PRIVACY AND DATA POLICY

ISSUED BY CHUCKLEFISH LIMITED

Last Updated:  19 August 2019

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed and/or published by Chucklefish Limited. (“Chucklefish / we / us”). Our registered office is at 64 Southwark Bridge Road, London, SE1 0AS.

We are a company registered in England, with company number 07664836.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games, our websites including without limitation (together known as the “Website”) and any of our online communities (“Communities“):

inmostgame.com

Together the Game(s), the Website and Communities are referred to herein as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at [[email protected]]

We are committed to protecting and respecting your privacy.  This Privacy Policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

This Privacy Policy should be read in conjunction with, our terms of use applicable to the Game, Website or Communities located on the relevant website as set out above. 

The Online Services may contain hyperlinks to services owned and operated by third parties.  These third party services may have their own privacy policies and we recommend that you review them.  They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services.  We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in 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 by email or through the Game or Community.

  1. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information, which may include your personal data.

Information provided by you when using an Online Service

(“Information”)

We will collect personal information from you when you use our Online Service or when you contact us for support: 

This may include:

      • Your name;
      • Your address, telephone number and email address; and
      • Your Steam ID and Steam profile/display name.
Information about your gaming and activity 

(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following: 

      • your IP address and MAC address;
      • device information (e.g. device identifier and browser)
      • game results, progress and timings; and
      • page usage (e.g. buttons clicked, screens viewed). 

This also includes the use of ‘cookies’.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Chucklefish uses cookies to help Chucklefish identify and track visitors, their usage of a Chucklefish website, and their website access preferences. 

The following cookies are used on the Websites: 

Cookie Name Description Link

Google Analytics Google Analytics is a service offered by Google that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sale http://www.google.com/analytics/

Gravatar Gravatar is a service that allows an image to follows you from website to website appearing beside your name when you do things like comment or post on a blog https://en.gravatar.com/

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. To opt out of being tracked by advertising providers you can access a general opt out at http://www.networkadvertising.org/managing/opt_out.asp

Information about you collected from third parties 

(“Content  Information”)

We may collect information which you make available to us via your various profiles, including your Steam account. 

 

  1. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Games to you 

To enable operation of the Game 

We will use information about you (including Information and Analytics) to deliver our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly.

To enable in Game purchases 

If you make purchases through the Online Services, your order and Information may be processed so that you can access these features within the Games. 

To provide the Communities and Preventing Spam

Certain Content Information and Information which you supply through our Online Service will be shared with other users of the Online Service.  In some cases you may be able to select specific recipients (for example if you are sending a forum post, or a private message, to a particular forum or individual) then only those recipients will receive it, however in all other cases, your information may be made publically available.

We may make your Content Information and Information available to forum moderators. Moderators are crucial to the Communities and help make them the place that they are. Moderators are directed to only act in accordance with our instructions and to adhere to the moderator rules.

Spam is a problem for many forums and websites. In order to minimise this we use Stop Forum Spam to check that any new registration is not spam. In order to do this certain information is provided to Stop Forum Spam for the sole purpose of checking that it is not spam. You can find out more about how Stop Forum Spam use this information on their website available here: https://stopforumspam.com/privacy

To respond to your enquiries and requests for support 

We may process Information and Content Information so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us.

As part of this we may share this Information and Content Information with the developers of the Games that we publish.

For advertising purposes

We may process Information, Analytics and Content Information to show you advertisements for third party services. Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not Chucklefish.

Analytics information may be shared with advertisers on an anonymous aggregate basis.  We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data.

Our Online Services integrate with AdSense, Google Analytics and GG Software.  Analytics data will be processed and tracked by those third party services, and you can find out more about the way they use this information at the following locations: 

To keep you up to date

We use your Information to send you emails in order to keep you informed of news and products. To do these we use our internal process and may use Mailchimp. You can find out more about how they process personal data here: 

 

  1. DATA SHARING
We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information 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 in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

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 Chucklefish, our customers or others.

Digital Content Stores:  The Games are made available to download via Steam and we may disclose your personal information to Steam for the purposes of making the Game available and facilitating any in-Game payments made through Steam.

 

  1. AUTOMATED DECISION MAKING
We may automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

For instance we use StopForumSpam and if the new user is flagged as spam the user will be informed of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision. If this applies to you, please contact us at [email protected]  

 

  1. CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act.

We therefore will not distribute your personal information to outside parties without your consent.

As part of the California Online Privacy Protection Act, all users of our Websites may make any changes to their information at any time by logging into their control panel and going to the ‘Edit Profile’ page.

  1. CONSUMER CONTROL AND OPT-OUT OPTIONS

Where you have linked your Steam account to any of your social media accounts, you can unlink these at any time by adjusting your settings in Steam.

You can also remove access in your social media settings. If you are using an iOS device, you can opt out of personalised adverts by visiting https://oo.apple.com

We will obtain your consent to collect your information to be used for marketing purposes that require consent. If you prefer that we do not use your data in this way, let us know by writing to [email protected] or by checking boxes on the forms we use to collect your data.

  1. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below.  We aim to comply without undue delay and within one month at the latest.

To make a request, please let our Data Protection Officer know via [email protected]  

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

You can download a copy of your Game account information by following the instructions in your account settings. 

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing or delete your personal data if:

  • you consented to our processing the personal data and have withdrawn that consent;
  • we no longer need to process that personal data for the reason it was collected;
  • we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Chucklefish or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed;
  • you need the personal data to be deleted in order to comply with legal obligations;
  • the personal data is processed in relation to the offer of a service to a child.

You can delete your accounts by following the instructions in your account settings. 

Obtain a machine-readable copy of your personal data, which you can use with another service provider

  • If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
  • If you request, we will supply you with the relevant personal data in CSV format.  Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority

  • If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
  • If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

 

  1. APPLE ARCADE

If you play the Inmost Game through the Apple Arcade, please note that Chucklefish collect and store no information on players of Inmost through the Apple Arcade. While playing Inmost certain data and information maybe be collected and stored by Apple, Inc. (and/or its affiliates or group companies) and the services it provides (for instance, Game Center). For information on data stored by Apple services, please refer to Apple’s privacy policy as made available via: https://www.apple.com/apple-arcade/ and/or https://www.apple.com/legal/.   

If you want to contact us for customer support please contact us at our customer support website or [email protected] Please note that any information provided through or in connection with customer support and our customer support websites is collected as part of that website and will be in accordance with this Privacy Policy for our support services.

  1. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

  1. CHILDREN

We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13.  Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at [email protected]  

  1. SECURITY

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Online Services; any transmission is at your own risk

  1. INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of the Service, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. You have the right to ask us about the safeguards we have in place for the purposes of international data transfers. To do so, you can contact us at [email protected]

  1. CONTACT INFORMATION

All questions, comments or enquiries should be directed to Chucklefish at [email protected]  We will endeavour to respond to any query or questions within two business days. 

© 2019 Chucklefish Limited.  All trade marks are the property of the relevant owners. All rights reserved.


Apple Arcade Privacy Policy

PRIVACY AND DATA POLICY

ISSUED BY CHUCKLEFISH LIMITED

Last Updated: 16 September 2019.

1. INTRODUCTION AND GENERAL TERMS

This privacy and data policy applies to the use of the game “Inmost” (“Game”) available on Apple Arcade published by Chucklefish Limited. (“Chucklefish” / “we” / “us”). Our registered office is at 71 Queen Victoria Street, London, United Kingdom, EC4V 4BE.

We are a company registered in England and Wales with company number 07664836.

If you have any questions or comments about this Privacy Policy, please contact us at [email protected] or if you need support for the Game the you can contact the developer Hidden Layer UAB at [email protected] 

We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through the Game is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018.

You have the right to object to the processing of your personal data in certain circumstances. Information on your right to object, and your other rights, is set out below.

Please read this Privacy Policy carefully as it contains important information about the following:

This Privacy Policy should be read in conjunction with such Terms of Use as may be applicable in respect of the Game. Where Terms of Use are applicable, they will be made available via the Game.

We do not accept any responsibility or liability for the privacy practices of third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Game.

2. INFORMATION WE MAY COLLECT ABOUT YOU

The Game collects information about your progression through and achievements in the Game (“Game Progress”). This Game Progress information is not stored by us and is stored on Apple services such as iCloud for game saves and Game Center for achievements. We do not store personal or gameplay data on our servers.

We may collect and process the following personal data from you (together, the “Submitted Information”):

Information that may be provided by you when you contact us for supportYour name; andYour address, telephone number and email address.

3.  WHY WE COLLECT INFORMATION ABOUT YOU

To respond to your enquiries and requests for support We may process Submitted Information so that we are able to properly respond to your enquiries and support requests, in accordance with the Terms of Use as may be agreed between us.For the above purposes, we rely upon the legal basis of performance of a contract and our legitimate interests, being our commercial interests to respond to your queries and requests for support and to maintain good commercial practice in customer service.We may obtain this information from or share it with Hidden Layer who developed the Game for the purposes described above.
To help us to fix any Game problems We may process information about you (being the Submitted Information or any part thereof) so that we can fix Game problems, bugs and defects (for example, if you report a bug to us in your support request).This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Game functions properly so that you and other users have the best experience when, for example, playing the Game; (ii) improving the quality of our Game, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Game.We may obtain this information from or share it with the developer Hidden Layer for the purposes described above.

4.  DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy PolicyGroup members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.Required by law: We may disclose your information 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 in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).Enforcement: We may also disclose your personal data to third parties (e.g. mobile network operators, gaming platform operators, game console manufacturers or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect our rights, property or safety, or those of our customers or others.

5.  YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below.  We aim to comply with requests without undue delay and within one month at the latest.

To make a request, please let us know by email to [email protected]   

Ask for a copy of data we are processing about you and have inaccuracies correctedYou have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.You can download a copy of your Game account information by following the instructions in your account settings. We will use reasonable efforts, to the extent required by law, to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).
Objecting to us processing data about youYou can ask us to restrict, stop processing or delete your personal data if:you consented to our processing the personal data and have withdrawn that consent;we no longer need to process that personal data for the reason it was collected;we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;the personal data was unlawfully processed;you need the personal data to be deleted in order to comply with legal obligations; and/orthe personal data is processed in relation to the offer of a service to a child.You can delete your account(s) by following the instructions in your account settings, where applicable depending on the relevant Game. 
Obtain a machine-readable copy of your personal data, which you can use with another service providerIf (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.If you request, we will supply you with the relevant personal data in CSV format.  Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory AuthorityIf you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

6.  DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person to whom it relates for longer than 180 days following the relevant matter having been addressed and/or inactivity or other cessation of your use of the Game.

7.  CHILDREN

The Game collects, uses, and discloses data from children in the same way as for other users, as described in this policy. The Game’s use of this data is limited to support internal operations of the Game. If you wish for this information to be deleted please contact at [email protected]    

8.  SECURITY

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Game; any transmission is at your own risk

9.  INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of the Service, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at [email protected] 

10.  CONTACT INFORMATION

All questions, comments or enquiries should be directed to [email protected] or for support to [email protected].  We will endeavour to respond to any query or questions within 5 business days. 

© 2019 Chucklefish Limited. All trade marks are the property of the relevant owners. All rights reserved.