PC & CONSOLE GAMES PRIVACY AND DATA POLICY

ISSUED BY KWALEE LIMITED

Last Updated: October 22, 2024

Welcome to Kwalee’s privacy policy hub for all of our PC & Console games.

The Kwalee General PC & Console Privacy Policy (below) applies to all PC & Console games published by Kwalee unless your game is listed below, in which case its own separate game-specific privacy policy shall apply instead.

Game-Specific Privacy Policies

Please follow the links below for the privacy policies applicable to the following games:

For Wildmender please follow link here: www.kwalee.com/pp-pcc-wildmender

For Robobeat please follow link here: www.kwalee.com/pp-pcc-robobeat

Kwalee General PC & Console Privacy Policy

1. Introduction and general terms

At Kwalee Ltd (‘Kwalee’ / ‘we’ / ‘us’), we respect your privacy. Our registered office is at Kwalee Ltd, Midlands Technical Centre, Southam Road, Radford Semele, Leamington Spa CV31 1FQ. We are a company registered in England, with company number 07648078.

This privacy and data policy (“Privacy Policy”) describes our practices with respect to the information we collect when you interact with our PC and console games (the "Game"). In certain circumstances, a Kwalee game may require its own specific privacy and data policy, in which case that policy shall be clearly identified and will take precedence over this Privacy Policy.

We collect analytics data to collect technical information about the use of the Game to help us improve the Game and other Kwalee products (together “Kwalee products”). The data we collect does not directly or indirectly identify individuals using the game. Since we value openness and transparency regarding data collection practices, this Privacy Policy explains the basis on which analytics data may be collected, used, processed, and disclosed by us or on our behalf.

If you have any questions or comments about this Privacy Policy, please contact us at privacypolicy@kwalee.com

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

What analytics data we may collect when you play the Game and how we will use that data;
Whether we will disclose that analytics data to anyone else; and
Your choices and rights regarding the analytics data we or our service providers maintain.

2. Data we may collect when you play the Game

We collect and process the following information.

Information collected for the purposes of providing analytics (“Analytics Data”)

We may use analytics technologies such as Unity Analytics or a developer plugin to collect technical information about your use of the Game which we use for our analytics purposes described below. This includes the following:

a unique randomly generated anonymized identifier for you (User ID);
the time, date and install source of a player’s first download;
game session start time, end time and duration;
player in-game preferences;
platform information (e.g., whether the player is playing on Steam, Nintendo, Xbox or PlayStation) and players’ device, make and model, operating system and version;
in-game interactions (including interactions you have with other players) and in-game purchases that you may make;
anonymous core information milestones related to your gameplay, such as the Game state, level information, completion of certain activities during your gameplay, player and host player gameplay logs
the geolocation of a player's device only to the level of country and region (town/city) using an obfuscated IP address;
text entered by the player when prompted to explain a bug;
identification of crashes, bug reports and defects; and
information that you supply to us using a “free-text” function when reporting bugs using the functionality within the Game.

When using the in-Game bug reporting function, please do not provide any personal information that may be used to identify you (for example your name, email address or any other personally identifiable information). No personal information is required in order for us to fix the bugs. In the event that you do identify yourself within a bug report, please note that this data will not be used in order to fix the bugs, it may be stored on servers that are outside of your territory and will be deleted as soon as the relevant bug is fixed.

3. Why we collect and process information about you

We will process Analytics Data for the following purposes.

To provide our Game to you

We will use Analytics Data to provide our Game to you. The processing of Analytics Data in this way is necessary for us to record your progress and current status within the Game, and to determine whether the Game features function properly, and to improve your experience when playing the Game and potentially other Kwalee Products.

To help us improve the Kwalee Products and fix any problems

We may process Analytics Data so that we can analyse and improve our Games and Kwalee Products.

This processing is necessary for us to (i) ensure that our Kwalee Products function properly so that you and other users have the best experience when playing the Game and using other Kwalee Products; (ii) improve the quality of our Kwalee Products, and provide a better experience to our users; (iii) identify and correct any bugs in the Game and Kwalee Products; and (iv) understand the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.

4. Data Sharing

We will share Analytics Data with third parties only in the ways that are described in this Privacy Policy.

Suppliers and service providers: We may transfer Analytics Data to our suppliers and service providers that provide services to us, including data analytics providers, game developers, IT and related services, payment processing, customer support providers, and security fraud-detection services.

Group Members: We may share Analytics Data among Kwalee group members, including our affiliates, subsidiaries and parent company for the reasons set out in this Privacy Policy, including developing and supporting the Kwalee Products and users, and sharing between teams collaborating on these purposes.

Required by law: In addition, we may disclose Analytics Data 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 personal data to others for the purposes of fraud prevention).

5. Your rights in relation to data which we process relating to you

Whilst we do not collect your personal data as set out in this Privacy Policy, we set out here your rights in relation to personal data generally.

Depending on where you live, you may have some or all of the following rights over the way personal data relating to you is processed. We aim to comply with your requests as required by applicable law.

To make a request, please let us know by sending an email to privacypolicy@kwalee.com or submit a request via our webform. To protect your information, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity.

Under certain laws, you may exercise these rights yourself or you may designate an authorised agent to make these requests on your behalf. We may request that your authorised agent have written permission from you to make requests on your behalf and may need to verify your authorised agent’s identity.

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

You may have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. Specifically, you may have the right to request the categories of personal data we have collected, the categories of sources from which we collected the personal information, the purposes for collecting, selling, or sharing the personal information, the categories of third parties with whom we have shared or sold your personal information, and the specific pieces of personal information we have collected about you.

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

Ask us to restrict or delete your data

You may be able to ask us to restrict or delete your personal data in certain circumstances, including if we no longer need to process that personal data for the reason it was collected, or you have objected to us processing your personal data and we are considering your request.

Withdraw your consent or object to or opt out of us processing your personal data

If you consented to processing of your personal data, you may be able to withdraw that consent. Similarly, if your personal data is processed, on the basis of the legitimate interests of Kwalee or a third party, and you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it, then you may have the right to object to the processing.

We do not sell or share personal information and have not engaged in business transactions with third parties that might be considered a “sale” or “sharing” of personal data as those concepts are defined in the California Consumer Privacy Act (“CCPA”).

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing data, please let us know by contacting us via the support services or sending an email to privacypolicy@kwalee.com.

We hope that we can satisfy queries you may have about the way we process Analytics Data. However, if you do not agree with the way we have processed your data or responded to your concerns, you also have the right to submit a complaint to a Data Protection Supervisory Authority. You can bring the complaint in your country or state of residence, place of work or where an alleged infringement of data protection law occurred. You can also submit a complaint to the UK Information Commissioner's Office, the Data Protection Supervisory Authority where Kwalee is headquartered.

6. Data Retention

We will hold Analytics Data on our systems for as long as is necessary for the relevant purpose, or as otherwise described in this Privacy Policy. If you delete one of our Games or cancel your account, we may retain and use your Analytics Data as necessary for the reasons set out above.

7. Children

We do not use our Kwalee Products to knowingly solicit or collect personal data from or market to children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age we will delete that personal data as quickly as possible. If you believe that we might have any personal data from or about a child under 13 years of age, please contact us at privacypolicy@kwalee.com.

8. Security

We take technical and organisational precautions to prevent the loss, misuse or alteration of data.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

9. International Data Transfers

If you use our Kwalee Products from the UK or EEA and this does involve processing of personal data, it is possible that your personal data may be transferred outside of the UK and EEA to our affiliates, service providers or other third parties in other countries around the world that do not provide an adequate level of data protection as defined by data protection laws in the EEA and the UK. Certain third countries, such as Canada, the Republic of Korea and Japan, have been officially recognized by the European Commission and the UK Secretary of State as providing an adequate level of protection.

10. Additional Information For California Residents

If you are a California resident, this section also applies to you and supplements the information contained elsewhere in this Privacy Policy. We collect, use, and disclose Analytics Data as described above. We do not collect any personal information (including sensitive personal information). We do not sell or share personal information, and we do not disclose personal information to third parties for those third parties’ direct marketing purposes. Your individual privacy rights to access, delete, and correct are described above in Section 5.

11. CHANGES TO THE PRIVACY POLICY

We may make changes to this Privacy Policy in future. You should check this page from time to time to ensure you are aware of any changes and can see when this Privacy Policy was last updated by noting the "last updated" date at the top of this page. Where we make any material changes to this Privacy Policy, we may notify you of such changes through the Game.

12. CONTACT INFORMATION

All questions, comments or enquiries should be directed to Kwalee at privacypolicy@kwalee.com.

Any data subject request including a request to Do Not Sell or Share My Personal Information shall be submitted to the above email address.