SFB: Apple Arcade Privacy Policy

Last updated: 16/09/2019

1.      About Us. We are SFB Games Limited (incorporated and registered in England and Wales with company number 08072089) of Unit 119 The Light Bulb, Filament Walk, London, England, SW18 4GQ (“SFB”).

 

2.      Which services does this Privacy Policy apply to? Our game ‘Tangle Tower’ on Apple Arcade (“Game”).

 

3.      What about GDPR? We respect your right to privacy and will only process personal data in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal data contained in this Privacy Policy which is used by SFB in connection with the Game, SFB is the data controller.

 

4.      What about children? We recognise we have a special obligation to protect personal information obtained from children. We do not collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact contact@sfbgames.com.

 

5.      What information does SFB collect? We will not collect any personal data from you unless you send this to us yourself (e.g. if you contact our support team at contact@sfbgames.com, we will collect your email address and any other details you provide). We may receive some anonymous, aggregated metrics about when and how you access our Game from Apple, but none of this will allow us to identify any particular user. We will not receive or store any of your payment details.

The Game collects non-personally identifiable data and stores it on Apple services such as iCloud for game saves and Game Center for achievements. We collect a limited amount of gameplay data, such as the rooms you have visited or the characters you have spoken to in the Game. We do not store personal data on our servers.

 

6.      Where will your information be stored? Our contact email is operated through Gmail and any emails will be stored on Google’s servers, which may be inside or outside the EEA. Google’s GDPR policy is set out here: https://cloud.google.com/security/gdpr/. Google operates under model contract clauses: https://cloud.google.com/security/compliance/eu-mcc/. We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

 

7.      How might your information be used? We will only use personal data you provide to us in order to communicate with you to try and resolve any questions or issues you may have. The relevant GDPR basis for this will be our ‘legitimate interest’ since we want to provide the Game to you free of issues.

 

8.      Will we ever share any of your information with other parties? We will not share your data with any third parties.

 

9.      How will your information be stored? We will only store your personal data for as long as is necessary for the purpose for which the data was originally collected (e.g. once we have resolved your customer support issue we will delete any data you provided to us).

 

10.   What are your rights? You have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. If you would like to exercise any of these rights or have any queries regarding them, please contact: contact@sfbgames.com.

 

11.   Will we ever change this Privacy Policy? Possibly, but if we do we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy it will become legally binding on you as of the date of publication (i.e. the new “Last Updated” date). You are welcome to contact us if you have specific questions about the changes at contact@sfbgames.com.