PRIVACY AND DATA POLICY

ISSUED BY XISLE GAMES LIMITED

Last updated: 23 April 2019.

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of our website (http://ancientsreborn.com/), games and other products and services developed and/or published by Xisle Games Limited. (“Xisle Games” / “we” / “us”) and as further detailed below. Our registered office is at Log Cabin 10b, Dunston Business Village, Stafford, United Kingdom, ST18 9AB. We are a company registered in England and Wales, with company number 11720389.

 

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of our game ‘Ancients Reborn’, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game”), as well as any other online features relating to the Game, our website (including, without limitation, http://ancientsreborn.com/) (together, the “Website”) and our online communities / forums (“Communities”), except where an alternative policy is made available by us. Together, the Game, Website and Communities are referred to herein as the “Online Services”.

Our Online Services are not marketed to users under the age of 13 and those aged under-13 should not use our Online Services.

We do not use our Online Services to knowingly solicit information from, or market to, those under the age of 13.

If you have any questions or comments about this Privacy Policy, or if you would like to exercise your right to object to our processing of your personal data, please contact us at support@xislegames.com.

 

We are committed to protecting and respecting your privacy.  This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purposes and means for which personal data you supply through these Online Services is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018.

Please read this Privacy Policy carefully as it contains important information about the following:

This Privacy Policy should be read in conjunction with our terms of use as may be applicable in respect of the relevant Online Services. Where terms of use are applicable, they will be made available via the relevant Online Services.

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 data 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.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Online Services.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following personal data from you when you use our Online Services (together, the “Online Service Information”):

Information collected when you are using a Game or Community

(“Game Information”)

o   Your mobile device’s unique device ID (e.g. for our Game);

o   Your user/account avatar;

o   Your user/account profile picture;

o   Your user/account username;

o   Your user/account ID; and

o   ‘Events’ related to your gameplay in our Game, such as your achievement of a milestone, the occurrence of other particular events during your gameplay (such as completing a tutorial, game level or making a purchase).

Information provided by you when using the Communities or that may be provided by you when you contact us for support

(“Contact Information”)

o   Your name;

o   Your profile identifier / display name / username or your username / identifier on another platform or account;

o   Your address, telephone number and/or email address; and

o   Your password (e.g. for Communities and otherwise where applicable).

User-generated content and score information hosted and displayed in our Online Services

(“User Content”)

When using our Online Services, you may decide to post information that may or may not contain personal data, in accordance with the rules of the relevant Online Services (such as the relevant forum rules applicable to our Communities). Similarly, when using our Game or other Online Services (where this functionality is provided by us) you may decide to post certain content such as leaderboard information and messages to other users, in accordance with the terms of use applicable for the relevant Online Services.

 

In some Online Services, the provision of User Content (e.g. leaderboard / ‘scoring’ information between users and/or in a public manner within the Online Services or similar) (“Leaderboards”) is a significant or essential part of the functionality and/or gameplay or user experience and may be posted automatically. We may, but we are not required to, provide you with a means to still play / use the Online Services without taking part in this functionality (e.g. without having your information on the leaderboard) within the Online Services. You can also contact us to enquire further about User Content at support@xislegames.com. Please be aware that it may not be possible for us to turn off this type of User Content functionality for you within the Online Services without affecting your user experience.

 

We cannot control the wider dissemination via the public internet of personal data that you may choose to post, or make available, in User Content.

 

Information about your activities

(“Analytics”)

We may collect technical information about your use of our Website or Communities through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

o   Your IP address and MAC address;

o   Device information (e.g. device identifier and browser)

o   Game results, progress and timings; and

o   Page usage (e.g. buttons clicked, screens viewed).

This also includes the use of ‘cookies’ and similar technologies such as SDKs and APIs in our Game.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies and similar technologies are widely used in order to make websites and mobile apps work, or work more efficiently, as well as to provide information to the owners/operators. The Game uses cookies to help Xisle Games identify and track visitors, their usage of the Website, and their Website access preferences.

The following cookies and similar technologies are used on the Website and in our Game:

Cookie or SDK Name / Title

Description

Link (for more information and/or to control your ad preferences)

Google Analytics (Websites)

Google Analytics is a service offered by Google that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sale.

https://safety.google/privacy/privacy-controls/

Google Play Games API (Games)

We use the Google Play Games API to enable you to log into / access your Google account in order to connect / interact your Google account with our Game.

https://safety.google/privacy/privacy-controls/

Google Firebase Analytics (Games)

Google Firebase Analytics is a service offered by Google that generates detailed statistics and analytics information about, for example, app usage.

https://safety.google/privacy/privacy-controls/

Unity Analytics (Games)

Unity Analytics is a service offered by Unity that generates detailed statistics and analytics information about, for example, app usage.

https://unity3d.com/legal/privacy-policy

https://unity3d.com/legal/gdpr 

 

Most web browsers allow some control of most non-essential 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 / Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Information about you collected from third parties

(“Third Party Account  Information”)

If you choose to access or log into our Online Services via a third party social media platform such as (without limitation) Google, we may collect and store personal data and other information made available by that third party platform, such as your profile username, profile picture, user ID and public information about your friends, provided that you have expressly agreed to the use of such information within the relevant Online Service.

We may also collect technical information in order to ensure that our Online Services connect correctly with your third party user account. This information may be obtained via a cookie, SDK, API or other similar device in our Online Services. The third party platform is responsible for obtaining your consent before sharing such data with us.

 

3.  WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Online Services to you

We will use information about you (including the Game Information, Contact Information, User Content (where applicable) and Third Party Account Information) to deliver our Online Services to you under the terms of use agreed between us. The processing of information in this way is necessary, for example, for us to record your progress and current status within the Online Services such as the Game, and to ensure the Online Services deliver the features promised and function properly.

Where we process your personal data for Leaderboards in our Online Services, we also rely upon our legitimate interests as a legal basis for undertaking that processing, being our commercial interests in providing an enhanced experience in our Online Services (though, depending on the nature of our particular Online Services, the Leaderboard may be a part of the core functionality of the Online Services).

To enable purchases

If you make purchases through the Online Services, your order and Game Information may be processed so that you can access these features within the Online Services.

For the above purposes, we rely upon the legal basis of performance of a contract (being performance of the terms of use agreed between us).

Moderation and Preventing Spam

Certain Game Information and User Content which you supply through our Online Services may be shared with other users of the Online Services. 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 Game Information and User Content 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. We may moderate content, but we are not required to do so. Please see our relevant terms of use with you for the relevant Online Services for more information about content moderation.

Spam is a problem for many forums and websites. In order to minimise this we may use Stop Forum Spam to check that any new registration is not spam. In order to do this certain information may be 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.

For the above purposes, we rely upon the legal basis of performance of a contract (being our terms of use with you for the relevant Online Services) and our legitimate interests, being our commercial interests to moderate the services and to prevent spam.

To respond to your enquiries and requests for support

We may process Online Service Information so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us.

As part of this we may also share this Online Service Information with our vendors who may assist us with managing support queries.

For the above purposes, we rely upon the legal basis of performance of a contract (being our terms of use with you for the relevant Online Services) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.

To prevent fraudulent or illegal activity

We may process your Online Service Information for our legitimate interests of ensuring that your use of our Online Services is lawful and in compliance with our agreement (being the terms of use agreed between us), to prevent disruption to our Online Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.

To help us to improve the Online Services and help us fix any problems

We may process information about you (being the Online Service Information or any part thereof) so that we can analyse and improve our Online Services and also for us to develop new Online Services or new parts thereof.

This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Game and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Online Services.

To help us to understand your usage of the Online Services

We may process information (being the Online Service Information or any part thereof) to understand how users use our Online Services, and to compile statistical reports regarding that activity, as well as understanding how users progress within particular Online Services such as the Game. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems (such as when users may frequently be ‘stuck’ in a particular Game level) and to improve our future products and services.

To keep you up to date

 

Where you have consented or where it is otherwise lawful to do so, we may use your Online Service Information to send you emails in order to keep you informed of news and products.

Push notifications about our Game and similar notifications

 

Where you have consented or where it is otherwise lawful to do so, we may use your Online Service Information to send you ‘push notifications’ or in-service notifications (for example, on your device and in relation to the Game). The third party platform (i.e. your device provider such as Apple) is responsible for obtaining your consent to activities such as push notifications.

 

 

4.  DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, transfer 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: 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 data to third parties (e.g. mobile network operators, gaming platform operators, game console manufacturers or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Xisle Games, our customers or others.

Digital Content Stores:  Where our Game is downloaded through a third party store service such as (without limitation) Amazon, Google Play or Apple's App Store, we may disclose your personal data to the relevant store/platform for the purposes of facilitating any in-Game payments made through these platforms.

Objectionable Content: If you send us or upload objectionable content, or behave in a disruptive manner when using our Online Services, we may process any personal information that you have submitted to us, to respond to and stop such behaviour.  Where we reasonably believe that you are or may be in breach of the law (for example, where the content you share amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties about the content, such as your email or internet provider or law enforcement agencies.

 

5.  AUTOMATED DECISION MAKING

We may use automated decision-making methods which do not involve human involvement to process your information, and shall do so only in the ways that are described in this Privacy Policy.

 

6.  CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to be part of a lookalike campaign or receive notifications from us you can opt-out by changing your notification settings on your device directly. 

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 support@xislegames.com or on the relevant forms or check-boxes that we may use to collect your data.

7.  YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

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 with requests without undue delay and within one month at the latest.

Ask for a copy of personal data we are processing about you and have inaccuracies corrected or request erasure

You have the right to request a copy of the personal data 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 (where this functionality is made available). Where this functionality is not available you can request a copy by emailing support@xislegames.com.

We will use reasonable efforts, to the extent required by law, to comply with any request to supply, correct or delete personal data held about you on our files (and request that any third parties to whom it has been disclosed to do the same).

Object to us processing personal data about you

You can ask us to restrict, stop processing or delete your personal data if:

  • you consented to our processing the personal data and have withdrawn that consent;
  • we no longer need to process that personal data for the reason it was collected;
  • we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Xisle Games or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed;
  • you need the personal data to be deleted in order to comply with legal obligations; and/or
  • the personal data is processed in relation to the offer of a service to a child.

You may be able to delete your accounts by following the instructions in your account settings, where applicable depending on the relevant Online Services. You can also request account deletion by sending an email to support@xislegames.com.

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 contractual 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 or by email at support@xislegames.com.
  • 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. Contact information for the Information Commissioner’s Office, the UK’s independent authority setup to uphold information rights, is available here: https://ico.org.uk/.

 

8.  DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.

9.  CHILDREN

We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at support@xislegames.com.  

10.  SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Online Services, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us.

Please be aware that, while we make the security of our Online Services and your personal information a high priority, no security system can prevent all security breaches.

Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted through our Online Services; the sharing of your personal information with us and any transmission is at your own risk.

11.  INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of the Online Services, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at support@xislegames.com.

12.  CONTACT INFORMATION

Questions, comments and requests in relation to this Privacy Policy are welcome and should be addressed to support@xislegames.com.