At Ultimate Studio Pty Ltd (Australian Business Number: 98 624 326 389) (defined here as ‘We’, ‘Us’ or ‘Our’), We recognise the importance of your privacy and understand the concerns surrounding security of personal information.
This policy will let you know:
What information (often referred to as ‘data’) is collected from you by Us;
How your information is used;
With whom your information may be shared;
How you can access, update, or delete your information.
We will comply with all relevant and applicable legislative requirements, and, in the event of any inconsistency, the legislative requirements will override the provisions of this document.
How do We use the data We collect?
No matter how We come to collect your data, We will always treat it in accordance with this document, and any applicable legislation.
What types of data are there, and what do we collect?
Data collected can be personal to you, or non-personal. Sometimes data that doesn’t appear to be personal can become personal if certain other facts are learned.
Data can be collected in three ways:
A. Data collected automatically;
B. Data you provide Us; and
C. Data collected by Our partners.
Our basis for collecting these types of data is a “legitimate interest” under GDPR (Global Data Protection Regulation) and “to support internal operations of the game” under COPPA (Children’s Online Privacy Protection Act).
Any data collected is done solely for internal uses that are reasonably and directly related to your relationship with Us, in accordance with the California Consumer Privacy Act (CCPA).
A. Data collected automatically
Certain data is collected automatically. This includes:
- Your device identification number, and data about your device, such as device name and operating system, and language;
- Data about your use of Our Game, by which we mean gameplay data that is for data saving/loading game files.
- Your IP addresses, and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI). Please note, there are ways to prevent this, which are outlined at ‘Third Party Service Providers’ below.
B. Data you provide Us
We collect and store your email where you nominate to specifically allow Our games to collect your player name and your email. We will also keep your contact details if you contact Us for a particular purpose.
If you contact Us with a message through Our support system, We keep a copy of any personal information you provide. This is so that We can respond to your comments and questions as a part of Our commitment to providing you with player support. If you contact Us directly for any reason, We also keep a copy of that correspondence.
You may unenrol from the Playtesting Program and Our mailing list at any time by giving us written notice at the following address: firstname.lastname@example.org.
What is Personal Information?
‘Personal Information’ is information that identifies you as an individual. The Game will automatically collect your device identification number, solely so that the Game can operate effectively on your device. This information is anonymised prior to being viewed by Us, and never sold or shared.
Personally identifiable data will only otherwise be actively collected by Us in very specific circumstances, such as if you contact Us directly.
What about Sensitive Information?
Sensitive information includes information about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a professional body, criminal records or health information.
We will not attempt to obtain or record any sensitive information.
C. Data we collect from our third-party providers.
Collection of other ‘Non-Personal’ Information
Some non-personal information may be gathered while you use Our Game. Non-personal information is general, non-identifiable and anonymous information that is gathered for statistical, analytical and research purposes such as the improvement of our games (for example, bug fixes).
Our third-party providers, and their privacy policies are as follows:
- Apple: https://www.apple.com/legal/privacy/
- Unity Analytics and Unity Crash Reporting: https://unity3d.com/legal/privacy-policy
- Steam Store: https://store.steampowered.com/privacy_agreement/
- Playfab/ Microsoft Azure: https://www.microsoft.com/en-us/trust-center/privacy/gdpr-faqs
- Google (Analytics and Google Play): https://policies.google.com/privacy?hl=en-US
- Facebook: https://www.facebook.com/privacy/explanation
- Appsflyer: https://www.appsflyer.com/services-privacy-policy/
Access to Your Data, and Permanent Deletion of Your Data
Regardless of how We come in contact with your data, you have the right to request access to any personal information We hold about you. You may request access to the information We hold about you by contacting Us via email at email@example.com. If at any time you believe that personal information about you is incorrect, incomplete or inaccurate, you may request that We amend such information. If We refuse your request, We will provide you a written notice which will outlines the reasons for such refusal and the complaint mechanisms available to you.
You may also request that We delete any personal information We hold about You by contacting Us via email at firstname.lastname@example.org.
Data Subject Requests
In the event that you send a data subject request to Us, or one of Our third-party partners informs Us that you have contacted them directly about your personal data they collected while you were using Our service, We will respond to that request in accordance with any applicable legislation.
If you wish to know what data We hold about you, if any, please make out your request to Us in writing at the address listed below. Please be aware that in order to protect the information in Our database, We will require identification from you before releasing any information.
Disclosure and Security of Your Information
We will not sell, trade, rent or disclose any of the personal information you provide to Us for any reason, without your prior consent. Otherwise, your Personal Information will only be disclosed where required or allowable by law.
Your Personal Information is stored offsite in a manner that reasonably protects it from misuse, loss, unauthorised access, modification or disclosure.
International Transfers of Your Information
Given that our Game is globally accessible, there are times where your data may need to be transferred across different jurisdictions. However, we will not transfer your personal information across jurisdictions, unless:
- You have provided your consent; or
- It is necessary to complete a transaction in Our Game; and
- We believe that the recipient of such information is subject to a law, or a binding scheme, that has the effect of protecting your information in a way that, overall, is at least substantially similar to the way in which the Australian Privacy Principles (APPs) protect information; and there are mechanisms you can access to take action to enforce that protection of the law or binding scheme; or
- Where otherwise allowed by any applicable legislation.
We will always keep this up to date so that you know what information We will collect from you, how We may use it, and when We may disclose it.
Office of the Australian Information Commissioner
Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749
TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls)
TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)
Post: GPO Box 2999 Canberra ACT 2601
Fax: +61 2 9284 9666
Ultimate Studio Pty Ltd © 2023