Apple Arcade Privacy Policy
1. Introduction, who we are and how to contact us
Thank you if you are going to download or have downloaded one of our games!
Who we are
We are Playstack Ltd, a company registered in England at 56A Poland Street, London, W1F7NN, United Kingdom and company number 10168633. We are the data controller (the company which is ultimately accountable for the processing of the information we collect about you under this Privacy Policy) and we are registered with the Information Commissioner (ICO) in the United Kingdom. If you have questions about this policy or would like to exercise your legal data protection rights, you can always contact our friendly data privacy manager by emailing them at data@playstack.com.
Why you need to read this
It’s a bit like telling you to eat your vegetables. We want to do what’s best for you. When you download or use our games or otherwise talk to us, you will be giving us your information that personally identifies you in a variety of ways as described in this policy (your ‘personal data’). This isn’t about giving you the small print. It is our commitment to you that we want to protect and respect your privacy. We want to try and make it as clear as possible to you what you are agreeing to when you download our game. If you have any questions, just email us at data@playstack.com and we will try and answer them!
This policy (together with our terms of use and any other documents referred to in them) sets out the basis on which we will use, store, collect, disclose and transfer (process) your data.
Where we ask for your permission to process your data, please remember you can decline to give it and you can change your mind later and withdraw it. When we ask for your permission, we will always explain the consequences of withdrawing it (e.g. if it affects gameplay).
Changes to this Policy
We may need to update this Policy at any time to reflect changes in our business. All changes will be flagged in the app and if we consider it appropriate, we will notify users of important changes by email or in-app too.
Children
Our App terms require users to be 13 or over. You do not need to create an account with us in order to play the game, however you will need a Gamecenter ID.
We do take precautions to ensure that risks to any unauthorised users being minors are limited.
If we discover any users not meeting our age requirements, we may take all such action as we deem appropriate as explained in our terms including the termination of your account and deletion of your data. If you are a parent and have discovered your child is using one of our Apps, please contact us at data@playstack.com and we will help you.
2. What information will you collect about me and why do you need to use it?
What information do we collect?
We collect and use obvious information you give us. This is information about you that you give us directly when you:
- fill in your user profile (your Gamecenter ID will be used as a default in all Apple Arcade games);
- provide any user generated content (where this feature is enabled in-app); or
- talk with us by phone, e-mail or otherwise (for example if you report a problem with the game).
You know what information you are giving us and why we need the information as you are filling in the forms and requesting us to do things for you! But as a gentle reminder, this may include:
- Identity Data – data we need to know to set up your account and enable gameplay (We will ask for your Gamecenter ID).
- Contact Data (the information you give us to contact you like your e-mail address and phone number for example if you would like to communicate with us for troubleshooting purposes)
- Profile Data (your username and password, your preferences, in-game progress and gameplay/settings, in-game friends, feedback and other information you give us such as the contents of any correspondence you have with our customer support or technical teams)
- Location Data – Our app does not use Location Data.
Why do you use this obvious information?
We use the obvious information you give us to perform our contract with you and to provide you with the App. Basically to do what you are asking of us. We need this data to administer your account registration and to provide services that you have asked us to provide to you. It also allows us to create in-App gameplay.
In addition we may use the following:
- Game Progress Data – meaning non-personal gameplay data, such as character and level progression and achievement tracking (“Progress Data”)
- Device ID – specific to Progress Data for internal operations of the game
- Game Crash Data – When a game crash occurs we collect data related to that crash and store it locally on your device. This data is transferred to our servers upon your consent and used to help find the source of the error.
- Game Save Data, along with a Device ID, is sent to Apple for Game Center achievements, leaderboards and to iCloud for storage. Game Save Data is also stored locally on your device used to access the Service. In some jurisdictions, Game Save Data or a Device ID may be considered personal data either because it can be combined with more specific personal data linking such data to a particular person or household or because it actually is, or is linked with, personal data associated with a particular person or household.
When a game is provided via Apple Arcade we collect your gameplay or crash data on our severs in AWS cloud.
We do not use your data for other purposes unconnected to providing you with the Game. For example, we do not use in-game analytics or use your data for our marketing purposes. You may, on occasion, see advertising from Apple relating to its products and services which forms part of the Apple Arcade experience. If you have any questions relating to this, please visit your Apple Arcade settings.
We may combine the obvious information with other less obvious technical types of data we collect about you such as data about your device and how you use our app (we’ve explained this a bit more below) and together this data helps us personalise your experience with us and remember your user settings and preferences. This is to perform the contract we have with you for the services you have requested and for good business reasons to ensure our apps are meeting your needs.
We also collect less obvious information about you and here’s why
Each time you download or play one of our games, there is some clever stuff going on in the background telling us about your use of our services and this includes some automatic data capture. Some of this happens when you download and open our app even if you have not set up an account or signed in.
We call this clever information we learn about you ‘Technical Data’ and ‘Usage Data’. We’ve set out in full the different types of technical data we collect about you here. We only collect and use this type of data where we need to in order to provide you with the service you have requested from us and have assessed again that there are good business purposes for doing so – for example that we need this information to provide you with troubleshooting and customer support and to keep our apps safe and secure, to improve our games and how the games appear to you, track how you played our games and used our apps so we can improve the player experience, provide you with the service as you want it, and to ensure you don’t receive marketing stuff.
We do not use cookies or other online identifiers.
In case you are interested (you’re probably not), your Technical Data boils down to: the IP address used to connect your device to the Internet, device unique ID, log in data (e.g. dates and times you interact with our app), your in-app actions, such as features and products you viewed or searched for in-app, response times, errors, app interaction information (such as scrolling or taps), the operating system, platform and device model you are using, other technology/apps on the device you are using including SDK version, timestamp, API key, application version, device identifier, locale (specific location where a given language is spoken), time zone, mobile network and network status (WiFi, etc.), general location information (not sufficient to derive city and street names), connection type (e.g. mobile data or WiFi), access status/HTTP status code, browser information (language, type and version and plug ins).
Sensitive Data
We do not collect any sensitive categories of personal data about you.
3. Data Sources and Data Sharing – Do you exchange my personal information with any third parties?
Apple Arcade: We share anonymised gameplay data with Apple Arcade. This does not identify you by name but instead tells Apple Arcade how many users have downloaded and played the game and also tells them about your achievement tracking and level progression for the Apple Arcade Game Center achievements and your iCloud storage.
Service Providers: We also share your data with our essential service providers who need to process it in order for us to provide you with our services and the App. For a list of these please click here. These third parties are our ‘data processors’ and we will always oblige them to protect your data in accordance with the law whenever they process it.
Group Companies: In addition, we have some corporate stuff to tell you about. We hope we will grow big. So eventually, we may have a number of different group companies (we will all be ultimately owned by the same company though). If this happens, we may want to share your information around our group so they can use it for the same internal purposes as we do and described above (for example we might want to store our data on one server or have a group wide troubleshooting team or other shared internal support services). We will only do this where we have assessed this as being for our good business reasons and where this does not unfairly compromise your privacy (legitimate interests). It is also possible we could sell our business to a third party or re-organise our business or become insolvent. In that scenario, our data is part of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business.
A full list of our group companies and their locations is here.
Law enforcement: We will cooperate with all third parties to enforce their intellectual property or other rights as appropriate. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. Our legal basis for using this data is to comply with a legal or regulatory obligation or where it is in the legitimate interests of protecting our or others’ rights.
4. Overseas transfers
Where do we store your personal data and for how long?
Our backend servers are located in Ireland, Germany and the United Kingdom. We will ensure that adequate safeguards are in place to protect these transfers. For a list of our group companies and their office locations, please click here.
We use essential third party providers to collect, export, process and store personal data on our behalf and some of these are located outside the UK and/or the EU. We only use data processors which we consider meet the minimum legal requirements required to protect your data and we ensure that applicable safeguards are in place to protect your data whenever it is sent overseas or shared with those processors. For a list of third party processors and service providers: click here. This list is updated from time to time. If you require further information about these data processors, please contact data@playstack.com.
Apple Arcade may have locations outside the UK and/or the EU. Please check their terms for details of their locations.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the applicable regulators or where there are adequate safeguards in place. For certain data transfers, we may use specific contracts approved by the applicable regulators which give personal data additional protections.
Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data overseas.
5. How long do you retain my personal data?
We only store your data for as long we need it for the purposes for which we collected it in the first place. Storing data costs us money! We will generally store your data while you keep a copy of the App on your device. However, the law requires us to delete your data after it is no longer needed and so we use internal processes to assess when this might apply – e.g. when you have been an inactive customer for two years or when we consider that the risk of any legal claim is negligible. If we regard you as an inactive user, we will delete your personal data except where retention is necessary to enable us to enforce our legal rights, to comply with any laws or regulation or to protect the rights, property or safety of our employees.
We will also delete your data on your request though we may hold a list of the ‘opt out’ requests to administer your request. Please contact us at data@playstack.com for details of our data retention policy.
6. Security – Being safe and how we protect your data
We have put in place appropriate technical and organizational security measures that are designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. These measures include data encryption for communications between device and data centres, hardened security zones and restricted access policies. Where we keep your personal data files on local devices these devices are protected by various security measures including app packaging security requirements for publishing to App Stores, and the hardware security native to the device. We regularly review our security systems to ensure that your personal data remains safe and secure.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach.
Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee that data breaches will never occur. Please keep your password safe at all times and log out of inactive sessions.
For safety purposes, we may require players to verify their identity such as their age or email address. Don’t worry! This is only to make sure you are not a robot and that you stay safe online. We won’t use this information for unexpected reasons.
We also do not recommend that you put email addresses, URLs, phone numbers, full names or addresses, credit card details or other identifying or sensitive information in any online chat function or profile.
7. Your legal rights
Your device settings will allow you to view and adjust your privacy settings for our apps and depending on your device software, may ask you to confirm privacy choices when you first download our apps. In addition, please note you have the following legal rights (these may or may not apply to you depending on your jurisdiction):
Right to be informed and of access. You have the right to be informed what data we hold about you and you can ask us for a copy of your personal data. To do this please contact us at data@playstack.com. Please note that we may ask you to specify what you wish to see in order to focus our search.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at data@playstack.com and we will correct it as soon as we can.
Data deletion/Right to be forgotten. In some circumstances you have a right to have some of the personal information that we hold about you deleted where this is no good reason for us continuing to process it or where you successfully objected to our processing or where we have processed your data unlawfully or are required to erase it to comply with local law. Should you wish to have any information about you deleted, please let us know at data@playstack.com. Please note that in order to process your request you must delete our games from your mobile devices. We may not always be able to comply with your erasure request for specific legal reasons which will be notified to you if applicable at the time we respond to your request. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a Wi-Fi network.
Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller in a machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the automated information to perform a contract with you.
Restriction of processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (if you do not feel they are legitimate) or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to still process your information which override your rights and freedoms. But we will only rarely rely on that option if we absolutely need to because we respect it is your data after all!
Right to withdraw consent. Consent isn’t a one-off thing. If you give it to us you can have it back! If you want to withdraw your consent for any use of your data just email us at data@playstack.com. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you do withdraw your consent, this may impact your experience of our apps and we will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our data privacy manager.
We may charge a reasonable administration fee if allowed by applicable law.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.
We will respond to all legitimate requests within one month.
8. Complaints
You may complain to your local supervisory data protection authority about us depending on where you are located. In the UK, please read: ico.org.uk/make-a-complaint for details of how to do this.
9. Contacting us
If you need to get in touch you can do so either by email to: data@playstack.com, or in writing to Data Compliance Officer, Playstack Ltd, 56A Poland Street, London, W1F7NN, United Kingdom; and please ensure you include specific details on your request and the best way for us to get back in touch.
That’s it!
Well done! You’ve read the whole thing, or just skipped to the end. Remember that this document is here to help you understand our commitment to protect your data and privacy, and to ensure you know how we are using any information we collect or need to store. If you have any questions or need more information, please do get in touch.
Last Update: April 2023
