Effective date: December 16th, 2020
THIS IS A LEGALLY BINDING AGREEMENT BETWEEN YOU AND EVERGUILD. BY USING OUR SERVICES, YOU ARE EXPRESSING YOUR AGREEMENT TO THIS POLICY.
Please note that this Policy applies only to information collected by Everguild through your use of Our Services. Everguild is not responsible for the actions of any third party, including their use of information you provide to them. Any link to the site or service of a third party does not imply that Everguild is affiliated with or sponsors that third party.
For the purposes of the GDPR, the data controller is Everguild Ltd., which is a limited liability company registered in England and Wales under company number 09334050. Our registered office is 20-22 Wenlock Road, London N1 7GU. You can contact us by email at firstname.lastname@example.org.
Information we may collect
We may collect and process the following data about you when you use Our Services:
- If you choose to contact us, including via our Sites, we will collect your contact details (for example your name and e-mail address) together with the details of the message/correspondence in question.
- If you choose to register for any of our Games then we will collect your e-mail address and subsequently your chosen user name and password for your account (your “Account”).
- When you use any of our Games, information about how you use our Games is recorded and provided by our internal tools, third-party analytics and advertising services (such as Playfab and Adjust) and any platform providers (such as Apple, Google, Kongregate and Steam). This includes technical information such as your device specifications, device ID, device advertising identifiers, statistical data regarding your gameplay and content that is created and shared by you with other players and as described further in the “Third-Party Service Providers” section below.
- When you use any of our Games, anonymised location data (country and city) as determined by third-party services using a truncated version of your IP address.
- When you use any of our Games, account IDs of any networks that you log into and associate with your game save. This includes Google Play, Game Center and Steam. The account IDs are used to ensure that your game save is backed up and can be recovered should you change or lose your mobile device. We do not receive your password, credit card number or other financial information from these networks.
Google Play Games Services, Game Center, Facebook and Twitter
Everguild may offer you the option to connect your Account to your account in Google Play Games Services, Apple’s Game Center, Facebook and/or Twitter (each of them a “Third Party SN Service”). Everguild may collect and record certain information from your profile and account in the Third Party SN Service, in accordance with the terms and policies of the Third Party SN Service. The information we collect in this manner may include your name as provided by the Third Party SN Service, your profile picture or its URL, your user identification number in the Third Party SN Service, the user identification number of your friends who are also connected to Everguild’s Service, your gender, and your birth date. Your nickname in Google Play Games Services or in Apple’s Game Center may be used as the profile name for your Account in Our Services, and be visible to other players. The remaining information may be used to analyze user trends and improve Our Services, to connect you in Our Services with your friends in the Third Party SN Service who are also using Our Services, and to offer you targeted recommendations and promotions from time to time.
We may offer you the opportunity to invite your friends in the Third Party SN Service to join Our Services, or to post content from Our Services into the Third Party SN Service. Your explicit permission will be requested every time before any information is posted or any invite is sent in the Third Party SN Service.
You may contact us at any time to request that we delete from our records all information relevant to you obtained by us from Third Party SN Services, by contacting us at email@example.com.
Third-Party Service Providers
Our Games may contain certain software development kits (“SDKs”) from third party service providers which provide services required by Everguild to provide its products and services. These third party service providers provide services such as back-end management, analytics, attribution and/or advertising, and use the SDKs in Our Games to collect information about you in order to verify information such as the number of installs and advertising performance. This information may include your UDID, IP address, geo-location and OS information.
The third party service providers we use are:
Adjust (for attribution services, which also passes through information relating to Facebook). For more information about Adjust’s use of your data, please see https://www.adjust.com/privacy-policy/
Steam (when you use our Services on a PC or Mac). For more information about Steam’s use of your data, please see https://store.steampowered.com/privacy_agreement/
Photon Engine (for matchmaking and chat services). For more information on Photon Engine, please see https://dashboard.photonengine.com/en/Account/PrivacyAndCookiePolicy
Google Firebase (for analytics, ads and other features). For more information about Google Firebase, please see https://firebase.google.com/support/privacy
Mailchimp (to manage our electronic marketing campaigns, if you have consented to these by subscribing to our newsletter). For more information about Mailchimp, please see https://mailchimp.com/legal/privacy/
DeltaDNA (for analytics) (if you play Legions). For more information on DeltaDNA, please see https://deltadna.com/privacy/
Helpshift (for customer support) (if you play Legions). For more information on Helpshift, please see https://www.helpshift.com/legal/privacy/
We provide certain parts of Our Services via third party marketplaces, such as Google Play, Apple’s App Store and Valve’s Steam. By using Our Services, these marketplaces may collect information about you. Everguild is not responsible for these marketplaces, and is not affiliated with or responsible for their actions. You should review these third parties’ terms of service and privacy policies, which are separate from Everguild’s.
How we use Personal Information
We use the information collected above in the following ways:
- If you choose to contact us, to respond to the question(s) that you raise when contacting us.
- If you choose to register for any of our Games, to verify your identity and allow you to access your Account and to the features of Our Services that require such account registration.
- To, in connection with the various analytical information, including anonymised location data, understand how users use our Games.
- To, where you choose to make use of the Third Party SN Service, allow us to ensure that your game save is backed up and can be recovered should you change or lose your mobile device as well as to allow you to participate in interactive features of Our Services, when you choose to do so.
- To, subject to obtaining your consent to the same: (a) use your e-mail address to provide you with information, products or services that you request from us or which we feel may interest you, including our newsletter; and (b) carry out re-engagement campaigns via advertising based on device advertising identifiers.
- To, in certain instances, notify you about changes to our service.
Where we store your personal information
The information that we collect from you may be transferred to, stored and processed at a destination outside the European Economic Area (“EEA”) (including the USA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services and the processing of your payment details. Where we transfer your personal information outside the EEA we have put in place appropriate adequacy procedures to ensure that such transfers are GDPR compliant. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy.
By submitting your personal data, you agree to this transfer, storing or processing. All information you provide to us is stored on our secure servers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our servers via any of Our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We are not responsible for the activities of other users or other third parties whom you choose to provide your information to or otherwise interact with via Our Services.
Legal basis for processing
We rely on the following processing grounds to collect and use the information listed above:
- the processing is in our legitimate interests, subject to your interests and fundamental rights, and notably our legitimate interest in using applicable data to conduct and develop our business activities; or
- you have consented to the processing (in the case of providing you with information, products or services that you request from us or which we feel may interest you, including our newsletter or presenting targeted adverts to you).
We will store personal data as long as is required for the relevant business use cases. Typically, this will be the life-span of the Games or Sites but may be longer – but not longer than 2 years after the Game or Site is no longer supported. The exception to this is if we are required to store data for legal purposes. After this period of time we will securely delete or anonymize data.
Disclosure of your Personal Information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
- If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce and other agreements; or to protect our rights, property, or safety of our customers or others.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Everguild Ltd. or substantially all of its assets are acquired by a third party (in which case personal data held by it about its customers will be one of the transferred assets).
We may also share your non-personal information with third party partners who work with us to provide the Services to you (for example, third party developers who we’ve worked with to create one of our games). These are as described in the sections “Google Play Games Services, Game Center, Facebook and Twitter” and “Third-Party Service Providers” above.
Information about children under the age of 14
Under Everguild’s Terms of Service, children under the age of 14 are not allowed to register or use Our Services. We do not knowingly collect or solicit personal information from anyone under the age of 14. If you believe that we have collected any information about a child under the age of 14, please contact us as soon as possible at firstname.lastname@example.org. If we learn that we have involuntarily collected information about a child under the age of 14, we will delete that information as soon as possible.
You can contact us at email@example.com if you wish to: (a) access a copy of the personal information that we hold about you; (b) correct any items of personal information that we hold about you; and/or (c) have any items of personal information that we hold about you erased or object to our processing of such items of personal information.
If you request us to delete all of your information, your Account may become suspended and deleted. You may opt-out of receiving promotional emails from us by following the instructions included in those emails. If you opt-out, we may still send you non-promotional emails, such as emails about your Account or our ongoing business relations.
Modifications to this Policy
We may modify this Policy from time to time. We will post all changes to this Policy on this page and, where appropriate, notify you by e-mail. The modified policy will specify its effective date. Any changes to the Policy will be effective when posted.
We welcome any questions, comments and requests regarding this Policy, which should be addressed to: firstname.lastname@example.org
You also have the right to make a complaint to the ICO by contacting them at any time at: https://ico.org.uk/global/contact-us/