Last updated: Sept 2021
For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. This includes Information relating to your use of: (a) our mobile games (“Mobile Game/s, Mobile App” the “Game/s”), ); (b) powersnooker.app and any other dedicated Power Snooker websites, such as .games, .live which link to this policy (“Website”). When you use the Mobile Games / App, (the “Game”), you accept our rules and policies which set out how we handle your Information, and you understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not play any of the Games. If you change your mind in the future, you must stop playing the Games and you may exercise your rights in relation to your Information as set out in this Policy.
Our Games are available for use by children 13+, but we advise that they obtain the permission of a parent or guardian. If you are not the bill payer, are under 18 years of age and/or are intending on making any in-app purchases, you must seek permission of the bill payer. To comply with the current ‘UK Data Protection Act’ for Children, specifically the Age Appropriate Design Code (also known as the children’s Act), risks have been assessed using a risk matrix during our Data Protection Impact Assessment. More information can be found https://ico.org.uk/for-organisations/childrens-code-hub/
1. PERSONAL INFORMATION WE COLLECT
We will collect and use the following Information about you:
- Information you provide to us
- Registration information: for example, when the web browser game version is available, and you register to play a game on the Website, you will be asked to provide your, email address and a password, and to create an avatar with a username. We advise you do not use your full real name and choose a ‘nickname.
- Information collected via our customer support channels, for example, when you contact us via email, we ask you to provide (a) your full name, email and (b) any information you choose to provide to allow us to assist you.
- Information you provide when using the Games: when you play the Games, we may ask you to choose a username. Also, if you choose to invite your friends to play a game on the Website or App, we will collect the email address of your friends. Please make sure you have permission from your friends before sharing Information relating to your friends with us. If you use the invite a friend option, this will launch a template email within your phone e-mail account. The email will contain a link that allows your friend to download the app. The email invitation is sent from you. We do not store your friends email address at this time. If your ‘friend’ chooses not to download the app, we do not have any of their information. Only at the time of them downloading the app will we hold their data in line with our terms and policies.
- Information collected through surveys: we may ask you to complete surveys about your experience. The Information we collect from you varies depending on the survey, but we typically ask you questions about your interests and habits, your opinion about different products and services and what you’d like to be offered in the future. We also collect your ratings, opinions, preferences, questions, pictures, and responses associated with that survey.
- Information provided: It is the responsibility of the you, the ‘user’ to ensure your details are accurate and up to date and, where possible, to only provide such information as is necessary.
- Information we automatically collect or is generated about you when you play the Games
- Identifiers, such as your IP address, device and app ID, unique Power Snooker ID, location data and device information (such as model, brand and operating system).
- Information you generate and display when playing the Games, such as profile photos, pre-written conversation chat text and emoticons content.
- Information regarding your use of the Games, such as date and time stamps of game events, interactions with our teams and ad engagement, and transaction records, or evidence of you using cheating software or using of modified versions of the Games.
- Location based data, is collected within the app and can only be collected if you, the ‘user’ has your location services activated. When the app is installed it will ask for permission to allow the app to access your location service, you can accept or deny. You can also go into your settings on your phone and disable this at any time. The purpose for collecting this is to match you to a player closer to your location in order to try and provide a smoother gaming experience.
- Information received from third parties
- Information we receive from third party platforms when you register: when you register through a third-party account (Apple or Google Play), we may receive your third- party ID, name, avatar and location. If you give our Game permission, we may also collect your email address, friends list, date of birth or age.
- Information from payment processors: when you make payments in our Games, we receive information from our payment processors about your transactions, including your Apple ID number for Apple, your postcode and user ID and state for Google.
- Analytics information: we integrate certain analytics software of Unity and Google analytics, a third-party analytics provider in some of our Mobile Games. They provide reports that help us optimise our in-game features and events to each user of our Mobile Games which include your user ID and information on your in-game activity.
- Information collected from advertising partners: we receive information from Unity Technologies (a US and Finnish company). This includes user ID and information on your interactions with advertising shown in on our Mobile Games.
- Information from mobile measurement partners: we receive information from third parties to allow us to track performance of our marketing campaigns and to detect fraud in such campaigns. This includes advertising ID, IP address, location and transaction information.
- Third-Party Terms and Policies. When downloading the app, registering your account and making in-app purchases, third-parties’ terms and conditions remain independent of Power Snooker terms and policies.
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.
2. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal data (such as email address or telephone number if provided to us) when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
The UK GDPR highlights certain purposes that either 'constitute' a legitimate interest or 'should be regarded as' a legitimate interest. These are: fraud prevention; network and information security; and. indicating possible criminal acts or threats to public security.
Some processing is necessary because it is in Power Snooker Group Limited or a third party’s legitimate interests, such as those of visitors, members or partners.
We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.
The Lawful Bases we rely on and our legitimate interests
We process your information on the following lawful bases and in furtherance of the following legitimate interests:
- Provide you with the Games. More in particular, we will use your Information to perform our contractual obligation towards you to allow you to create an account, play the Games (including as a guest) and remember your progress, allowing you to play Games with your friends, provide you with in-Game pre-written conversation chat text functionality by using the pre-written conversation wording and emoticons, and to allow you to make purchases via Google Play, IOS App Store and maintain a record of such purchases. The Information we process when doing so includes your registration information, information you provide to us when playing the Games, identifiers, information you generate and display when playing the Games, and information regarding your use of the Games such as transaction records.
- Improve and monitor Game use. To improve our Games for our customers. When doing so, we may collect information we automatically collect or is generated about you when you play the Games, as well as non-personal information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system, and the amount of free space on your device.
- Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to create a support account for you, respond and resolve your queries and complaints, facilitate support. (e.g. retrieval of a forgotten password). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your registration information, your identifiers, non-personal information about your device such as your Wi-Fi strength and the amount of free space on your device, and any other information about you collected via our customer support channels.
- Conduct analytics. To analyse the use of and inform, our Games, newsletters and advertising campaigns, and any other interaction or interest in the same. When doing so we will process information we automatically collect or is generated about you when you play the Games or interact with our newsletters and advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; and (c) conduct predictive analytics about your interests.
- Send you updates about in-Game offers and our other products and services that may be of interest to you. We will send you promotional offers, and information about other products and services that may be of interest to you. Where it is required, we will only do so where we have your consent. We do so via email, push notification or in Game. When doing so, we process your registration information and the analytics information above. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication for emails or by adjusting your device settings for push notifications.
- Prevent fraud, defend Power Snooker against legal claims or disputes, enforce our terms and to comply with our legal obligations. To protect our users against online abuse and other anti-social or illegal activity, e.g. when moderating conversation (pre-written conversation chat text and emoticons) in our Games. Furthermore, it is also in our legitimate interest to protect our interests by (1) monitoring Game use to detect fraud or any other user behaviour which prejudices the integrity of our Games, (2) taking steps to remedy aforementioned fraud and behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties.
- Conduct surveys. From time to time, we may ask you to participate in surveys because they help us understand our userbase and improve the Games. If you choose to participate, we process your registration information and any other information collected through the survey questions.
3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We share your Information with selected third parties, including:
- Other players and users will see your profile information and in-game activities, as well as any other information you choose to share with them, such as pre-written conversation chat text data;
- Vendors and service providers we rely on for the provision of the Games, for example:
- Cloud service providers who rely on for data storage, including Unity, Google Firebase and Go-Daddy.
- Analytics providers. we work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase. This includes Apple, Google, Unity.
- Payment processors: For Mobile Games we use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments. These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies as below:
- Google: https://policies.google.com/privacy
- We share your information with all the subsidiary companies within Power Snooker Group Ltd but only if its applicable to Games
- Law enforcement agencies, public authorities or other judicial bodies and organisations, We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
- Change of corporate ownership. If we are involved in a merger, acquisition, insolvency, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.
Third Party Privacy Practices
If you access any Games through a third-party platform such as Apple or Google (“Third Party Services”), you must understand that those Third Party Services may collect other information about you (including information you share with them directly or about your use of the Games) in accordance with their own terms and privacy policies. The privacy practices described in this Policy do not apply to Third Party Services. Any links in the Games to Third Party Services do not imply that we endorse or have reviewed the Third-Party Services.
Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process.
4. WHERE WE PROCESS YOUR PERSONAL INFORMATION
Your Information will be processed by our employees and service providers, Apple, Google, Unity, Go-Daddy. We take steps to ensure all transfers are protected by adequate safeguards. When you download the app via Google Play or Apple, you will need to read their Terms and Policies which are independent of Power Snooker Terms and Policies. We may share with Google, Apple, Unity, Proton and Firebase data we have collected from your device in order to track game errors and gaming experience.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
5. HOW LONG WE STORE YOUR INFORMATION
Your Information is kept for as long as you are registered or using our games, and then for up to three years from the date you stop interacting with the games.
When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.
6. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:
- The right to request access to your personal data
- The right to request correction of your personal data
- The right to request erasure of your personal data
- The right to object to processing of your personal data
- The right to request restriction of processing your personal data
- The right to request transfer of your personal data
- The right to withdraw consent
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.
If you are based a legal resident of California in the U.S. or Brazil, you have certain rights in relation to your Information. For Californian residents, please refer to Addendum 1 – California Privacy Rights. For Brazilian residents, please refer to Addendum 2 – Brazil Privacy Rights.
ADDENDUM 1 – CALIFORNIA PRIVACY RIGHTS
The terms of this Addendum apply to residents of California under the California Consumer Privacy Act of 2018 and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this addendum, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include information that is: lawfully made available from government records, deidentified or aggregated, or otherwise excluded from the scope of the CCPA.
Collection and Disclosure of Personal Information
Over the course of 12 months, through your use of the Game, we may collect and disclose the following categories of Personal Information from or about you:
- Identifiers, including name, email address, IP address, device identifiers, game user ID, and profile photos. This information is collected directly from you or your device. If you have registered through a third-party account (Apple or Google), we may have also collected from those third-party services your third-party ID, name, and avatar.
- Internet or other electronic network activity information, including your use of in-game features and events and information on your in-game activity, and information on your interactions with advertising shown in on our Games. This information is collected from our selected third-party analytics providers and advertising partners.
- Geolocation data. This information is collected directly from you or your device and from third party services when you register through them.
- Commercial information, including records of products or services purchased, obtained, or considered, your Apple ID number for Apple, your postcode and state for Google. This information is collected directly from you or your device, and from our payment processors.
We collect personal information for the following purposes:
- To operate and administer the Game;
- To improve the Game;
- To communicate with you;
- To serve advertising;
- For security and verification purposes, including to prevent and detect fraudulent activity;
- To address and remediate technical issues and bugs.
We may disclose personal information to the following types of entities:
- Other players and users who will see your profile information and in-game activities, as well as any other information you choose to share with them, such as pre-written conversation chat text or emoticons data;
- Our affiliate companies within our corporate group who process personal information in order to operate the Games;
- Marketing and advertising partners who use your information to serve you ads in the Games and on other sites;
- Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us;
- Regulators, judicial authorities and law enforcement agencies;
- Entities that acquire all or substantially all of our business.
ADDENDUM 2 – BRAZIL PRIVACY RIGHTS
The terms of this Addendum apply to residents of Brazil under the Lei Geral de Proteção de Dados (Lei nº 13.709, de 14 de agosto de 2018) and its implementing regulations, as amended or superseded from time to time (“LGPD”). For the purposes of this Addendum 2, Personal Information has the meaning as defined in the LGPD.
Categories of Personal Information collected and processed
How we use your Personal Information
Your rights under the LGPD
The LGPD provides residents of Brazil with certain legal rights; these rights are not absolute and are subject to exemptions. In particular, you have the right to:
- Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed.
- Request that personal information be corrected.
- Restrict the processing of your personal information that is not being processed in compliance with the LGPD.
- Obtain information on the possibility of refusing consent and the consequences of doing so.
- Obtain information about the third parties with whom we share your personal information.
- Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Art. 16 of the LGPD apply.
- Revoke your consent at any time.
- Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.
To exercise your rights, please follow the procedure set out below:
email us at email@example.com
Subject should say ‘I have a data related question connected to my account’
- Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals.
- Erasure. You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case.
Note that where the Information is held by a third party data controller, such as an advertising partner or a payment processor, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.
- Objection and withdrawal of consent. You have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests (see above under How we use your personal information). You may exercise this right as follows:
- To stop receiving marketing emails: please follow the unsubscribe mechanism at the bottom of each email communication.
- To stop receiving push notifications: please change your device or browser settings.
- Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.
- Correction. You have the right to correct any Information held about you that is inaccurate.
- Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.
7. CONTACT & COMPLAINTS
We welcome questions, comments and requests regarding this Policy. These should be addressed to firstname.lastname@example.org
You can send a letter to the Data Protection Officer at Power Snooker Group
If you wish to make a complaint about how we process your Information, please contact us at email@example.com and we will endeavor to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.
We may need further information from them to verify you and will contact you to request further information if needed.
We aim to respond to complaints within 30 days; however, this may be delayed if you have not provided us with all relevant information.
If you are a UK user and feel that we have not handled your compliant within a reasonable timeframe or have not satisfied your complaint, you can seek advice from ICO. https://ico.org.uk/make-a-complaint/
Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you in-Game.
9. DEVELOPER PARTNERSHIPS
We work with the following third-party developer We Are Creative Online Ltd.