1.  Intro

Hello and welcome to the VP Games Privacy Policy. Your privacy is important to us and we take our responsibility of protecting your personal data seriously. This policy describes how VIEWPOINT APPLICATION LTD trading as VP Games (“we”, “us” or “our”) and its third-party marketing and advertising partners collect, use, process and share information about you.

This Privacy Policy applies to all of our games played on mobile devices, our website https://vpgames.co.uk and to our marketing and advertising actives on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games, websites, marketing and advertising activities and other services collectively as our/the “Services”.

By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy. We may amend and/or update this Privacy Policy from time to time, so please review it frequently. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.

2.  Personal Data

The information we collect depends on the Services you use and how you use them. We are the data controller for any personal data that you supply to us using our Services.  

2.1  What is Personal Data?

Personal data is any personal information about a person from which that person can be identified. If a person cannot be identified from the information, then it is not personal data (for example data where identity has been removed and has been anonymised).

For more information on what data is considered to be personal data, please visit the website of the Information Commissioner’s Office at www.ico.org.uk.

2.2  What Personal Data Do We Collect?

In the course of using our Services, you may provide us with personal data either directly or indirectly.

A.  Data We Receive Directly

When you download, access and/or play our games or use our other Services, most of the data we collect comes directly from you or your device. We use this data to provide our games and Services to you, including for the purposes of optimisation, preventing fraud, customising in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy, including for marketing and advertising purposes.

The information you provide voluntarily to us, including:

• Information you provide when you request customer support and/or help from us, such as your name, email address, screen username or user IDs, and records of the issues you experience;

• Information you provide when you send us an email or otherwise interact with us, such as your name, email address and any other information you choose to provide;

• Information you provide when you register for our Services as a registered user and create a VP Games Profile, such as your name, email address, screen username and unique VP Games user ID;

• Information provided when you participate in online leaderboard components of our Services, your in-game profile information, gameplay, and statistics may be visible to all;

B.  Data We Receive When You Use Services

When you download, access and/or play our games on your mobile phone or use our other Services including our websites such as https://vpgames.co.uk, and other websites and forums operated by us (“Websites”), we automatically collect certain information from you and/or your device. We may use the information we collect about you for a number of purposes, including for operating and optimising our games and/or Websites, in connection with our advertising purposes, and for research or analysis.

We collect this information with either your explicit consent in accordance with GDPR article 6(1)(a) or as part of our legitimate interest in accordance with GDPR article 6(1)(e)., including:

• Device information: about the device you use to access our Services, including information about the device’s type, software and hardware, other unique device identifiers (such as Device ID and Advertising ID), device token, mobile network information, and time zone;

• Device event information: including crash reports, request and referral URLs and system activity details (e.g. whether you encountered an error playing our games or lost Internet access).

• Browser log Information: about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services;

• Location information: We collect location information in order to comply with legislation and policies that apply to your area. However, neither we nor our partners collect location information more granular than city level without your explicit consent;

• Usage information: details relating to your use of VP Games Services, how you use them and your interaction with other users;

• Consumption information: about your consumption habits relating to your use of our Services, including which purchases you make with both virtual and real currencies;

C. Information Provided to Us by Third Parties

When you download our games through Google Play Services or Apple Game Centre, we may collect information from app stores systems and update one of our applications.

If you play or purchase our games or in-app purchase on your mobile device using real currencies as part of your use of the Services, we receive information about you and your purchase from the app store and other mobile platform providers, in order to facilitate your payment for such purchased virtual goods; purchase history (this does NOT include payment method details or banking information which is collected and processed by a third-party). This information may include:

• Your username;

• Device identification number and the fact that you made a purchase; for instance, but does not include any sensitive or financial information.

• Some of our mobile platforms also may send information to us that you authorize them to provide, through systems such as Google Play Services or Apple Game Centre.

We may also receive or obtain Personal Data from other third-party. For example, if you log into our Services via certain third-party social networking sites (each a “Social Networking Service”) or platform such as Facebook. We may receive and use Personal Data you have provided to such Social Networking Services and made available via your account privacy settings, such as your name, screen name, profile information, profile picture, friend lists, IP address, and other unique IDs and email address.

We may also receive personal information about you from other third-party service providers and advertising partners. We use information from these companies primarily to help us deliver relevant advertising to you. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.

2.3  How Do We Collect Information?

We process and collect some information from you when you provide it to us directly, such as via an online form or when you communicate with our customer support team. We and third-parties also use certain technologies, described below, to deliver positive customer experiences.

A.  Cookies and Similar Technologies

We and other third-parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Services. This information helps us measure the effectiveness of our advertising, make sure you don’t see the same ad repeatedly and otherwise enhance your user experience.

Your Internet web browser enables you to opt out of tracking with cookies. Please visit http://www.allaboutcookies.org the documentation for your individual web browser if you would like to learn more about managing your cookie preferences.

We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our products, troubleshoot technical problems, detect and prevent fraud, and to enforce our Privacy Policy. Our legal basis for this collection and processing is to protect our legitimate business interests and therefore we do not seek consent to collect your information for these purposes.

B.  Analytics Technologies

We use a third-party hosting server and Google Analytics to collect information regarding visitor behaviour and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

VP Games may also collect and store data from your device when you use our Services. This information includes technical and related information about your computer or device and operating system (such as IP address and device ID), information about your feature usage, gameplay and usage statistics and system interactions. If you play a game offline, this data will be stored on your device and may be transmitted to VP Games when your device connects to the Internet. If you participate in online components of our games, such as leaderboards, VP Games may also collect, use, store, transmit, and publicly display statistical data regarding game scores and achievements.

C. Fraud Prevention Technologies

When you use an VP Games Services, we or third-parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security, and authentication purposes. Our legal basis for collecting and processing your information for these purposes, without your consent, is that we consider them vital to protecting our legitimate business interests.

3.  How We Use Your Information  

We user your personal data and non-personal information, both individually and in aggregate, for various purposes, as listed below. Where applicable, if you do not provide us the relevant Personal Data, you may not be able to use our Services completely.

To operate our business and to enhance and personalise your game experience, including to:

• Operate, improve, and develop our games and services;

• Populate online leaderboards;

• Help you find your friends or tell your friends about an VP Games Services;

• Facilitate sharing on social networks;

• Serve and measure the effectiveness of advertising;

• Measure the health of our Services;

• Provide game experiences customised to your preferences;

• Facilitate your gameplay on multiple devices, when available;

• Identify, fix, and troubleshoot bugs and service errors;

• Provide software updates;

• Save game progress and stats;

• Send you technical notices, updates, and push notifications messages;

• Process and deliver contest entries and rewards;

• Adhere to your preferences and to deliver dynamic content; and

• Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behaviour, comply with the law, and to enforce our agreements and policies.

To provide you support, including to:

• Help identify and troubleshoot problems with your account or games;

• To survey your opinions through surveys or questionnaires;

• Communicate with you and respond to your specific requests or questions; and

• Manage and send you confirmations and important information about your products.

To personalise our communications with you, including to:

• Present offers or information relating to games you might like;

• Make recommendations to you; and

• Personalise advertising for you and deliver targeted marketing, service updates and promotional offers.

However, we do not request or intend to collect any “sensitive information” or “special categories of personal data” such as information on race, ethnic background, religion or belief, political opinions, disability, health, and gender reassignment or sexual preferences/orientation. Be cautious when sharing this information about yourselves (or others) in our Services.

4.  International Data Transfers

VP Games operates globally and our Services are global by nature. Your Personal Data and information collected via and/or by VP Games may be stored anywhere in the world and may be transferred to — and maintained on or processed in — computers located outside countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.

When we transfer your personal information internationally, VP Games takes steps to ensure that adequate safeguards are in place to protect your personal information and it is treated securely, lawfully and in accordance with this Privacy Policy.

5.  Data Retention

We store and retain your Personal Data information collected as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collect, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

6.  Data Protection and Security

VP Games is concerned with safeguarding your Personal Data, and we take steps to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. We have put in place reasonable controls designed to help safeguard the personal information we collect via our products.

However, unfortunately the Internet cannot be guaranteed to be 100% secure and no security measures are perfect and therefore we cannot assure you that personal information that we collect will never be accessed or used in an unauthorised way. And as such, to the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

7.  Data Sharing and Disclosure

At VP Games, we do not sell your Personal Data to third-parties nor have we sold Personal Data in the past 12 months. Nevertheless, in order to provide a more relevant advertising experience, we may allow third-party advertising partners to set Technologies and other tracking tools on our Services that collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day).

We may also combine and share such information and other information (such as demographic information and past purchase history) with our third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for the purposes of delivering targeted advertisements to you in our games, or when you visit third-party websites or applications that use their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your Personal Data with third-party advertising partners, you may follow the instructions above in the section “Cookies and Interest- Based Advertising.”

Additionally, as part of our business, we disclose your Personal Data with the categories of recipients below.

7.1  Other VP Games Registered Users

If you register for the Services and submit your Personal Data to create a profile in our games, other registered users will see your username (“Subscriber Identifier”). Providing Other Subscriber Information is voluntary and should correlate with the degree of interaction you want to have with other VP Games users. Since your username is public, we recommend that you do not use your real name as your Subscriber Identifier since that may allow others to identify you in the real world.

7.2  Service Providers

We may share any Personal Data we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for the provision of the Services, the provision of information, products, and other services you have requested, marketing and advertising, analytics, customer service activities, and the provision IT and related services.

7.3  Disclosures to Protect Us or Others

We may access, preserve, and disclose your Personal Data, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; respond to your requests; protect your, our or others’ rights, property, or safety; to enforce our policies or contracts; to collect amounts owed to us; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or if we, in good faith, believe that disclosure is otherwise necessary or advisable

7.4  Business Transfers

VP Games may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, receivership, reorganisation, purchase or sale of assets, transition of service to another provider or in the event of bankruptcy.

8.  Age Guideline and Children’s Privacy

Protecting children’s privacy online is extremely important to us. Generally, VP Games Services are not directed to children under 13 (or other age as required by local law), and the Services do not knowingly collect or solicit Personal Data from children, or knowingly allow such persons to use our Services.

We also encourage parents and/or guardians to play an active role in their children’s online experiences at all times. If you are a parent or guardian and believe that we might have any information from or about a child under the age of 13 (or other age as required by local law), have any concerns regarding the service, wish to review information collected from your child, or have that information modified or deleted, you may contact us at privacy@vpgames.co.uk.

If we become aware that a child has provided us with Personal Data, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.

9.  Your Rights

As a VP Games user, you have the rights listed in this section in accordance with applicable laws. If you want to exercise any of your rights or receive further explanation about them, please contact us via the contact details at the bottom of this Privacy Policy. We will action your request as soon as we reasonably can. However, we may not be able to continue to provide the nominated VP Games or other Service to you. Please note that some of these rights may be connected to certain statutory preconditions and thus, might not be applicable to you and your specific situation.

9.1  Data Protection Act 2018

Under the Data Protection Act 2018 and UK law you are entitled to:

1. Access, update or amend the information that we hold about you;

2. Object to the processing of your information by VP Games and our Services, including for marketing purposes or otherwise where you have a legitimate reason for doing so;

3. Ask for a copy of any of your personal data in a machine-readable form (such as .CSV) so you can use it elsewhere; and/or

4. Ask us to delete your information. Please note that we may need to retain some information about you in order to satisfy our legal or security obligations or legitimate internal requirements.

9.2  Withdrawal of Consent

You may, at any time, withdraw any consent you have given, and we will no longer process your personal information, unless we can continue the processing based on another purpose. If you wish to withdraw your consent, you can so by contacting us via the contact details at the bottom of this Privacy Policy.

10.  Contact Us

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, please contact us by sending us an email to privacy@vpgames.co.uk

If you require further information on privacy and data protection generally, please visit the ICO website which oversees data protection compliance in the United Kingdom: https://ico.org.uk/