PRIVACY POLICY

Introduction

This privacy notice (this “notice”) is about how we use personal information about you called “personal data” when you’re playing Critter Café (the “game”).

Who are we?

We are Secret Mode Limited (“we” or “us” in the rest of this notice). We are located at Unit 32 Jessops Riverside, Brightside Lane, Sheffield, United Kingdom, S9 2RX and you can find our contact details below.  

We make decisions about how and why we use your personal data when you play the game. The means we’re what’s called a “data controller” of this personal data.

Personal Data We Collect and How We Collect It.

We process personal data about you when you play our game. This includes:

· Usage and tracking information. We automatically collect certain types of usage and device information when you play the game. This information includes device identifiers like IP address, country of install and unique device or account ID. Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory, and we will not be able to provide the game without this information.

We collect the following categories of personal data in connection with your use of the game:

· Usage, browsing and activity information: such as your game activities and device, including IP address, country of install and device ID.

· Third party tools: We use a third-party tool called Sentry to track and report error monitoring in the game. The information collection and sharing practices of these third parties are subject to their respective terms and conditions and privacy policies.

How and Why We Use Your Personal Data

Depending on where you play our game, we are only legally allowed to use your personal data where a “legal basis” allows us to do so. These are the legal bases which could apply:



 Legal Basis When does this Legal Basis apply?  
“Contract”   We need to carry out a contract   When it’s necessary to use your personal data to perform a contract with you.   In these cases, if you don’t provide your personal data, then we won’t be able to perform the contract or do what you have asked us to do.  
“Legitimate Interest”   It’s in our or someone else’s “legitimate interests  “Legitimate interests” is a legal phrase. It usually means a commercial or business interest that is important to us or another company, and which we’ve balanced against your right to privacy.    We will always let you know what the interest is, and you can object to us using your personal data for these reasons via email at info@secretmode.games.  
“Legal obligation”   We need to do something a legal obligation tells us to do.   When it’s necessary to use your personal data so that we can perform our legal and regulatory obligations – so that we don’t break the law.
This table lists the types of personal data we use about you, and our reason for this:
The types of your personal data we use   Why we use this personal data   Legal basis
Providing our services, third-party account IDs, usage and tracking data, and gameplay data     Where you can login to our services from a third-party platform, we process account information provided by that third party. We also use this information to host our servers and enable the game.   Performance of Contract   Legitimate interest in maintaining and improving the service
Running technical diagnostics and crash reporting, including country data.      We use this information to conduct run technical diagnostics and crash reporting. We process some of your usage and tracking information to accomplish this including device IDs and other technical information necessary to why something went wrong. Legitimate interests in improving the game.    
Improving the Game usage and tracking data, gameplay data, steam ID, Player ID, IP address, Device ID, Epic Account ID. We process information provided from analytics of our users gameplay to optimize our game, fix patches and bugs, offer upgrades, facilitate software updates, and develop new games, features, offerings, and services.   Legitimate interests in improving our game
Meeting regulatory requests – potentially all information categories listed above. We may disclose personal data to meet requests from regulatory, prosecuting, law enforcement, tax or governmental authorities, courts or tribunals Legitimate interests – defending our legal rights and interests.
Responding to data subject requests: potentially all information categories listed above If a data subject request is submitted, we use this information to confirm the requestor’s identity, your rights and to process the request.   Legal obligation - our obligations under data protection laws
Sending legal reports/responding to court orders – potentially all information categories listed above if a law enforcement body requests it   We may be required by law to disclose this information to law enforcement bodies.   Legal obligation – our obligations under tax, anti-money laundering, anti-bribery, security, and intelligence laws


Disclosures of Your Personal Data

Sometimes we share your personal data with other companies and organizations.

The types of companies and organizations we share your personal data with are as follows:

· Companies in our “group” of companies – We have lots of different companies in our “group” who are linked to us. When needed, we share all personal data mentioned above with these other companies so they can assist us with the processing set forth in this policy. We may share your personal information with our parent company Sumo Group Limited and its subsidiaries (the “Sumo Group”), but we will not share your personal data with our ultimate parent, Tencent Holdings Ltd., a public company listed on the Stock Exchange of Hong Kong (SEHK: 0700) and headquartered in China or any of Tencent Holdings Ltd.’s affiliates outside the Sumo Group.

· Service providers – We need separate companies to provide us with services we use to support the game (such as Sentry). We share personal data with the following categories of third parties: hosting providers (we share your account data, and device usage and tracking data, Steam ID, Steam photo & region/country) and technical support providers (we share technical diagnostics information contained in your usage and tracking data, and gameplay data).

· Regulators, official authorities, and other third parties in relation to legal compliance – For example, the police or the government might legally require use to give them personal data to help them with an investigation, or we might be required to give these companies personal data to enforce our terms, address security and fraud, and to protect you. We may be required to share all categories of personal data mentioned above with these entities.

· A third party that acquires all or part of our business – we might disclose all categories of your personal data mentioned above to another company which buys or undertakes another type of corporate transaction in respect of our shares or buys all or part of our assets.  

Where We Share Your Personal Data

Yes, sometimes your personal data goes to other countries as part of using your personal data in the ways we listed above, including in the European Economic Area (“EEA”). If you are in the UK, the EEA, or Switzerland and your personal data goes outside of these countries, the law requires us to take extra steps to make sure your personal data is protected in the place it is going to.

We transfer your personal data to third parties that host or access personal data outside of these jurisdictions, including the United States and Germany.

Where the country outside the UK or EEA is a country which is subject to an adequacy decision by the European Commission, we rely on that adequacy decision of the transfer – for example the United States (when recipients are certified under the EU-US Data Protection Framework).

If we send your personal data to a company (either in our “group” of companies or a separate company) which is in a jurisdiction not subject to an adequacy decision, we will rely on EU standard contractual clauses, which require that company to protect your personal data. To the extent required or permitted by data protection law, we may rely on a vendor’s processor binding corporate rules and/or other data transfer mechanisms available under EU data protection law.

We might take similar steps where you are in another country with similar legal requirements, as well. If you want to find out more information about international transfers, you can contact us using the details below.

How Long We Retain Your Personal Data?

We only keep your personal data for as long as is necessary to fulfil the purpose for which it was collected. As soon as your data is no longer required for the aforementioned purposes it will be deleted. Generally, we will retain data necessary to provide our game to you for as long as we make the game commercially available.

We might need to keep your personal data for longer if a law requires us to (for example, laws about record-keeping and tax). Normally this is about six to ten years. If we are keeping your personal data for longer in this way, we will make sure it is secure and you can still change what we do with it (see below).  

Your Data Subject Rights

Because your personal data is about you, you should be able to control what happens to it.

We provide different ways you can do this. The easiest way is to write us an email at info@secretmode.games requesting one or more of the following:

· “Right to Object” – you can object to how we are using your personal data if we are using it based on legitimate interests (see above) in certain situations.

· “Right to Portability” – you can request a downloadable copy of your personal data and for us to transfer it to another party. If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible.

· “Right to Access” – you can request to access to the personal data we use about you, and information about how we use it and who we share it with.

· “Right to Deletion” – you can request that your account or specific personal data we store about you is deleted from the game. Please be aware that once an account has been deleted there is no way to recover it;

· “Right to Correct” – you can request that information about you that is wrong or outdated is corrected.

· “Right to Restrict” - you can request to restrict the use your personal data, for example to storage purposes only.

· “Right to Withdraw Consent” – you can withdraw your consent if our reason for using your personal data is consent (see above). We will then stop using your personal data in this way (though this doesn’t affect the lawfulness of the processing until you withdraw).  

You can also submit requests to exercise these rights by contacting us at info@secretmode.games.

Unfortunately, we’re sometimes not able to do the things you tell us to, for example because of the legal basis we have been relying on to process your personal data, or because it would interfere with another person’s own privacy rights. If this happens, we’ll explain to you why we aren’t able to do what you tell us to with that piece of personal data.

We may also be required to keep certain personal data to satisfy legal requirements or for security purposes, or if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case. 

You can contact the official organization which regulates personal data in your country (the “regulator”) to lodge a complaint, if you think we are not using your personal data correctly. If you are in the UK or the EEA:

·  You can find a list of EEA data protection regulators here.

· In the UK, the regulator is the Information Commissioner’s Office which you can contact here.

Updates to this policy

We may make updates to this policy from time to time (for example because of changes in laws). We will appropriately notify you of this. The date this notice was last updated can be found at the top.  

Children

We do not use the game to knowingly solicit data from or market to children under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@secretmode.games. We will delete such information within a reasonable time.

Contact Us

If you have any questions about what we have said in this notice or how your personal data is used, you can contact us about it.

Our contact details are: 32 Jessops Riverside, Brightside Lane, Sheffield, United Kingdom, S9 2RX. Our email address is info@secretmode.games. If you are located in the EEA and have questions about your personal data or would like to request to access, update, or delete it, you may contact our representative at:

32 Jessops Riverside, Brightside Lane, Sheffield, United Kingdom, S9 2RX. Our email address is info@secretmode.games.

Thank you!

We hope you have a great time playing Critter Café.