Privacy Notice for Game Developers
Effective Date: 21st August 2023
Version: 2.2
Who we are and what we do
We are GameAnalytics ApS, a company registered in Denmark under company number 34043221, with our registered office at Pilestræde 58, 2, 1112 Copenhagen K, Denmark.
Our affiliate, GameAnalytics Limited is a company registered in England and Wales under registration number 09214168, with their registered office at 18 Soho Square, London, England, W1D 3QL.
GameAnalytics Limited is registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number ZA439557.
We are an ‘in game’ analytics service provider, working in partnership with developers around the world to monitor and improve everything about their games.
GameAnalytics ApS, together with its affiliate GameAnalytics Limited, (“GameAnalytics”, “we”, “our” or “us”) is committed to protecting the privacy and security of all Personal Data processed as part of its business activities.
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.
For residents in Mainland China, please read the GameAnalytics China PIPL Privacy Notice at https://gameanalytics.com/legal/pipl-china.
Who this privacy notice applies to
This privacy notice applies to you if:
- You visit our website
- You register and/or create a GameAnalytics Account
- You enquire about our products and/or services
- You purchase goods or services from us
- You are an existing client
- You contact us by email, telephone or by using our online contact form
- You sign up to receive newsletters and/or other promotional communications from us
What Personal Data is
‘‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation. Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
Personal Data we collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect, see the table below in the section entitled ‘Purposes for which we use personal data and the legal bases’.
How we collect your Personal Data
We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website.
However, we may also collect your Personal Data from third parties such as:
- reputable companies who provide lead generation contact lists
- others to whom you have provided consent
- publicly available sources such as social media platforms
- sub-contractors in technical, payment and delivery services
- advertising networks
- analytics and tracking software providers and
- search information providers
Purposes for which we use personal data and the legal bases
We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:
| Purpose | Lawful Basis for Processing |
|---|---|
| Responding to correspondence from you | It is in our legitimate interest to respond to enquiries made via our website, by email, through our social channels or any other means. |
| Sending you information on sales events or product information which may be of interest | If you are an existing customer or have expressed an interest in our products or services, we will rely on legitimate interests to contact you for marketing purposes.
You may object to the processing for this purpose by emailing privacy@gameanalytics.com. If we have captured your consent for the purposes of marketing, that consent may be withdrawn at any time by emailing privacy@gameanalytics.com or using the unsubscribe option. |
| Provision of our services | Processing is necessary for the performance of the contract between us. |
| To maintain a record of contact for current client engagement | It is our legitimate interest to maintain a record of the contact we have with you within our client database. |
| Business management, forecasting and statistical purposes | It is our legitimate interest to identify areas for managing current business relationships, develop new products and services, and for managing our business. |
| Improving our websites and the overall website visitor and user experience | It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our websites. |
| Improving our websites and the overall website visitor and user experience. | We use cookies on our websites with your consent. |
| Improving our platform and the overall client experience. | It is our legitimate interest to utilise analytical and tracking software to help improve and optimise our client platform. |
Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.
Sharing your Personal Data
We may also disclose your information to third parties in connection with other purposes set out in this privacy notice. These third parties may include:
- business partners, suppliers and sub-processors* who may process information on our behalf
- advertisers, social media platforms, and advertising networks
- analytics and search engine providers
- IT service providers
*A list of our sub-processors is available upon request.
This site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.
Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider necessary to protect the rights, property or safety of GameAnalytics, its personnel, users or others.
International Transfers
Your Personal Data may be transferred internationally, this is because the organisations we use to provide our service to you are based outside the EU/UK.
We have taken appropriate steps to ensure that any Personal Data being processed internationally, still has an equivalent level of protection to that guaranteed in the EU/UK. We do this by ensuring that:
- Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation) or
- We either enter into EU Standard Contractual Clauses or an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk))
How long we keep your data
We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.
At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.
How we protect your data
We implement appropriate technical and organisational measures to protect data against unauthorised or unlawful processing and against accidental loss, destruction or damage.
GameAnalytics is SOC2 Type II** compliant and ISO27001 certified. You can review our real-time Trust Report and address any inquiries that you may have at security@gameanalytics.com.
** The SOC2 Type II Report is available upon request.
In addition to the technical and organisational measures we have put in place, there are simple things you can do to in order to further protect your personal information, such as:
- Never share One Time Passcodes (OTPs) or passwords.
- Never enter your details after clicking on a link in an email or text message.
- Always send confidential information by encrypted email to reduce risk of interception.
- If you’re logged into any online service do not leave your computer unattended.
- Close down your internet browser once you’ve logged off.
- Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.
- You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.
Your data protection rights
GameAnalytics would like to make sure you are fully aware of your rights. We will always ensure, no matter where you are located in the world, that we adhere to and fully respect your data protection rights.
You have the following rights if you are located in the EU or UK:
| Rights | Description |
|---|---|
| Right to be informed | Individuals have the right to be informed about the collection and use of their personal data. |
| Right of access | Individuals have the right to receive a copy of their personal data, and other supplementary information. |
| Right to rectification | Individuals have the right to have inaccurate personal data rectified or completed if it is incomplete. |
| Right to erasure (the ‘right to be forgotten’) | Individuals have the right to request their personal information to be erased, in certain circumstances. |
| Right to restrict processing | Individuals have the right to request the restriction or suppression of their personal data, in certain circumstances, in particular:
|
| Right to data portability | Individuals have the right to obtain and reuse their personal data, in a machine-readable format, for their own purposes across different services, in certain circumstances. |
| Right to object | Individuals have the right to object to the processing of their personal data, in certain circumstances.
Where we are using your personal data because it is in our legitimate interests to do so, you can object to us using it this way. Where we are using your personal data for direct marketing, including profiling for direct marketing purposes, you have an absolute right to ask us to stop doing so. |
| Rights with respect to automated decision-making and profiling | Individuals have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
In addition to the above, an individual also has the following rights:
| Rights | Description |
|---|---|
| Right to withdraw consent
(if applicable) |
Where we are using your personal data based on your consent, you can withdraw your consent at any time. |
| Right to lodge a complaint with a supervisory authority | Our lead EU data protection supervisory authority is the Danish Datatilsynet and you can submit a complaint via this link (local language).
You can also submit a complaint directly to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection in the UK, via this link. If you are based anywhere within the EEA a list of supervisory authorities can be found via this link. If you are based in Switzerland, you can contact the Swiss Federal Data Protection and Information Commissioner via this link (local language). |
Exercising your data protection rights
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your data protection rights, please email privacy@gameanalytics.com.
Recruitment
We may advertise job vacancies and opportunities on the careers section of our website, for more information on how we process candidate information please read our recruitment privacy notice.
Children’s Privacy
GameAnalytics is committed to complying with the Children’s Online Privacy Protection Act (COPPA) and protecting the online privacy of children under the age of 13. Our services are not directed at children under 13, and we do not knowingly collect personal information, including persistent identifiers, from such individuals without verifiable parental consent.
As required by COPPA, our privacy policy clearly states that we do not share personal information or persistent identifiers related to children with third parties.
If you are a parent or guardian and you are aware that your child has provided us with their Personal Data without your consent, please contact us at privacy@gameanalytics.com.
By using our Services, you acknowledge that you have read and understood our commitment to COPPA compliance and our practices regarding the collection and use of personal information from children.
Cookies
A cookie is a text file containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies do lots of different jobs, such as letting you navigate between pages efficiently, remembering your preferences, and providing you with content that is relevant to you.
We use cookies on our website, more information about which can be found within our Cookie Policy.
How to contact us
If you would like to exercise your statutory data protection rights, or if you have any concerns or questions about how we handle personal data, please contact us using the details below.
| Danish office:
GameAnalytics ApS Pilestræde 58, 2, 1112 Copenhagen K, Denmark Email: dkoffice@gameanalytics.com |
UK office:
GameAnalytics Limited 18 Soho Square, London, W1D 3QL Email: ukoffice@gameanalytics.com. |
Please send your communication clearly indicating ‘F.A.O. Data Protection Officer’ and your message will be passed directly to the DPO for attention.
How To Complain
You have the right to lodge a complaint with the relevant supervisory authority if you are concerned about the way in which we are handling your Personal Data.
Our lead EU data protection supervisory authority is the Danish Datatilsynet and you can contact them and/or submit a complaint via this link (local language).
You can also submit a complaint directly to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection in the UK, via this link.
If you are based anywhere within the EEA a list of supervisory authorities can be found via this link.
If you are based in Switzerland, you can contact the Swiss Federal Data Protection and Information Commissioner via this link (local language).
Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify you of the changes where required by applicable law to do so.