Last updated: 16th July 2019
1. Personal information we may collect from you and how we use it
Registration as a user
The options and what this means:
We offer three registration options as follows:
i. Anonymous registrations
This allows you to register as a user with a simple in-game username. No other information is retained by us, and if the App is uninstalled, or username forgotten, then it is possible that all associated purchases, features, rewards, state of play etc, associated with the original anonymous account could be lost. In addition, anonymous registration means that you are unable to link any devices to an anonymous account, that we are unable to contact you with information about our promotions, special rewards, enhancements, and also that you cannot connect to friends, or post achievements.
This allows you to manage your account, and sync all state of progress across multiple associated devices, that you authorise us to link your account details (eg email and username) with through a single account, including all additional content and/or hint coin purchases and achievements. You can also connect with friends, via email, so long as they have also installed the App, which if accepted by your friend, will add their name to your in-game friend list where you can view their state of play, rank badge and leaderboard positions. We will contact you via email to advise of any special in-game rewards, trophies/achievements or suspicious account activity. All email addresses are encrypted on our server, and if you have more than one App, with each registered via the same email address, these will all be directly linked by the email address you have registered with.
iii. Facebook Connect
This allows you to register via your Facebook account, which will sync your App with your Facebook profile, email and Facebook avatar (avatar name can be changed within the App when loaded or within game settings), and link App data with that of your associated Facebook account. This will allow limited access to your Facebook profile so that we can automatically add, and you can manage your Facebook friend list within the game. This allows you to instantly connect and engage with friends and post and share your achievements with your personal Facebook page, plus invite friends to compete against you within game. Your App game data is then managed against this account email and username profile for each App game you have registered using Facebook Connect. We will contact you via email, to advise of any special in-game rewards, trophies/achievements, or suspicious account activity.
Please note that you can upgrade your registration route at any time within game settings, or by contacting us via email@example.com. You can also contact us at any time via the in-game email option to reset any registered account to an anonymous player, whereby all encrypted email and username profiles will be deleted from our server.
The information you submit
Information we may collect about you:
An in-game username or a username and encrypted email when you register as a user of Applications.
In connection with your user account sign-in facility, your login and password details.
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.
When you connect with our App using your Facebook account, you will be advised that our App would like to access your basic profile information and list of friends, and you can confirm "Don't Allow" or "Allow". Selection of "Allow" means you agree that we can access your basic public profile and friend list, including username, email (email shall be encrypted) and avatar, and we will then link your App to this account for the purpose of managing and protecting your game status, rewards, content and trophies etc.
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 log into the App, which shall be encrypted on our server
Email address used to contact us
Public profile and friend list (when connecting to the App using Facebook login)
Links you click on, including within Apps
Advertisements you click on
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
Operating system and operating version
Mobile network information
Your device's unique identifier, which is encrypted (excluding anonymous players)
In-game registration details, including username and email (emails are encrypted)
Friends list if connected to Apps via Facebook Connect
In-app progress, including time, friend invites, leaderboard, 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
When you use 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.
When your device talks to our server to synchronise your account, purchases, state of play, or talks to our system to tell us about your installation and the service you receive.
Analytical tracking tools/code
The Applications may 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 Flurry and Facebook Connect: for more information about their tracking technology, visit https://dev.flurry.com/secure/optOut.do and https://www.facebook.com/.
Our Apps contain in-game advertising where the technology and code have been provided by Hoopla Digital 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.hoopladigital.co.uk/.
By continuing to use the Application, you consent to our App device identifier settings.
What do we use the information for?
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.
To allow you to participate and use the Apps across your associated devices.
Ability to manage your in-game App rewards, leaderboard scores, rank badges and any in-game achievements, including trophy rewards.
Ability to connect via Facebook Connect, allowing you to invite friends and connect with Facebook friends within Apps, review friends' achievements and performance.
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.
We will not share your data or information with any third parties, except that of Puzzler Media Ltd, who may contact you directly with other related offers.
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.
Ability to verify your account and/or registration details, including authentication of your email when registering to use the Apps.
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. Your personal information and marketing
Account and associated email
If you do not want to receive marketing communications from us to your account email address, please simply unsubscribe at the base of the email, or contact us via firstname.lastname@example.org.
Please note that we will still need to process your personal information for you to use the features of the App. If you want to change your login details for our Apps to an Anonymous Player, then you can make this request in-game, or by contacting us so that we can change your preferences and ensure that any previous account information such as email, profiles, username and device information is deleted from our game server. Moving to an Anonymous Player account will not affect your general game status and content purchases, but will result in the loss of certain features and preferences.
3. Data storage and international transfers
Where your information is stored
All personal information we collect from you is stored on a secure Amazon Web Server, with emails and unique device information being encrypted, 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.
We use Amazon Web Services EC2 servers, which fall under EU West Ireland, with S3 for backups. Our Amazon Web Server (AWS) is protected by the AWS Standard Shield which includes active monitoring services.
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.
4. 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.
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. These adverts are operated by Hoopla. Adverts can be switched off by purchasing additional content within the Puzzler App.
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).
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, where a player has logged in via an email address or Facebook.
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.
5. Security and safety
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 email@example.com.
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.
Our Applications are created 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.
6. 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.
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.
You are entitled to have us transfer to another controller the personal information that you have provided us with.
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 firstname.lastname@example.org or by post to Information Security Manager, Two Way Media Ltd, Somerset House, Strand, London WC2R 1LA.
7. 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.
Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
8. 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 email@example.com or by post to Information Security Manager, Two Way Media Ltd, Somerset House, Strand, London WC2R 1LA.
9. Changes to this Policy