PRIVACY POLICY
Last updated: 14 October 2024
Introduction
Welcome Clone Jockeys! This privacy notice (this “notice”) is about how we use personal information about you called “personal data” when you’re playing DEATHSPRINT 66 (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 use the game. The means we’re what’s called a “data controller” of this personal data.
What is personal data and why is it important?
Personal data is any information which identifies you (like your name, username, and email address). It is also information which can be pieced together with other information to identify you, like your title, location, age, gender, or the technical IDs given to your computer/laptop (these IDs are sometimes known as “online identifiers”).
It is important to know what we do with your personal data, because you should be able to control what happens to it. By reading and understanding this notice, you will know how we collect, use, share, and protect your personal data, and how you can ask us to use it differently.
How do we collect your personal data?
We process personal data about you when you play our game. This includes:
· Information you provide to us and information relating to your communication, such information you submit when filling in your account set up form or contacting our customer support teams with queries about the game.
· Usage and tracking information. Sometimes we also use certain technologies, such as game analytics and crash handling tools, to collect information about you automatically when you play our games. Where information that is collected automatically can be linked back to you or pieced together with other information to identify you, it will be classified as personal data.
In relation to information, you provide us, the provision is optional, but if you choose not to provide it you may not be able to access certain aspects or functionalities of the service where this information is needed. 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 our services without this information.
We collect the following categories of personal data when you play the game:
· Account information, third party identifiers such as the username that you use on third-party platforms, and other information shared with us via those third-party platforms.
· Customer support data, any information voluntarily provided by you to our customer support team, including your name, email, other contact information, username and details related to gameplay data.
· Gameplay data, such as information about events in the game including progress, achievements, occurrence of particular events, information about any game crashes, game installation/uninstallation, play session durations, choices/selections for different parts of the game, game-play statistics, in-game purchases, scores, rankings, click paths, game profile, preferences and friends, and interactions with game content.
Third Party Sources
We collect personal information about you from the following third parties:
· Third party tools: We also may use third-party tools to help us manage and analyse behavioural analytics and in-game crash reporting. The information collection and sharing practices of these third parties are subject to their respective terms and conditions and privacy policies
· Vendors and business partners: We collect contact, account and payment transaction data from our vendors (such as payment processors, digital storefronts, cloud hosting and service providers) to enable game features and content.
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 or sign up to a contract | When it’s necessary to use your personal data to perform a contract with you, or because you have asked us to do something before signing a contract with you that requires the processing of your personal data. 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 before signing the contract. |
| “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. |
| “Consent” You have given us your consent | Sometimes we will ask for your (or we might need to ask for your parent’s) consent to use your personal data. This consent will always be clear and separated out from other information. You can always withdraw your consent by contacting us 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 |
| Third-party account login and profile information: third party identifiers such as the username that you use on third-party platforms, and other information shared with us via those third-party platforms. | We use this information to allow you to access the game from a third-party platform. | Contract Legitimate interest our interest in allowing our game to be published and distributed on third-party platforms, so that you may access and play it. |
| Providing friends list functionality, account data, gameplay data. | We use this information so that you can connect with your friends and share game activities with your friends. | Contract |
| Enabling customer support: identity and contact data (email), account data, customer support and communication data, transaction data, and gameplay data. | We use this information to help provide support to you in relation to the issue you’ve contact us about. | Legitimate interest in answering your questions about our service to improve your experience. |
| Leaderboards, including Steam ID, Steam photo & region (country) | We use this information to provide player level data including show on in-game leaderboards | Legitimate interest in providing the service. |
| Running technical diagnostics and crash reporting, including account data, gameplay data, and usage and tracking data (e.g., basic hardware information, IP address, operating system information, server logs, log files, and bug/crash reports). | 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. | Consent (where consent is needed to access information stored on your device) |
| Maintaining network security, including account data (Device ID, Steam ID,), and usage and tracking data (IP address, IP lookup information) | We use this information to help provide security and network protection mechanisms, | Legitimate interest in ensuring the security of our services & technologies |
| Conducting analytics for gameplay features, account information, usage and tracking data, gameplay data. | We process data related to your device and your gameplay to learn more about our services. | Consent (where consent is needed to access information stored on your device). |
| Conducting behavioral analytics, Steam ID, IP address, country | We track behavioural analytics based on player activities, technical performance. | Legitimate interests in improving our products and services |
| Improving our game, account information, usage and tracking data, customer support and communication data gameplay data. Steam ID, IP address, country. | We process information provided from your feedback and analytics of our users gameplay to optimize our products and services, fix patches and bugs, offer upgrades, facilitate software updates, and develop new games, features, offerings, and services | Legitimate interests in improving our products and services |
| Enabling anti-cheat and security related features: Device ID, game related data (platform ID), operating system information | We use this information to detect and observe cheating behaviours and fraud, identify and address bugs caused by cheating in the game, prevent hacking and spamming, and combat users registering for multiple accounts. We use this in conjunction with (Proxima Beta Game Anti Cheat (PGAC)) | Legitimate interest in maintaining a fair gaming environment |
| Protecting and enforcing our rights: where relevant, identity and contact data, account data, transaction data, customer support and communication data marketing and advertising data, gameplay data. | We may process personal data to protect and enforce the rights, property, security or safety of us, our business, our customers or others, including investigating and helping to prevent fraud or other unlawful activity. We keep business, accounting and legal records to do this. | Legitimate interests in defending our legal rights and interests. |
| 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: where relevant identity and contact data, account data, transaction data, customer support and communication data marketing and advertising data. | 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 |
| Financial reporting: transaction data, usage and tracking data | We use this information to complete our financial reporting and disclosure obligations to parent company, tax agencies and regulators | Legal obligation – our obligations under tax and corporate law. |
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. Some of them provide us with services to help us to manage our games. 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”).
· Service providers – We need separate companies to provide us with services we use to support the game. We share personal data with the following categories of third parties: payment processors and online store providers (we share your identity and contact and account data); hosting providers (we share your account data, and device usage and tracking data, Steam ID, Steam photo & region/country); customer support companies (we share your identity and contact data, customer support and communications data, and gameplay data); technical support providers (we share technical diagnostics information contained in your usage and tracking data, and gameplay data); offline support services such as product support or data storage (we share your account data, and device usage and tracking data, Steam ID, Steam photo & region/country); and anti-cheat software providers (we share your account 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 (“European Region”) 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 the European Region, including the United States, Singapore, and China.
Where the country outside the European Region is a country which is subject to an adequacy decision by the European Commission, UK Government, or the Swiss Federal Council, 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 until we sunset it. Any additional data related to providing our services, including troubleshooting and customer service, will be kept as long as necessary to fulfil the request.
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.
· In Switzerland, the regulator is the Federal Data Protection and Information Commissioner (FDPIC), which you can contact here.
Updates to this policy
We may make updates to this policy from time to time (for example because our services have changed or 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 Services 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 DEATHSPRINT66! Now, RUN FOR GLORY CLONE JOCKEYS!