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.
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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”):
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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). |
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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). |
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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. |
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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:
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. |
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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
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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). |
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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. |
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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. |
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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. |
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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. |
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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. |
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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. |
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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
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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
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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.
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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). |
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Object to us processing personal
data about you You can ask us to restrict, stop
processing or delete your personal data if:
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. |
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Obtain a machine-readable copy
of your personal data, which you can use with another service provider
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Make a complaint to a
Supervisory Authority
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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.