, if you use our services while you are outside the EEA, your information may be transferred outside the EEA to provide you with those services.

3. Information sharing

Disclosure of your information

Remember that when you purchase or use the App, you may be transferring your personal data to:

  • the app stores;

  • your mobile network provider; and/or

  • any payment-processing provider.

Please note that payments made on our Applications are made through our payment-processing provider/the app store. You will be providing payment information direct to them and to their secure server, encrypting your payment information and authorising payment. Information you supply is not within our control and is subject to their privacy policy and terms and conditions.

We may disclose your personal information to agents or contractors who assist us in providing the service we offer through the Applications. Our agents and contractors will only use your information to the extent necessary to perform their functions as instructed by Two Way Media Ltd.

We do not share your personal information with third party marketers, unless we have asked for and obtained your explicit consent. However, we may share to third parties:

  • Aggregated information that does not identify you.

  • Where Applications carry in-game advertising, advertisers may collect information to help serve adverts to you.

  • To protect our users:

    • where legally entitled or required to do so (for example, if required by law, by a court order or if we believe such action is necessary to prevent fraud or cybercrime or to protect the Applications or the rights, property or personal safety of any person); and

    • in the event we undergo reorganisation or if the brand or business or Apps are sold to another company (any personal information we hold about you may be transferred to that re-organised entity or third party).

Data storage

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

What grounds (legal basis) are we processing the data under?

There are a number of grounds we process your data under. These are:

  • Contractual – to enable the features of an Application.

  • Legitimate interest – this means the processing is in Two Way Media’s interest. It allows us to manage the customer relationship effectively and efficiently and improve the services we provide by better understanding how our Apps are used and which Apps are popular with which groups of individuals.

4. Security and safety

Security

We understand the importance of ensuring all personal information associated with our users is safeguarded and whilst we take steps to ensure the security of your information, there is a risk that any information transmitted over the internet and stored on a computer may be intercepted or accessed by an unauthorised party. If you think that someone has accessed your information held by us without your permission or gained unauthorised access to your login details, you must notify us at customerservices@twowaymedia.co.uk.

Public forums

The Applications may allow chat or provide facilities for you to submit comments. Information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal information.

Child safety

Our Applications are designed for consumers aged 18+. If you are aged 18 or under, please get your parent/guardian's permission before you provide any personal information to Two Way Media Ltd.

Other app stores or sites that are not operated or managed by us, or not ours

App stores, Facebook or websites will have their own privacy policies. We recommend that you read these sites or app store terms. We are not responsible for the privacy policies or the content of such sites.

5. Your rights

Under the data protection law, you have a number of rights with respect to your personal information which are:

Correcting your information 
You are entitled to have your personal information updated to ensure it is up-to-date and accurate. This can be done by following the instructions below.

Withdrawing consent 
You have the right to withdraw your consent to any processing that is currently being done under your consent eg marketing. Consent can be withdrawn for some processing by updating your preferences in your online account. You can also follow the process below.

Obtaining a copy of your information 
You are entitled to receive a copy of the personal information we hold about you.

Deleting your information 
You can request that we delete personal information in certain circumstances. These will be specific to each case.

Data portability 
You are entitled to have us transfer to another controller the personal information that you have provided us with.

Restricting processing 
You can request a restriction on the processing of your data in some limited circumstances. Examples are concerns over data accuracy or we no longer require to hold your data but you have requested its retention by us to aid you in a legal matter.

Right to object to processing 
You are entitled to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc (also known as profiling).

You can action any of these rights by contacting our Customer Services department or by contacting us by email at customerservices@twowaymedia.co.uk or by post to Information Security Manager, Two Way Media Ltd, Somerset House, Strand, London WC2R 1LA.

6. Right of complaint to the Regulator for Data Protection

The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this via:

  • The ICO’s website (https://ico.org.uk/concerns): follow the links or have an online Live Chat.

  • Call the ICO helpline on 0303 123 1113.

  • Email casework@ico.org.uk.

  • Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

7. About Two Way Media Ltd

Two Way Media Ltd is the data controller for the purposes of the General Data Protection Regulation 2016 and the Data Protection Act 2018. If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us using customerservices@twowaymedia.co.uk or by post to Information Security Manager, Two Way Media Ltd, Somerset House, Strand, London WC2R 1LA.

8. Changes to this Policy

We may change our Privacy Policy from time to time, so please check back regularly. We will try to notify you in advance where there are any significant or very important changes.