What does this
Privacy Policy Cover?
We respects your privacy and
is committed to protecting your Personal Data. We want to be transparent with
you about how we collect and use your Personal Data in making available our
games, (“Site”) and tell you about your privacy rights and how the law protects
you.
With that in mind, this
Privacy Policy is designed to describe:
Contents
This Privacy Policy aims to
give you information on how PLUSDOT collects and processes your Personal Data
through your use of this Site, including any data you may provide through this
Site.
The Privacy Policy is intended
to meet our duties of Transparency under the “General Data Protection
Regulation” or “GDPR”.
We will post any modifications
or changes to this Privacy Policy on this page.
Who we are and
how to contact us.
Who we are.
We are the Controller (for the
purposes of the GDPR) of your Personal Data (referred to as either “PLUSDOT”,
“we”, “us” or “our” in this Privacy Policy).
How to contact
us.
You can contact us by
emailing: barcircle@hotmail.com
Our EU Representative.
As PLUSDOT does not have an
establishment in the European Union, we have appointed a representative based
in England, who you may address to raise any issues or queries you may have
relating to our processing of your Personal Data and/or this Privacy Policy
more generally.
Our EU representative can be
contacted directly by emailing them at the following address: redbag@hotmail.com
Your rights
relating to your Personal Data.
Under certain circumstances,
by law you have the right to:
How to exercise your rights.
If you
want to exercise any of the rights described above, please contact us using the
contact details shown here.
Typically,
you will not have to pay a fee to access your Personal Data (or to exercise any
of the other rights). However, except in relation to Consent Withdrawal, we may
charge a reasonable fee if your request is clearly unfounded, repetitive or excessive,
or, we may refuse to comply with your request in these circumstances.
We may
need to request specific information from you to help us confirm your identity
and ensure your right to access your Personal Data (or to exercise any of your
other rights). This is a security measure to ensure that Personal Data is not
disclosed to any person who has no right to receive it. We may also contact you
to ask you for further information in relation to your request to speed up our
response.
We try
to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you have
made a number of requests. In this case, we will notify you and keep you
updated.
Complaints
If you would like to make a
complaint regarding this Privacy Policy or our practices in relation to your
Personal Data, please contact us at: redbag@hotmail.com.
We will reply to your
complaint as soon as we can.
If you feel that your
complaint has not been adequately resolved, please
note that the GDPR gives you the right to contact your local data protection
supervisory authority. You can find your data protection regulator here.
What Personal
Data we collect.
All the Personal Data we
collect, both from you and from third parties about you, is outlined in the
table below.
Before you read that table, it
might be useful to explain what “Personal Data” is. The GDPR definition of
Personal Data can be found here . Essentially,
it boils down to: information about an individual, from which that
individual is either directly identified or can be identified.
It does not include ‘anonymous
data’ (i.e., information where the identity of individual has been permanently
removed).
However, it does include
‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone
doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a
particular person).
Category of Personal Data Collected |
Definition |
Identity Data |
Depending on the game you
download, this may include your first name, surname, last name, username,
Game Centre ID, social network ID such as Google+ (if you sign up that way),
or similar identifier, title, age and gender. |
Contact Data |
Your email address and
telephone numbers. |
Transaction Data |
Any details about payments
to and from you and other details of subscriptions and services you have
purchased from us (including in-game purchases). Data in respect of your
transactions with third parties, including payments [in relation to the
PLUSDOT games] made through the app store. This does not include your bank
account or payment card details. |
Behavioural Data |
Inferred or assumed
information relating to your behaviour and
interests, based on your online (including in-game) activity. This is most
often collated and grouped into “segments”. |
Technical Data |
Internet protocol (IP)
address, your login data , app ID and version ,
browser type and version, timestamp, time zone |
setting and location,
browser plug-in types and versions, operating system and platform and other
technology on the devices you use to access this website or use our services.
|
|
User Content Data |
Any Personal Data that you
post on our Site in user-generated information and content, including in
text, photos, videos, private chats, and feedback. |
Aggregated Data
We also collect, use and share
“Aggregated Data ” such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your Personal Data,
but once in aggregated form it will not constitute considered Personal Data for
the purposes of the GDPR as this data does not directly or indirectly reveal
your identity. For example, we may aggregate your Behavioural
Data and Technical Data to calculate the percentage of users accessing a
specific Site feature. However, if we combine or connect Aggregated Data with
your Personal Data so that it can directly or indirectly identify you, we treat
the combined data as Personal Data which will be used in accordance with this
Privacy Policy.
No Special
Categories of Personal Data
We do not collect any “Special
Categories of Personal Data ” about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
How we use your
Personal Data and why.
We will only use your Personal
Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose.
If we need to use your
Personal Data for an unrelated purpose, we will update this Privacy Policy and
we will explain the legal basis which allows us to do so.
What is our
“legal basis” for processing your Personal Data?
In respect of each of the
purposes for which we use your Personal Data, the GDPR requires us to ensure
that we have a “legal basis” for that use. Most commonly, we will rely on one
of the following legal bases:
question
(“ Consent ”).
Generally we do not rely on your Consent as a legal basis for using your
Personal Data.
We have set out below, in a
table format, the legal bases we rely on in respect of the relevant Purposes
for which we use your Personal Data.
Purpose |
Category(ies) of Personal
Data involved |
Why do we do this |
Our legal basis for this use of data |
To register you as a new
customer. |
Contractual Necessity. |
||
Account Creation |
Identity Data Contact Data |
||
Game Operations |
Identity Data Contact Data |
To allow you |
Legitimate Interests. We have a legitimate
interest in improving, and ensuring the proper operation of, our services,
Sites and associated IT services and networks. |
To process and deliver your
orders including manage in-game purchases. |
Contractual Necessity. |
||
In- |
Identity DataContact
DataTransaction Data |
||
Fraud Prevention |
Identity Data Contact Data
Technical Data |
To keep our website, our
services and associated systems operational and secure. |
Legitimate Interests. We have a legitimate
interest in ensuring the ongoing security and proper operation of our
services, website and associated IT services and networks. |
To track issues that might
be occurring on our systems. |
Legitimate Interests. It is in our legitimate
interests that we are able to monitor and ensure the proper operation of our
Sites and associated systems and services. |
||
Troubleshoo ting |
Technical Data |
||
What happens
when you do not provide necessary Personal Data?
Where we need to process your
Personal Data either to comply with law, or to perform the terms of a contract
we have with you and you fail to provide that data when requested, we may not
be able to perform the contract we have or are trying to enter into with you
(for example, to provide you with the functionalities of the Site).
In this case, we may have to
stop you using our Site.
Personal Data
from Third Party Sources
In addition to the Personal
Data that we collect directly from you (as described in the section immediately
above this one), we also collect certain of your Personal Data from third party
sources. These sources are broken down in the table below, together with a
description of whether they are publicly available or not.
Third party data source |
Publicly available? |
Category(ies)
or other types of personal data received. |
Yes |
Identity Data Contact Data |
|
Social Media sites |
||
Analytics Providers |
No |
Behavioural Data Transaction Data
Technical Data |
Game Developers – where you
did not download the game from the PLUSDOT Sites |
No |
Identity Data Contact Data Behavioural Data Transaction Data Technical Data |
How we use
cookies & other tracking or profiling technologies.
What are
cookies?
We may collect information
using “cookies”. Cookies are small data files stored on the hard drive of your
computer or mobile device by a website. We may use both session cookies (which
expire once you close your web browser) and persistent cookies (which stay on
your computer or mobile
device until you delete them)
to provide you with a more personal and interactive experience on our Site.
We use two broad categories of
cookies:
Cookies we use.
Our Site uses the following types of cookies and other tracking
technologies for the purposes set out below:
Type of Cookies |
Purpose |
Essential Cookies |
These cookies are essential
to provide you with services available through our Site and to enable you to
use some of its features. Without these cookies, the services that you have
asked for cannot be provided, and we only use these cookies to provide you with
those services. |
Functionality Cookies |
These cookies allow our Site
to remember choices you make when you use our Site, such as remembering your
language preferences, remembering your login details and remembering the
changes you make to other parts of our Site which you can customise.
The purpose of these cookies is to provide you with a more personal
experience and to avoid you having to re-enter your preferences every time
you visit our Site. |
These cookies are used to
collect information about traffic to our Site and how users use our Site. The
information gathered via these cookies does not “directly” identify any
individual visitor. However, it may render such visitors “indirectly
identifiable”. This is because the information collected is typically linked
to a pseudonymous identifier associated with the device you use to access our
Site. The information collected is aggregated and anonymous. It includes the
number of visitors to our Site, the websites that referred them to our Site,
the pages they visited on our Site, what time of day they visited our Site,
whether they have visited our Site before, and other similar information. We
use this information to help operate our Site more efficiently, to gather
broad demographic information and to monitor the level of activity on our
Site. We use Google Analytics for this purpose. Google Analytics uses its own
cookies. It is only used to improve how our Site works.You can find out more information about
Google Analytics cookies here. You can find out more about
how Google protects your data here. We also use Baidu Tongji for this
purpose. |
|
Analytics and Performance
Cookies |
|
|
|
You can find out more
information about how Baidu Tongji cookies here. You can find out more about
how Baidu Tongji protects your data here . For more information on our
use of the Baidu Tongii services, please contact us
here. |
|
Targeted and advertising
techno logies |
These tracking technologies
track your browsing habits to enable us to show advertising which is more
likely to be of interest to you. They use information about your browsing
history to group you with other users who have similar interests. Based on
that information, and with our permission, third party advertisers can place
cookies and/or similar technologies to enable them to show adverts which we
think will be relevant to your interests while you are on third party websites or mobile applications . See “Mobile Advertising |
These cookies are used when
you share information using a social media sharing button or “like” button on
our Site or you link your account or engage with our content on or through a
social networking website such as Facebook, Twitter or Google+. The social
network will record that you have done this. |
|
Social Media Cookies |
|
Disabling
cookies
You can typically remove or
reject cookies via your browser settings. In order to do this, follow the
instructions provided by your browser (usually located within the “settings”,
“help” “tools” or “edit” facility). Many browsers are set to accept cookies until
you change your settings.
If you do not accept our
cookies, you may experience some inconvenience in your use of our Site. For
example, we may not be able to recognise your
computer or mobile device and you may need to log in every time you visit our
Site.
Further information about
cookies, including how to see what cookies have been set on your computer or
mobile device and how to manage and delete them,
In particular, you can disable
cookies which remember your browsing habits and target advertising at you by
visiting the Your Online Choices website . If you
choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do
choose to remove cookies by the companies listed at the above link, not all
companies that serve online behavioral advertising are included in this list,
and so you may still receive some cookies and tailored adverts from companies
that are not listed.
You can also prevent the use
of Google Analytics relating to your use of our Site by downloading and
installing the browser plugin available here.
Web Storage:
Local Storage
We may also use localStorage which is a way to store persistent data, such
as tracking ID, locally on your web browser (i.e. information is not transferred
to the server). This technology fulfils a similar purpose as cookies,
but is more secure and allows the storage of larger amounts of data.
Blocking/Clearing
localStorage
Same as Cookies.
Clearing Cache and Local Storage:
• Chrome • Safari
• Firefox
Mobile
Advertising Identifiers
We, or third
party Ad Networks, may collect, and may associate information with,
mobile advertising IDs (such as iOS Advertising Identifiers and Google’s
Advertising IDs) on the Sites. These are unique identifiers (which are
resettable) set by the applicable mobile operating system provider (“ Mobile Advertising IDs ”).
How to opt-out
of / reset Mobile Advertising IDs
iOS
Reset
your iOS Advertising Identifier: if at any time you wish to reset your iOS
Advertising Identifier, you can do so by replacing the final step with “ Click on ‘Reset Advertising Identifier ’”.
Do Not Track Signals
Some
Internet browsers may be configured to send “Do Not Track” signals to the
online services that you visit. We currently do not respond to do not track
signals. To find out more about “Do Not Track,” please visit the All About DNT website.
No Cross Device Tracking
Although
we collect information via the various “tracking technologies” referred to
above – we do not engage in ‘cross-device tracking’ .
This
means that we do not link information collected via multiple identifiers across
your different devices and browsers to create a consolidated picture of your
cross-device online activity or behaviour.
How we keep your
Personal Data secure.
We have put in place
appropriate security measures to prevent your Personal Data from being
accidentally lost, used or accessed in an unauthorized way, altered or
disclosed.
We limit access to your
Personal Data to those employees and other staff who have a business need to
have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place
procedures to deal with any actual or suspected Personal Data breach. In the
event of any such breach, we have systems in place to work with applicable
regulators. In addition, in certain circumstances (e.g., where we are legally
required to do so) we may notify you of breaches affecting your Personal Data.
How long we
store your Personal Data.
We will only retain your
Personal Data for so long as we reasonably need to use
it for the purposes set out above here, unless a longer retention period is
required by law (for example for regulatory purposes).
The table below shows our
standard retention practices:
Category of Personal Data |
Retention Period |
Behavioural Data |
To the extent there is any
Personal Data in Behavioural Data: two months from
the date on which we collected or received it. However, we only store Behavioural Data that constitutesAggregated
Data and/or anonymous data, and keep this record
forever. Please refer to our Ad Networks ’ privacy
policies for further information on how long they keep your Personal Data (if
any) – see Mobile Advertising Identifiers. |
Contact Data Identity Data |
For so long as retention is
necessary to fulfil the Purposes/Use for which it is used here. |
For 12 months following the
discontinuation of the applicable game, or upon request from the Game
Developer (if earlier), unless a longer period is required by law. |
|
Transaction Data User Content Data |
|
T echnical
Data |
Two months from the date on
which we collected or received it. |
Our policy on
children.
This Site is not intended for
children below 13 and we do not knowingly collect data relating to such
children.
Third party
links.
This Site may include links to
third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share your
Personal Data. We do not control these third-party websites and are not
responsible for their privacy statements. When you leave our Site, we encourage
you to read the privacy policy of every site you visit.