committed to respecting your privacy and protecting your personal data. This
sets out how we use data relating to you and applies to all use of your
personal data by Secret Mode Limited, a company registered in England and Wales
under company number 12912552
and with registered office at 32 Jessops Riverside, Brightside Lane, Sheffield,
United Kingdom, S9 2RX (“Secret Mode”. “we”, “us” or “our”). Secret Mode is the controller
Policy applies to personal data we may collect from you, or that you provide to
us, through or in connection the game Her Majesty Spiffing (“Game”). Our Game and any services provided by us relating to the
Game are together the “Services”.
Please read the Policy carefully to understand our views and practices
regarding your personal data. This Policy sets out the basis on which personal
data will be processed by us, pursuant to the Services, and describes how we
use, disclose and otherwise process this personal data, and explains the rights
you have regarding your personal data processed by us. If you are a California resident, please be
sure to review Section 12 below for important information about our privacy
practices and your rights under California privacy laws.
1. HOW WE COLLECT AND USE YOUR PERSONAL DATA
collect personal data directly from players and other users (collectively, “Users”)
of our Services, automatically related to the use of the Services, and in some
cases, from third parties (such as operators of certain third-party services
that we use). The information we collect about Users varies depending upon the
circumstances, such as the Services used.
Information We Collect from You. Generally,
we collect your personal information on a voluntary basis. However, if you
decline to provide certain personal information that is marked mandatory, you
may not be able to access certain Services or we may be unable to provide our Services or fully respond to your
inquiry. In general, we may collect the following personal information from you:
Registration and profile
information: To access and use certain Services
(e.g., to register a game, download or use a mobile application, access
subscription-based Services, create an account) you may be required to register
with us, by providing us with certain required information, which is identified
on the registration page. Depending upon the Services you use, this may include
your name, a username and password, as well as country of residence, email, and
contact information; certain Services will not be available if you decline to provide
required information. We may also ask you or allow you to submit certain
optional information, which may include your location, preferences, a photo or
avatar, and other profile information.
Purchases and payments
information: If you make a purchase or sign up
for certain subscription-based Services, you are required to provide your
payment information, including name, billing and shipping address and details,
payment type, as well as credit card number or other payment account details
(e.g., PayPal). We work with third parties like payment processors and
fulfillment partners to process these payments. These third parties may
directly collect, receive, process or store credit card or debit card numbers,
or other third-party payment account credentials (e.g., PayPal) from you in
order to process your payment.
Marketing, contests and
promotions: Users can sign up online to receive
direct marketing communications from us, including emails about game launches,
developments, and upcoming releases. If you agree to receive direct marketing
communications from us, we collect your email address, and we may also collect
your name, preferences, and if relevant, information about your account and the
Services and other games you use. We may also collect your name, age, email
address, and other information related to contests, sweepstakes or other events
or activities on our websites and social media channels.
Support / enquiry information and other communications: When you email us, call us,
or otherwise send us communications regarding the Services, we collect and
maintain a record of your contact details, communications and our responses. We
may also maintain records of the in-game communications and information that
you post within the Services.
Information We Collect and Receive from Third Parties. We may collect and receive personal information about you from
third parties, as explained below.
Third-party and mobile platforms: You may be able to login through or connect certain third-party
accounts (each a "Third-Party Account")—to your account with
us, or to interact with us and others on game forums and communities on
third-party platforms. These Third-Party Accounts and platforms are operated
and managed by third parties and subject to their respective terms and conditions.
When you access, play or use our Services through a third-party platform or
website, or through your mobile device, we may collect or receive your UID,
device ID app ID, IP address, MAC address, and other device identifiers, as
well as username, registered email address, and other information you authorize
to be shared.
Third-party tools: We also may use third-party tools to help us manage and analyze our
social media presence, and report on comments, mentions and other content that
is posted about us on social media and other third party sites, platforms,
public channels and forums. The information collection and sharing practices of
these third parties are subject to their respective terms and conditions and
Vendors and providers: We may engage vendors and work with other partners to provide services
to us or to Users on our behalf (such as payment processors, digital
storefronts, cloud hosting and services providers). In addition, we may receive usage
and browsing data from ad networks, analytics providers and others who we work
with to deliver, improve and measure our online advertising and marketing
Information We Collect Automatically
About Your Usage and Activities. We collect personal information about how you use the
Services and interact with us and others, such as information we collect
automatically (e.g., using cookies and pixel tags), as well as information we
derive about you and your use of the Services. Such information includes:
Usage, browsing and activity information: When you use our Game we may
collection information about your game activities and device, including IP
address, location information, country of install and language, device ID,
manufacturer, and model. See Section 4 below for more information.
‘Events’ related to Game
usage: When you use our Game we collect information, such as
progress, achievement of a milestone and the occurrence of other particular
events during your Game usage (such as Game installation/uninstallation, play
session durations and choices/selections for different parts of the Game,
interactions with Game content).
2. PURPOSES AND LEGAL BASES FOR PROCESSING YOUR DATA
While the purposes for which we may process personal information will
vary depending upon the circumstances, in general, we use personal information
for the business and commercial purposes set forth in this section. In this
section, we also explain the legal bases for which we process personal
information about Users, as required by the EU General Data Protection
Regulation (the "GDPR"), UK
Data Protection Act 2018 (“UK DPA”) and other similar laws.
Legal Bases for Processing. Pursuant to the GDPR,
the UK DPA, and other similar laws, in general, we process your personal
information for the following legal bases:
Performance of our contract
with you: The personal information we collect
other terms and conditions applicable to the Services you use.
To comply with a legal
obligation to which we are subject: The personal information we
collect may be processed in order to comply with the law and our legal
For our legitimate business
interests: We may process personal information
in furtherance of our legitimate business interests in protecting, maintaining
and improving the Services; developing new games, features and services;
marketing and promoting our Services (including by profiling and marketing to Users);
protecting our legal rights and interests; in support of mergers, acquisitions,
reorganizations and other business transactions; and to generally operate and
improve our business.
With your consent: We may process personal information about you based on your consent,
for example (where required by law) to send you marketing communications,
surveys, news, updates and other communications. In addition, where required by
applicable law, we will obtain your consent to this Policy and our collection,
use and disclosure of your personal information. Users may be able to withdraw their consent at
any time in accordance with applicable laws. For information on how revoke your
consent, please see Section 6 below.
Purposes of Use and
In general, we process your personal data for the following purposes:
Providing our Services and
related support: Including to operate our Services;
to administer contests, programs and promotions; to communicate with Users
about their access to and use of our Services; to respond to User inquiries; to
fulfil User orders and requests; to process payments; to provide
troubleshooting and other technical support; and for other customer service and
support purposes. (Legal basis: performance of our contract with you;
and for our legitimate business interests)
Protecting the integrity of
the Services: Including to verify your identity;
to detect and prevent fraud, cheating and unauthorized activities; to
facilitate software updates; to secure of our systems and the Services; to
Conduct, and other applicable terms; and to protect the rights and safety of
Users. (Legal basis: performance of our contract with you; compliance
with laws; and for our legitimate business interests)
Analyzing and improving the
Services and our business: Including to better
understand how Users access and use our Services; to evaluate and improve the
Services and our business operations; to develop new games, features, offerings
and services; to conduct surveys and other evaluations; and for other research
and analytical purposes. (Legal basis: our legitimate business
Personalizing the Services: Including to tailor content we send or display on our websites and
other Services (e.g., for your geographic area); to offer personalized help and
instructions; to tailor your gameplay experiences; and otherwise personalize
your experiences with the Services. (Legal basis: our legitimate
Advertising, marketing and
promotional purposes: Including to send or display
targeted marketing; to reach you with more relevant ads and to evaluate,
measure and improve the effectiveness of our ad campaigns; to send you
newsletters, offers or other information we think may interest you; to contact you
about our Services or information we think may interest you; and to administer
promotions and contests. Where required by applicable law, we will obtain your
consent to use your personal information for marketing and related purposes.
(Legal basis: our legitimate business interests and/or with your
Securing and protecting our
business: Including to protect and secure our
business operations, assets, Services, network and information and technology
resources; to investigate, prevent, detect and take action regarding fraud,
cheating, unauthorized access, situations involving potential threats to the
rights or safety of any person or third party, or other unauthorized activities
or misconduct (Legal basis: our legitimate business interests and/or
compliance with laws)
Defending our legal rights: Including to manage and respond to actual and potential legal disputes
and claims, and to otherwise establish, defend or protect our rights or
interests, including in the context of anticipated or actual litigation with
Users or third parties. (Legal basis: our legitimate business interests
and/or compliance with laws; in Brazil, this also includes the exercise of
rights in judicial, administrative or arbitration proceedings in accordance
with applicable laws)
Auditing, reporting, corporate
governance, and internal operations:
Including relating to financial, tax and accounting audits; audits and
assessments of our operations, privacy, security and financial controls, risk,
and compliance with legal obligations; our general business, accounting, record
keeping and legal functions; to maintain appropriate business records; to
enforce company policies and procedures; and related to any actual or
contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy
or restructuring of all or part of our business. (Legal basis: our
legitimate business interests and/or compliance with laws)
Complying with legal
obligations: To comply with applicable legal or
regulatory obligations, including as part of a judicial proceeding; to respond
to a subpoena, warrant, court order, or other legal process; or as part of an
investigation or request, whether formal or informal, from law enforcement or a
governmental authority. (Legal basis: our legitimate business interests
and/or compliance with laws)
DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal
data with third parties as set forth below:
Affiliates and group members: We may disclose your
personal data to a member of our corporate group in order to carry out the
processing set forth in this Policy. For
example. for purposes of assisting us to market our Services and games, conduct
analytics, research and demographic studies, develop and improve the
Services, and to help us improve and tailor the Services we provide. Our
subsidiary or affiliate companies are subject to this Policy when they use your
personal information. 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
service providers: We may engage vendors, agents, service providers, and others to provide
services to us or to Users on our behalf, such as support for the internal
operations of our websites, online stores (including payment processors),
products (such as our games) and services (e.g., forum operations, and
technical support processing), as well as related offline product support
services, data storage and other services. In providing their services, they
may access, receive, maintain or otherwise process personal information on our
behalf. Our contracts with these service providers do not permit use of your
personal information for their own marketing and other purposes.
Stores and platforms: We may also disclose your
personal data, to the extent necessary, to game / application stores or
platforms (such as the Apple App Store and Google Play Store) if that is
reasonably necessary to the provision of the Services, for example, to fulfil
an order you make (e.g. if needed to fulfil a mobile game DLC order) or in
order to investigate or prevent fraud. Such platforms and stores may also
process your information in order to provide you with cross-device access to
your current position in the Game and your in-Game progression, for example.
Advertising and analytics: We may engage third
parties that provide advertising, campaign measurement, online and mobile
analytics, and related services to us (with your consent, where required by
applicable laws). They may use this information to help us better reach
individuals with relevant ads and to measure and improve our ad campaigns, or
to better understand how individuals interact with our Services. In addition,
these third parties may combine the information collected from us and our
Services with information collected about you from third-party sites, apps and
services, in order to make inferences about you and your interests, to better
tailor advertising and content to you across multiple sites, apps, and
services, and to collect associated metrics.
Where legally required: In addition, we may
disclose your personal data 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 to
establish, exercise or defend our legal rights (including providing information
to others for the purposes of fraud prevention).
Potential acquirers or
If we are involved in a potential or actual merger, acquisition, transfer, sale,
bankruptcy or similar transaction, involving all or a portion of our business
or assets, , your personal be disclosed as part of such transaction (including
related to due diligence associated with such transaction, to the extent
permitting by applicable data protection laws).
Enforcement: We may also disclose your
personal information to third parties in order to enforce or apply the terms of
agreements, to investigate potential breaches, or to protect the rights,
property or safety of us, our personnel or customers, or others.
With Consent: We may also disclose your
personal data to other affiliated or third parties where you have consented or
requested that we do so.
4. COOKIES, ANALYTICS AND PERSONALIZATION
collect and record information about your browsing activities, gaming
performance and use of the Services. We may combine this "activity
information" with other personal information we collect about you.
Generally, we use this activity information to understand how our Services are
used, track bugs and errors, provide and improve our Services, establish
matchmaking, verify account credentials, allow logins, track sessions, prevent
fraud, and protect our Services, as well as for targeted marketing and
advertising, to personalize content and for analytics purposes.
Below is a summary of these activities. For more detailed information
about these mechanisms and how we collect activity information, see our Cookie
Log Files. We collect certain activity
information from log files. Log file information is automatically reported by
your browser or mobile application to our servers when you access our Services.
We record certain information from these log files, including web requests, IP
address, browser type and version, language information, referring and exiting
URLs, links clicked, pages viewed and other similar information.
Cookies. Are small files with a unique
identifier that are transferred to your browser through our websites. They
allow us to remember Users who are logged in, to understand how Users navigate
through and use our Services, and to display personalized content and targeted
ads (including on third-party sites and applications).
Clear GIFs, pixel tags and web beacons.
These are tiny graphics with a unique identifier, similar in function to
cookies that we use to track the online movements of Users of our Services and
to personalize content. We also use these in our emails to let us know when
they have been opened or forwarded, so we can gauge the effectiveness of our
Anti-Cheat and fraud prevention. Providing
a fair gameplay environment is important to us. We prohibit cheating, hacking,
account stealing, and any other unauthorized or fraudulent activity when using
our Services. In order to detect and prevent fraud and cheating, we may use
anti-cheat and fraud prevention tools, applications, and other technologies.
When you use our Services, such technologies may create a machine
"fingerprint" or "hash" of your machine components, and
collect information about you, including information about your browser,
device, activities, game identifiers, and operating system.
Analytics Tools. We may use internal and
collect and aggregate activity data and other data across multiple channels.
Our Game and other Services may include third party advertising. In some cases
the advertising content may be tailored to your perceived interests by our
advertising services vendor. This is in order that advertising can be served to
you which may be more interesting to you. You can opt-out of such interest-based
advertising , such as by utilising in-Game privacy settings or the cookie
preferenc manager for our websites.
5. DATA RETENTION
We will only hold data about
you for as long as necessary, bearing in mind the purpose for which that data
was collected, or as otherwise described in this Policy. To determine the
appropriate retention period for personal data, we consider the amount, nature,
and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
6. USER RIGHTS AND CHOICES
We give Users several
easy-to-use ways to access, amend and exercise their choices and rights
regarding their personal information.
Subject to the conditions set out in the applicable law, Users may have
the following rights regards our processing of their personal information:
Right of access. If you ask us, we will confirm whether we are processing your personal
information and, if necessary, provide you with a copy of that personal
information (along with certain other details).
Right to correction
(rectification). If the personal information we hold
about you is inaccurate or incomplete, you are entitled to request to have it
corrected. If you are entitled to have information corrected and if we have
shared your personal information with others, we will let them know about the
rectification where possible.
Right to erasure. You can ask us to delete your personal information in some
circumstances, such as where we no longer need it or if you withdraw your
consent (where applicable). If you request that we delete your personal
information, we may do so by deleting your account(s) with us. Brazilian Users
may also request the anonymization, blocking or erasure of unnecessary or
excessive personal information, or personal information processed in violation
of the LGPD.
Right to restrict (block)
processing. You can ask us to restrict the
processing of your personal information in certain circumstances, such as where
you contest the accuracy of that personal information or you object to our use
or stated legal basis.
Right to data portability. You have the right, in certain circumstances, to receive a copy of
personal information we have obtained from you in a structured, commonly used
and machine-readable format, and to reuse it elsewhere or to ask us to transfer
this to a third party of your choice.
Right to object. Where our processing is on the basis of our legitimate interests
(other than marketing purposes), we must stop such processing unless we have
compelling legitimate grounds that override your interest or where we need to
process it for the establishment, exercise or defense of legal claims. Where we are relying on our legitimate interests (other than
marketing), we believe that we have a compelling interest in such processing,
but we will individually review each request and related circumstances.
Right to object to marketing. You can ask us to stop processing your personal information to the
extent we do so on the basis of our legitimate interests for marketing
purposes. If you do so, we will stop such processing for our marketing
Right not to be subject to
automated decision-making. You have the right not to be
subject to a decision when it is based on automatic processing if it produces a
legal effect or similarly significantly affects you, unless it is necessary for
entering into or performing a contract between us. Secret Mode does not engage
in automated decision-making. Brazilian Users may also request the revision of
any decision made solely on the basis of automatic processing, to the extent
such decision affects your interests and applies to our Services.
Right to withdraw your consent. In the event your personal information is processed on the basis of
your consent, you have the right to withdraw consent at any time, without
affecting the lawfulness of processing based on consent before its withdrawal.
Brazilian Users also have the right to be informed about the consequences of
denying or withdrawing consent.
Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory
authority if you consider that our processing of your personal information
infringes the law.
Please note that some of these rights may be limited, such as where we
have an overriding interest or legal obligation to continue to process the
data. Please contact us using the information set out above, in Section 13.
Contact Details, if you wish to exercise any of your rights or if you have any
enquiries or complaints regarding the processing of your personal information
Submitting a Privacy Request. Privacy requests should be
directed to our privacy team as set forth below. Please keep in mind that
certain Services will not be available if you withdraw your consent, or
otherwise delete or object to our processing of certain personal information.
We will respond to your request in accordance with applicable law, and we will
inform you if we do not intend to comply with your request.
Additional Information for
Users for California Residents. In Section 11 , we provide additional information as
required under California privacy laws. Users in California, should review this
section for more information regarding their rights under these respective
We have implemented
technical and organisational to safeguard the personal information we collect
and process about Users. However, no website, online service, or internet
transmission is completely secure. Thus, we cannot guarantee that unauthorized
access, hacking, data loss, or other breaches will never occur. We urge you to
take steps to keep your personal information safe, such as choosing a strong
password and keeping it private, enabling multifactor authentication (where
available), as well as logging out of your User account, and closing your web
browser when finished using the Services.
INTERNATIONAL DATA TRANSFERS
We have servers, operations
and service providers in the European Union, the United States and other
jurisdictions; some of these jurisdictions (including the United States) may
not provide equivalent data protection laws as your home jurisdiction. We will take steps to ensure that your
personal information receives an adequate level of protection in the
jurisdictions in which we process it, including through appropriate written
data processing terms and/or data transfer agreements where necessary. Such appropriate
safeguards may include standard data protection clauses adopted by a data
protection regulator and approved by the European Commission, such as the
European Commission’s standard contractual clauses, or other appropriate
If you would like to find
out more about these safeguards or if you have any other queries or comments in
relation to this Policy, please let us know by emailing us at as set forth in
the Contact Us section below.
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 email@example.com. We will delete such
information within a reasonable time.
THIRD PARTY LINKS
If you follow a link from
the Service to any third party websites, you should be aware that those
websites may have their own privacy policies. We do not accept any
responsibility or liability for those websites. Please check the policies of
any third party websites before submitting any personal data to those websites.
We may make changes to this
Policy in the future, which will be posted on this page. You should check this
page from time to time to ensure you are aware of any changes. Where
appropriate we may notify you of changes, such as by email.
contact us regarding this Policy or submit a privacy request to us at:
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Below, we provide information, as required under California privacy
laws, including the California Consumer Privacy Act ("CCPA"),
which requires that we provide California residents certain specific
information about how we handle their personal information, whether collected
online or offline. This section does not address or apply to our handling of
publicly available information made lawfully available by state or federal
governments or other personal information that is subject to an exemption under
Categories of Personal Information We Collect and Disclose. Our collection, use and disclosure of personal information about a
California resident will vary depending upon the circumstances and nature of
our interactions or relationship with such resident. We may collect personal
information from the following sources:
Our affiliates and subsidiaries
Third-party sites and services
Internet service providers
Operating systems and platforms
Our vendors and service providers
The table below sets out generally the categories of personal
information (as defined by the CCPA) about California residents that we may
collect, sell, and disclose to others for a business purpose. We collect and disclose
this personal information for the purposes described in Section 2 and Section 3
of this Policy. We do not sell the personal information of California
|Personal Information Collected||Categories of Third Parties to Whom We May Disclose this Information|
|Customer Records||Includes your account and profile information and customer records that contain personal information, such as username, name, demographics and other characteristics or descriptions, email, address, telephone number, and other contact information, account credentials, communications preferences, billing and payment information, customer service and support tickets and records), and other information individuals provide us in order to register for, access or purchase our Services.||None.|
browsing history, clickstream data, search history, access logs, information
regarding your interactions with our websites, mobile apps and other Services
and our marketing emails and online ads, and other and other usage data
related to your use of the Services, such as language and preferences,
in-game purchases, game-play statistics, scores, persona, achievements, rankings, time spent playing,
click paths, game profile, preferences and friends, as well as your comments,
posts and interactions in forums and communities.||None.|
|Inferences||Includes inferences drawn from other personal information that we collect to create a profile based on your account and activities, that reflect your preferences, characteristics, behavior, attitude and abilities related to the Services.||None.|
California Residents' Rights.
California law grants California residents certain rights and imposes
restrictions on particular business practices as set forth below.
Do-Not-Sell. California residents have the right
to opt-out of our sale of their personal information. We do not sell personal
information about Californi residents. Requests to Delete. Subject to
certain exceptions, California residents have the right to, at no charge,
request deletion of their personal information that we have collected about
them and to have such personal information deleted, except where an exemption
Request to Know. California residents have
the right to request and, subject to certain exemptions, receive a copy of the
specific pieces of personal information that we have collected about them in
the prior 12 months and to have this delivered, free of charge, either (a) by
mail or (b) electronically in a portable and, to the extent technically
feasible, readily useable format that allows the individual to transmit this
information to another entity without hindrance. California residents also have
the right to request that we provide them certain information about how we have
handled their personal information in the prior 12 months, including the:
categories of personal information
categories of sources of personal
business and/or commercial purposes
for collecting and selling their personal information;
categories of third parties/with whom
we have disclosed or shared their personal information;
categories of personal information
that we have disclosed or shared with a third party for a business purpose; and
categories of third parties to whom
the residents’ personal information has been sold and the specific categories
of personal information sold to each category of third party.
California residents may make a
Request to Know up to twice every 12 months.
Submitting Requests to Know and Delete.
Requests to Know and Requests to Delete may be submitted online or by email at firstname.lastname@example.org.
When you submit a request to know or a request to delete, we will take
steps to verify your request by matching the information provided by you with
the information we have in our records. You must complete all required fields
on our webform (or otherwise provide us with this information via the above
email address) and verify your access to the registered email address for your
account, in order to verify your request. In some cases, we may request
additional information in order to verify your request or where necessary to
process your request. If we are unable to adequately verify a request, we will
notify the requestor. Authorized agents may initiate a request on behalf of
another individual by contacting us in writing at the contact information set
forth above, in Section 13. Contact Details; authorized agents will be required
to provide proof of their authorization and we may also require that the
relevant consumer directly verify their identity and the authority of the
authorized agent. We will respond to verifiable requests received from
California residents as required by law.
Right to Non-Discrimination. The CCPA prohibits
discrimination against California residents for exercising their rights under
the CCPA. Discrimination may exist where a business denies or provides a
different level or quality of goods or services, or charges (or suggests that
it will charge) different prices, rates, or penalties on residents who exercise
their CCPA rights, unless doing so is reasonably related to the value provided
to the business by the residents' data.
Financial Incentives. California residents have
the right to be notified of any financial incentives offers and their material
terms, the right to opt-out of such incentives at any time and may not be
included in such incentives without their prior informed opt-in consent. Where
we offer any financial incentives under the CCPA, we will notify you in advance
of the material terms of such incentives and your related rights, before we
obtain your consent to such incentives.
For more information about our privacy practices, you may contact us as
set forth above, in Section 12.