Ben Olding Games, a United Kingdom limited company, with registered offices at [X] (“Ben Olding Games”) respects your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you may understand the ways in which we do and do not use the information you transmit when accessing and playing Ben Olding Games’ Games, accessing and using websites, platforms, software services and related services (hereinafter the “Game”). Please note that your access and/or playing of the Game constitutes your acceptance of this Privacy Policy as well as our Terms of Use.
“Personal Data” shall mean any information relating to a Data subject; an identifiable person is one who can be defined, directly or indirectly, notably by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Contact data and Service Data are Personal Data.
“Contact Data” means any names, phone numbers, e-mail addresses and certain financial details held within commercial systems to conduct the Parties’ relationship management and billing transactions between the Parties;
“Service Data” means any Party’s Personal Data (that is not Contact Data) held within the Parties’ systems, applications or databases and that may be accessed, processed, used or stored as a consequence of performing the services under the Agreement.
Information collected through the Game
Where applicable, access and playing of certain basic Game versions, experience of certain basic content and games features may not require registering of an account with applicable platform/service providers that are providing the Game etc. to you. However, in order to access and play the complete Game, access certain premium game functions, levels, content and features you must register an account with the platform/service providers that are providing the Game etc. to you. You must then create an account with the platform/service providers’ platforms that hosts the Game to access such premium game functions, levels, content and features etc. To create an account you are required to provide certain mandatory information such as your name, your email address, account login etc. which is mandatory in order to be able to establish an account. Ben Olding Games and/or the platform/service providers (i.e. Apple App Store, Google Play, PlayStation (PSVR), Xbox etc.) collects financial information on the terms and conditions set out in this Privacy Policy and/or the platform/service providers’ own Privacy Policies, which can be found on the respective platforms. Ben Olding Games does not use financial information for any purpose other than processing payments. Further you may, but may not be required to, provide certain voluntary information such as date of birth, screen name, your personal profile in the Game, interests in and use of various games, products and services, and any other personal or preference information.
Ben Olding Games may also collect and process other information when you interact with the Game online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifier such as a device identifier of any of your computer(s) or device(s) that are used to access the Game. Such information will be collected and processed irrespective of whether you only access the Game or if you actually play the Game. Ben Olding Games may also collect and process certain information when you as a user with a user account interact with the Game such as the information in your personal profile, the relationships you form in the Game, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit information through various channels.
Information collected through other sources
Ben Olding Games may invite you to share your email address with us for sales and marketing purposes. You may be invited to do this in the Game, related websites etc. as well as third party ad networks. By opting in to receive these emails on our website or from our ad partners, you are giving your consent to receive these types of sales and marketing emails, as well as us storing Personal Data related to such emails and related material in accordance with the terms and conditions of this agreement.
If you choose to use any invitation service to tell a friend about the Game, Ben Olding Games will ask you to provide Personal Data needed to send the invitation, such as your friend’s email address etc. Ben Olding Games will send your friend a one-time email or instant message inviting him or her to visit the Game. Ben Olding Games stores this Personal Data to send this one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact Ben Olding Games at contact@clique.games to request that Ben Olding Games remove this Personal Data from its database.
Ben Olding Games may also collect information about you from other sources, such as third party sites or platforms, newspapers, blogs, instant messaging services, and other End Users of the Game through the operation of the Game in order to provide you with more useful information and a more personalized experience.
3. Cookies and logs etc.
Cookies. A cookie is information a website, app or platforms places on your computer’s hard drive or devices etc. so that the website, app or platform is able to remember your preferences and/or which pages you visited on the website/app/platform and make your visit more efficient and enjoyable. Ben Olding Games may use cookies to determine the number of unique players of the Game over a given period, or to remember user account details, etc. so that the need for multiple log-ins is eliminated. It may combine information collected through cookies to any Personal Data submitted online when using the Game to help personalize a user’s access to and playing of the Game. Cookies may be disabled on your computer by indicating this in the preferences or options menus in your browser.
Logfiles. Log files are files that log actions that have occurred on a website, app or platform. Ben Olding Games may collect data in the form of log files and may use such log files to gather statistics about End Users user habits and to assess overall Game activity, including how many “hits”; a particular web page etc. is getting and other navigational data. These entries are generated anonymously, and enable Ben Olding Games and/or platforms to track interest in specific promotions, features, troubleshoot technical concerns, and provide End Users with content that may be of interest to them. Log files are used internally only, and are not associated with any particular user, computer, or browser.
Web beacons. The Game may use a variety of technical methods for tracking purposes, including “Web beacons” etc. Web beacons are small pieces of data that are embedded in images on the pages of the Game. We may also use these technical methods to analyse the traffic patterns in the Game such as the frequency with which End Users accesses various parts of the Game etc. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. The information from use of these technical methods may be collected in a form that is personally identifiable.
4. Use of information – Purpose and legal basis
Ben Olding Games will use information about you for the following purposes in accordance with applicable laws:
Age identification
To identify your age for data protection purposes, for example to determine the legal requirements for processing of Personal Data. We request that anyone under the age of 18 not send any Personal Data about themselves over the Internet unless sent under the supervision of their parent or guardian. We do not knowingly collect Personal Data from children under 13 years old in the Game. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or played the Game and provided personally identifiable information to us, please contact us at contact@clique.games or the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information.
Information you provide or is collected from you in or in relation to the Game and information from other sources
Information is provided by you or collected in or in relation to the Game and/or collected from other sources in order to:
Processing of this information is necessary for the purpose of performance of a contract to which you are a party, in order to support the operation of the Game, facilitate the delivery of requested products and services, enable maintenance and update of the Game. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
With respect to processing of Personal Data Ben Olding Games is Data Controller. Ben Olding Games shall (i) Not keep the Personal Data for longer than is necessary for the purposes of performing the Agreement unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules; (ii) Store, process and use the Personal Data for the sole purpose of performing the Agreement; and (iii) Ensure that their employees and employees of their affiliates and subcontractors involved in the performance of the Agreement comply with the provisions of this agreement (iv) Implement all reasonable technical and organizational measures to protect your Personal Data against any accidental or unlawful destruction, accidental loss, unauthorized alteration, communication or access, (v) Where applicable report to you, upon its occurrence, any unauthorized access, disclosure, use, modification or destruction of your Personal Data, (vi) Refrain from exporting or transferring your Personal Data to any country outside of the USA, and from collecting, using or Processing Personal Data within any country outside of the USA, unless prior to the transfer we have ensured that an adequate level of protection of the Personal Data has been implemented. Personal Data is deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with us has ended.
As a general rule we will not share Personal Data that directly identifies you (such as your name, e-mail or postal address etc.) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
Notwithstanding the forgoing, we may share information about you with certain third parties based on the legal basis as follows:
Third Party Agents and Contractors
We may share information about you with third party agents and contractors in order to provide the Game to you, for ongoing development, for analytical purposes etc. We will only provide information to such third party agents and contractors for their performances of their specific assignments for us and consistent with this Privacy Policy, and for no other purposes and provided that such third party agents and contractors have ensured an adequate level of protection of the Personal Data in accordance with agreements with us.
Social networks
Where the Game and related services are accessed and/or provided through social networks.
Third parties
When required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity.
Courts, law enforcement agencies, legal authorities etc.
When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of Ben Olding Games, the Game, end users etc.
Other end users
In order to provide certain Game features.
Advertising networks
For advertising purposes. We may share your advertising ID with advertising partners in order to serve behavioural advertisements to you within the Game if you have given consent.
Where applicable certain third parties’ use of Personal Data will not be covered by this Privacy Policy. In such instances you must review such third parties’ privacy policies.
In order to access the complete Game, certain premium game functions, levels, content and features etc. you are required to pay certain fees. When purchasing such features and functions etc. you may be asked by the platform/service providers to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 18 or older to make purchases in the Game, however children over thirteen but under eighteen may access and play the game under the supervision of a legal guardian.
Once End Users have successfully entered valid credit card information etc. and completed the order process, a purchasing account will be created and maintained for them. The platform/service providers will use the information provided to process the End User’s order and to send order confirmations via email, as well as to make future purchases easier for the End User. Ben Olding Games does not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with its third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate Ben Olding Games’ business (e.g. processing orders and payments).
Ben Olding Games has taken reasonable steps to ensure that the personally identifiable information it collects is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the Personal Data collected from our Game’s End Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with the Game, that we store on our systems or that is stored on our service providers' systems.
Please note that Ben Olding Games may provide links to other games and websites that are operated and hosted by third parties who may have their own information collection practices. Those other games and websites are governed by their own privacy policies, which may be substantially different from Ben Olding Games’ policies. Visitors to other games and websites are encouraged to review the privacy policies and information collection practices of those websites.