1.1 | Thunderful Publishing AB (“Thunderful”, “we”, “us”) is a developer and publisher of video games. When you play our games, we will collect and process certain information about you – known as personal data. Our role in relation to your personal data is that of controller: meaning that we are responsible for determining how your personal data is processed and for keeping it secure. This privacy notice describes how we will process your personal data and provides you with information about your rights and how you can exercise these rights.
1.2 | We may update this privacy notice from time-to-time, so please do check back.
2.1 | Legally, you must be at least 13 to use our games (although some of our games may have a higher age rating). If you don’t understand something on this page, then please ask your parent or guardian to help.
2.2 | We do not knowingly collect personal data of anyone under the age of 13. If you’re a parent or guardian and are concerned about how we process your child’s personal data, please do get in touch.
3.1 | When you play our games, we collect device information, username (if applicable) and in-game information (i.e. your progress and activity within the game).
3.2 | We do not collect any specific identifiers about you, such as your name or address, and you do not need an account with us to play our games.
3.3 | We use your personal data for the following purposes:
3.3.1 | In order to make our games available for you to play. This is necessary for the performance of the contract that we have with you.
3.3.2 | In order to review our games to identify and remedy any bugs or errors, and to make sure our games are running as we intended. This is necessary for the performance of the contract that we have with you.
3.3.3 | In order to assess if our games can be improved in any way. This is in our legitimate interests so that we can make the best games possible.
3.3.4 | We also use information to enforce our policies, notify you about changes, protect our services, deal with cheats and hacks, and protect you and our other users. This is necessary for the performance of the contract we have with you.
3.3.5 | If you contact us, we will process your personal data so that we can respond to your query. This is done in accordance with our legitimate interests so that we can respond to such queries.
3.3.6 | If you exercise your rights, we will process your personal data to give effect to your request (where applicable). This is necessary to comply with legal obligations.
3.3.7 | If we carry out direct marketing. This will be done on the basis of your consent or in accordance with our legitimate interests if the marketing relates to goods / services which are similar to those that you have signed up for.
3.4 | We may also collect and use your personal data where necessary for us to comply with our legal obligations.
3.5 | We also process personal data for other purposes that are compatible with those listed above.
4.1 | As the controller of your personal data, it is our responsibility to keep it secure. This means that we will only share your personal data where it is necessary and where we have put suitable controls in place.
4.2 | We may share your personal data with certain service providers, known as processors. These processors will only process your personal data on our behalf and in accordance with this privacy notice. In all instances, we will ensure that our processors are contractually obliged to keep your personal data secure and only to process it in accordance with our instructions.
4.3 | We may share also your personal data with other partners and group companies where necessary, such as developers and platforms. Again, we will always ensure that any sharing is kept secure.
4.4 | In the event of a merger, acquisition or other corporate activity, we will be required to share your personal data.
4.5 | Finally, in rare circumstances, we may be required to share information with law enforcement.
5.1 | Data protection laws impose restrictions on controllers when it comes to transferring personal data – this is to ensure that your personal data is kept secure and not held in countries with lower data protection standards.
5.2 | We will only transfer your personal data to those countries with adequate data protection requirements or where we have put in place contractual measures – commonly known as standard contractual clauses – to ensure that the recipient applies the same data protection standards that are in place in Europe and the UK.
6. How long do we keep personal data for?
6.1 | We only keep personal data for as long as is necessary.
6.2 | Generally, we will not hold personal data for longer than six years. There will be circumstances, however, where we need to keep personal data for longer (i.e. if we have a legal obligation to keep personal data for longer, to resolve a dispute, or to prevent cheating or other inappropriate activities).
7. How do we keep personal data safe?
7.1 | It is impossible to guarantee that information will be kept secure in today’s digital age. However, we have robust security arrangements in place to guard against your personal data being lost, stolen or access by unauthorised persons.
7.2 | When we use third-party organisations to process your personal data, they must comply with contractual requirements and instructions with regard to security.
8. Your rights
8.1 | You have certain rights in respect of your personal data. This means that you can contact us and ask us to do certain things with your information, such as provide it to you or delete it. You can learn more about these rights here: https://ico.org.uk/your-data-matters/ In particular, we’d like to remind you that you can:
8.1.1 | ask us for a copy of the personal data we hold about you;
8.1.2 | ask us to change information that is inaccurate;
8.1.3 | object to decisions about you being taken by automated means (i.e. where a computer makes a decision about you with no human involvement);
8.1.4 | where we have asked for your consent, you can change your mind and withdraw your consent at any time;
8.1.5 | ask us to stop using your information;
8.1.6 | ask us to share your personal data with another company;
8.1.7 | ask us to delete the information we hold about you; and
8.1.8 | ask us to stop sending you direct marketing.
8.2 | If you wish to exercise any of your rights, please contact us at info@thunderfulgroup.com. You can exercise these rights whether you’re an adult or a child.
8.3 | Please be aware that your rights are not absolute. This means that there may be circumstances where we are unable to comply with your request or where we are permitted to refuse to comply. Once you make a request, and where we can comply, we will do so within one calendar month although we may have to extend this for more complex requests or where we have received a high volume.