GDPR – Privacy-By-Design and Record of Processing Activities
We are committed to a lawful, fair, and transparent processing of personal data, adhering to the EU General Data Protection Regulation (GDPR). This document provides our general privacy-by-design considerations (articles 5, 25, and 26 GDPR) and records our processing activities (article 30(1) GDPR).
Personal Data Processings: Player data
Creation date / last update: 29 Oct 2024
Contact email: pocketplaystudios@gmail.com
* Not formally a DPO under the GDPR.
1. We process the following (categories of) personal data
When you play our games, connect to a social networking site through our games, register an account, enter a promo code, or place an order, we process the following personal data with your consent:
- Your IP address and country
- Your device type (e.g., iPhone 7, Samsung Galaxy S7) and operating system version
- Your Game Center ID (for iOS games) or Google Play ID (for Android games)
- When you connect to Facebook, Game Center, or other social platforms, we access your profile, including your username and friends list
- For analytics, details such as when you installed and played the game, your progress, and events connected to gameplay. We generally cannot identify you with this data but treat it as personal data
- For advertising, we may use collected IDFAs to (re)target users on advertising platforms
2. What (purposes) do we use the data for
We use this personal data to perform analytics for our games and enable third parties to sell, buy, and deliver advertising in those games that display advertising. Social network data is used to show you personalized content, such as friend-specific high scores or showing your name or avatar on in-game objects.
3. What is our legal basis for the processing
For analytics and advertising, we base the processing of personal data on the legitimate interest of our company. For analytics, this is our ability to analyze gameplay progression to improve our games and understand our player base on an aggregate level. For advertising, it allows us to offset development costs with advertising income. Our third-party providers have a legitimate interest in offering their services, including showing advertisements.
4. Where do we obtain the data from (sources)
We obtain data from our third-party service providers:
- Google Analytics
- Firebase
- Admob
- Applovin
- Facebook Audience Network
- Unity Ads
5. How long and where do we store data
We store personal data for up to a year, after which only aggregate data is retained, except for email addresses used for newsletters. Aggregated data means individual players cannot be identified. When a third-party service provider is a controller, they may retain data for a shorter or longer period.
6. What safeguards have we taken to protect data
We have taken the following technical and organizational measures to protect data:
- Access to our database and user accounts with third-party providers is protected with access control
- Database access is limited to authorized staff only
- Data transmitted from our games is encrypted in transit where technically possible
- We rely on processors to notify us of any data breaches
7. Who we share data with
We share data with the following third parties, who may act as controllers or processors on our behalf:
- Google Analytics
- Firebase
- Admob
- Applovin
- Facebook Audience Network
- Unity Ads
- Apple and Google (when using their app stores)
8. How to contact us
If you have any questions, please contact us:
Website: https://puzzly.in
Email: pocketplaystudios@gmail.com