Privacy Policy

+ Facebook Apps

For apps and games that access Facebook, we only post information generated by the game or app (such as score) to your profile. These are set as public postings by default. We don’t access your information at all nor use any permissions to your profile to gather any data about you. The permissions for the games and apps we create can be seen, edited or revoked via your Account Settings/Apps page on Facebook.

+ Marketing Information

If you have signed-up to follow us via email, Facebook, Twitter or any other means we may use this connection to tell you about news related to Auroch Digital Ltd, our games or apps. If you email us about something, we may reply and invite you to join our mailing lists and/or other social media network connected to our games or apps. We may also email you with important news about our games. However we will never share your information with any third-party without your permission.

+ Data Heuristics

Some of our games and apps may use data heuristics such as Flurry. If so we only gather summarized data and do not use this to track individual users. We are limited to the functionality of the platforms we use such as the App Store, Steam or Google Play, however we would never use any embedded functionality that these system may embed to track individuals.

+ New GDPR Information

Auroch Digital Limited ("we" or "our") are committed to respecting and protecting your privacy and personal data.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any data including personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting websites operated by us or using our services you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Auroch Digital Limited. Our nominated representative for the purpose of the Act is Tomas Rawlings.

+ Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Auroch Digital collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, sign up for a workshop or training with us or a talk or presentation given by us, purchase a product or service from us or take part in a competition or survey or give us feedback.

This website is not intended for children under 13 years old and we do not knowingly collect data relating to children under 13 years old.It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy notice supplements the other notices and is not intended to override them.

Controller

Auroch Digital Ltd is the controller and responsible for your personal data. Auroch Digital is a private limited company registered in England and Wales with company number 07389229 whose registered office is 32 Jessops Riverside Brightside Lane, Sheffield, United Kingdom, S9 2RX.

Our directors are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Company name: Auroch Digital Limited

For the attention of: Tomas Rawlings

Email address: gtn@aurochdigital.com

Postal address: Auroch Digital Ltd, 129 Newfoundland Road, St Pauls, Bristol, United Kingdom, BS2 9LU

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice are your duty to inform us of.

This version was last updated on 14th March 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

+ Third-party links

Our website may include links to third-party websites, plug-ins and applications, including links to our social media channels on third-party websites (such as Facebook, Twitter, LinkedIn, Instagram, YouTube and Twitch). Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We have no control over these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

+ The data we collect about you

Personal data, or personal information, means any information about an individual from which that personcan be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have groupedtogether as follows:

• Identity Data includes first name, last name, username or similar identifier, login information, profile picture, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone number.

• Transaction Data includes details about payments to and from you (via third-party providers such as PayPal or Steam) and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Game Data includes information about your use of our games such as in-game play progress, levels, games played, session length, preferred settings, interaction with in-game adverts and notifications, game preferences and information about the friends you have connected with you.

• Usage Data includes information about how you use our website, products and services, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.How is your personal data collected?

We use different methods to collect data from and about you including through;

• Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• request information about or make an order for any products or services, sign up for a workshop, training or presentation;

• participate in any discussion boards or other social media functions on our site or on any of our social media channels;

• fill in the contact form on our website;• subscribe to our service or newsletter;

• request marketing to be sent to you;

• enter a competition, promotion or survey;

• report a problem with our site or a game; or

• give us some feedback.

• Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical or Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical or Usage Data about you if you visit other websites employing our cookies.

We may also automatically collect or receive Game Data.

Third parties.

We may receive personal data about you from various third parties as set out below:• Technical and Usage Data from analytics and search information providers such as Google based outside the EEA or advertising networks.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• Any type of personal data that may be collected by the stores that you have given them permission to pass to us, that we then use to promote and sell our games, or by the online platforms we mayuse to promote our business, products, events, etc. We mainly use systems and services provided by the following third parties:

• Google Analytics – we may collect or receive Technical and Usage Data which may be used for improvement of our video games and the website experience. We tend to embed these is most PCgames and also in our Steam pages and other systems that allow them such as Kickstarter. This data is not personalised and we do not process it in a way that might push it in that direction.

• Google Adwords and Remarketing – we may collect or receive Technical and Usage Data which maytrack visitors to our site for the purpose of serving advertisements on 3rd party websites and monitoring the performance of those ads if/when the visitors return to our site. The data is not personalised and cookies expire after 30 days.

• Facebook tracking pixels – To identify visitors to our site for serving advertisements on Facebook and monitoring the performance of those ads. Data is not personalised and cookies expire after 30 days.

• Online stores – we may collect or receive any type of personal data from online game and app storessuch as Steam, Google Play or the App Store if you purchase our games from those stores.• Online platforms – we may collect or receive any type of personal data from other online platforms suchas Kickstarter.

• Flurry – some of our older games use Flurry as a method of gathering analytics. This data is not personalised and we do not process it in a way that might push it in that direction.

• PayPal & Stripe Payment Services – We make offer you options to complete transactions via these services. If you engage with them we only use the basic data they share with us needed to process that transaction, typically an email address and/or physical address.

+ How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where we need to comply with a legal or regulatory obligation.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Explanation of the legal grounds

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

• Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. We have explained below more about the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

+ Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us, attended a workshop or training with us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Advertising and third-party marketing

We will get your express opt-in consent before we share your identifiable personal data with any company outside the Auroch Digital group of companies for marketing purposes.

We may use advertising to fund our part of our services and to make some our games available for free or at a lower cost. We may show third-party advertising on our website and in our games and also advertise our games and services via third parties. We want to provide you with more detail about how we use information for advertising, both in our properties and in third-party properties.

+ When you view ads on our website and in our games

• To enable us to show in-game ads, we may send your advertising ID and IP address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party websites and games. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (this is controlled by ad networks), but we do prohibit certain types of ads.

Advertising IDs are used by ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed herein as "Third Parties") including, for example, to:

• limit the number of times you see the same ad;

• ensure they are dealing with humans with real devices and not automated “bots”;

• to serve you with advertisements likely to be relevant to you based on your advertising ID, your engagement with other brands and ads which is recorded using your advertising ID, and to use your general geographic area.

• Other brands may buy ad placements via an ad network or ad exchange to advertise their products in our games. The ad network or ad exchange acts as intermediary between the other game companies and We. In order for an ad network to charge the company purchasing the ad, clicks from the ad and potential installs of other developers’ apps are tracked. Views, clicks and installs from ads are measured using the Advertising ID.

• Ad networks track which games you have used to market you similar kind of games.

Your IP address is typically used by advertisers to identify your general geographic location, for example, your country, state and, sometimes, your city).

When you view our ads on third-party services;

• We may also advertise our games on third-party websites, games and apps by asking ad networks to place our ads for audiences that will be interested in them (determined using Advertising IDs).

• Ad networks use Advertising IDs for this and other purposes including, for example, to:

• Measure ad effectiveness (looking at total views, clicks and installs generated by our advertising in other publishers’ games). • Inform players that have not played for a while about new content in the game. We give a list of these users in the form of Advertising IDs to an ad network. The ad network then shows these users ads about the new content.
• Not display ads for a game a player is already playing. We may send a list of active players in the form of Advertising IDs to an ad network. The ad network then excludes these players from seeing the ad.

• Market games to a group of potential players. We may provide Facebook a list of Advertising IDs to match them with similar type of Facebook users to whom we could then market our games. We do not have information on how Facebook identifies or creates profiles of similar type of users.

You can opt out of interest-based advertising on mobile applications by changing the privacy settings of your device and selecting "limit ad tracking" (Apple iOS) or "opt out of interest-based ads" (Android).

+ Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

+ Cookies

As we are part of Sumo Group Ltd please see here for our cookies policy: Cookie Policy

+ Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

+ Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above. We may share your personal information with our parent company Sumo Group Limited and its subsidiaries (the “Sumo Group”), but we will not share your personal data with our ultimate parent, Tencent Holdings Ltd., a public company listed on the Stock Exchange of Hong Kong (SEHK: 0700) and headquartered in China or any of Tencent Holdings Ltd.’s affiliates outside the Sumo Group.

External Third Parties as set out below:

• Service providers acting as processors both in and outside the EEA who provide IT, CRM and system administration services.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance withthe law. We do not allow our third-party service providers to use your personal data for their own purposesand only permit them to process your personal data for specified purposes and in accordance with ourinstructions.

+ International transfers

Some of our external third parties (set out above) may be based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

+ Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

+ Data retention

How long will you use my personal data for?

We will only retain your personal data 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.You can request details of retention periods for different aspects of your personal data by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

+ Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data: request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing purposes

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.Request restriction of processing of your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. No fee usually required

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 (usually £10) if your request is clearly unfounded, repetitive or excessive.

Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you: we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.Time limit to respond: we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.