KEYWORDS STUDIOS PRIVACY POLICY FOR APPLE ARCADE GAMES

9th of June 2021

Keywords Studios (hereinafter, “the Company,” “we,” “us” and “our”), respects the privacy rights of our users and is committed to protecting the information collected through our products and services. This policy applies only to Keywords Studios Games on Apple Arcade, referred below as the “Game”.

This privacy policy (the “Privacy Policy“) explains what personal data we may collect about you when you use or access the Online Services and how we collect, store, disclose, transfer, protect, and otherwise process that information for the purposes of operating and providing the Game.

The lawful processing basis for the processing of your personal data is justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.

Unless defined herein or the context requires otherwise, terms used in this Privacy Policy have the meanings given to them in the General Data Protection Regulation (GDPR) (EU) 2016/679.

WHO THIS PRIVACY POLICY APPLIES TO This Privacy Policy applies to all users of our Games on Apple Arcade across all supported Apple devices (iOS, iPad, MacOS, TvOS).

WHAT DATA WE COLLECT The Game collects “Personal Data” as you play the game in order to track game progression, to allow save game data across Apple devices, register achievements (‘Game Progress Data’) and to facilitate online matchmaking for multiplayer games. The data we collect cannot be used to identify you, but it will relate to you.

  • Game Progress Data is the only Personal Data that the Game collects. This Game Progress Data is stored on Apple services such as iCloud and GameCenter for game saves and progress and GameCenter for achievements, and its use is governed by Apple’s policies.
  • The game collects the GameCenter ID for the purpose of achievements, game saves, and for cross save for the same account across different Apple devices.
  • The player’s GameCenter user name is collected and shared with other players during online multiplayer games, but is not retained on our servers.
  • Our multiplayer servers collect the GameCenter Alias for the purpose of online matchmaking. This data is not stored. The GameCenter Alias is discarded once matchmaking is complete and a multiplayer game begins.
  • We generate a temporary ID during online matchmaking. This ID is not retained and does not tie back to any user data.
  • Our multiplayer servers are run by a third-party vendor: Photon
  • Our data controls over Photon data usage are stipulated in their GDPR and DPA:
  • We do not store personal or gameplay data on our servers. The data is collected and stored on Apple Services such as iCloud and GameCenter.
  • We do not use any other third-party analytics services for collecting or storing any data and we do not use cookies or similar tracking technologies to track user activity when you play the Game.
  • The Game does not request access to data from any other Apps on your device.

In addition to the Game Progress Data we may collect and process the following personal data from you (together, “Your Information”):

Information that may be provided by you when you contact us for support

  • Your name; and
  • Your address, telephone number and email address.

How to Access and Control Your Personal Information You may decline to store data in iCloud or to send data to GameCenter. To turn off iCloud data storage, you must turn off iCloud in Apple Settings for our game. To stop sending data to GameCenter, you must sign out of GameCenter in Apple Settings.

You may decline to enter Multiplayer. Multiplayer is not enabled unless you give consent. You may change your consent options at any time in the in-game options menu.

Where We Store and Process Personal Data The Game collects data and stores it on Apple services such as iCloud for Game saves and GameCenter for achievements. We do not store personal data on our servers.

Our Policy Towards Children The Game collects, uses, and discloses data from children in the same way as for other users, as described in this policy. Game use of children’s data is limited to support internal operations of the Game. If you are a parent, you can decline to have that data collected from your child by turning off iCloud for our game and signing your child out of GameCenter.

HOW DO I ASK A QUESTION? Contact information for inquiries about the Personal Data Protection Policy or Personal Data.

E-Mail: DataProtectionManager@keywordsstudios.com