Imago Games OÜ Privacy Policy
Last Updated: 04.08.2023
1. Introduction
Welcome to the Privacy Policy of Imago Games OÜ ("Imago Games," "we," "us," or "our"). We respect the privacy of our users and are committed to protecting it through our compliance with this policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you use our mobile game and our practices for collecting, using, maintaining, protecting, and disclosing that information.
2. Detailed Data Collection
2.1 Anonymous Accounts and Player Identification: Upon accessing our game, anonymous accounts are automatically generated for players. Each player is assigned a unique PlayerId, which is utilized to map their in-game states and progress. Players have the option to set a username for their profile after account creation.
2.2 IP Address Cache: For the duration of a game session, we might cache IP addresses. This is primarily to implement rate limiting, ensuring a consistent and fair gaming experience for all players.
2.3 In-app Purchases: While players make in-app purchases through third-party providers such as Google and Apple, we do not directly process or store payment details. We receive and validate receipts from these providers to confirm purchases within the game.
2.4 Third-party Analytics: We employ third-party analytics tools, specifically Unity Analytics, to improve and analyze the game's functionality. Unity Analytics may capture information about your device's operating system and unique device identifier.
2.5 Gameplay Data: To enhance the player experience, we store data related to game progress, including levels achieved, achievements unlocked, scores, and other in-game statistics. This data allows players to track their performance and continue their gameplay seamlessly across sessions.
2.6 Multiplayer Match History: For those engaging in multiplayer modes, match histories and interactions are recorded and stored on AWS services to provide a record of gameplay and to facilitate features like leaderboards or matchmaking.
3. Purpose for Data Collection
3.1 Anonymous Accounts and Player Identification: Our primary goal in auto-generating anonymous accounts and assigning a PlayerId is to offer continuity in gameplay and store individual player progress. This approach ensures that you can pick up from where you left off, regardless of any interruptions.
3.2 Player Usernames: Player-chosen usernames or nicknames are utilized for in-game identification, particularly during multiplayer interactions. These usernames are also displayed on leaderboards, allowing players to achieve recognition and interact competitively with others.
3.3 IP Address Cache: We cache IP addresses exclusively for rate limiting. This practice ensures that our game servers remain responsive and can accommodate a large number of simultaneous players without performance issues.
3.4 In-app Purchases: The information we receive concerning in-app purchases is strictly used to validate receipts from third-party providers like Google and Apple. As of now, this data doesn't serve any other purpose within our game.
3.5 Third-party Analytics: We employ Unity Analytics to continuously refine our game, understand player preferences better, and troubleshoot potential issues. The insights gained help us to optimize gameplay and deliver a more satisfying experience for all our users.
3.6 Gameplay Data: The primary purpose of collecting gameplay data is to allow players to view their statistics, achievements, and progression. Currently, we do not use this data for personalized in-game suggestions or recommendations.
3.7 Multiplayer Match History: Besides providing players with a record of their multiplayer matches and facilitating in-game functionalities like leaderboards or matchmaking, this data also aids our team in troubleshooting any issues or discrepancies that might arise during multiplayer interactions.
4. Data Sharing and Third-party Access
4.1 Service Providers: We collaborate with several third-party service providers that may have access to certain user data. These providers include:
- Google IAP SDK and Apple IAP SDK for in-app purchase functionalities.
- Google Firebase and Unity Analytics for data analytics purposes.
- Amazon Web Services (AWS) for hosting and other related services.
Our engagement with these service providers is governed by strict data protection agreements to ensure the safety and confidentiality of your data.
4.2 Affiliates and Partners: We currently do not share user data with any sister companies, affiliates, or partners.
4.3 Business Transfers: In the unlikely event of a business transfer, merger, acquisition, or sale, user data could be among the transferred assets. However, in such a scenario, we'll ensure that the confidentiality of personal data is protected and inform users appropriately.
4.4 Legal Requirements: We may disclose user data if required to do so by law or in the good faith belief that such action is necessary to comply with legal obligations, protect and defend our rights or property, or protect the safety of our users or the public.
4.5 Protection and Safety: User data may be shared or disclosed to address fraud, security risks, or technical issues, particularly if mandated by data protection regulations such as GDPR or CCPA.
4.6 Aggregated or Anonymized Data: We may share aggregated or anonymized data, which cannot identify individual users, for purposes like research, analysis, or improving our game. Such data sharing typically occurs when utilizing analytic SDKs like Google Firebase and Unity Analytics.
4.7 User Consent: Certain third-party SDKs might check for user consent configured in device settings and track data accordingly. Users always have the right to modify these settings to limit or permit data sharing based on their preferences.
5. Data Storage and Security
5.1 Data Storage Location: User data is primarily stored in data centers located in Europe and both North and South Americas. These locations are chosen based on infrastructure robustness and compliance with international data protection regulations.
5.2 Data Retention Period: We retain your data for as long as your account is active or as needed to provide you the Service. We may for example periodically de-identify unused game accounts, and we may regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
5.3 Security Measures: The safety of our users' data is of utmost importance to us. We employ a range of security protocols, including:
- Encryption: User data is encrypted both during transit and at rest.
- Access Controls: Strict controls are in place to ensure only authorized personnel have access to stored data.
- Security Audits: We conduct regular security audits to identify and address potential vulnerabilities.
5.4 Data Breaches: In the unfortunate event of a data breach, we are committed to informing affected users as swiftly as possible. Users will receive a detailed description of the breach, potential implications, and the measures taken to rectify the situation.
5.5 Third-party Service Providers: We rigorously vet our third-party service providers, ensuring they maintain a high standard of data security. Agreements with these providers include strict data protection clauses, and we routinely review their security practices. Alright, moving forward with User Rights and Choices.
6. User Rights and Choices
6.1 Access:
Users have the right to access the data we hold about them. This includes information like gameplay stats, achievements, scores, and any other data linked to their PlayerId.
6.2 Rectification:
If a user believes any of the data we hold is inaccurate or incomplete, they have the right to ask for corrections.
6.3 Deletion:
Users can request the deletion of their data. Upon such a request, we will erase the user's data, except where retention is necessary for legal or compliance reasons.
6.4 Restriction:
Users have the right to request a restriction on the processing of their data in certain circumstances. This might be the case if a user contests the accuracy of the data or if the processing is unlawful.
6.5 Data Portability:
In some jurisdictions, users have the right to receive their personal data in a structured, commonly used, and machine-readable format. They can also request that we transfer this data directly to another organization, where technically feasible.
6.6 Objection:
Users can object to the processing of their personal data in some circumstances. We will then stop processing their data unless there are compelling legitimate reasons to continue.
6.7 Consent Withdrawal:
If our processing is based on a user's consent, they have the right to withdraw that consent at any time. However, this will not affect any processing that has already taken place.
6.8 Raise Concerns:
Users have the right to raise concerns about the way we handle their data. They can do this by contacting our Data Protection Officer or lodging a complaint with a supervisory authority, especially in the European Union for GDPR-related concerns.
To exercise any of these rights or for more information, users can contact us directly through our provided contact channels.
7. International Data Transfers
Given the global nature of our services your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that we may use include standard contractual clauses approved by EU Commission and other lawful safeguards.
8. Changes to the Privacy Policy
8.1 Regular Updates:
Imago Games OÜ strives to keep its services in alignment with the best practices and legal requirements. As such, we may update our Privacy Policy from time to time to reflect changes in our practices, services, or in response to changes in the law.
8.2 Notification:
Whenever significant changes are made to this Privacy Policy, we will notify users through an in-game notification or other prominent means. It's crucial for users to ensure they read any updates to stay informed about how we protect their personal data.
8.3 Review:
We encourage users to regularly review our Privacy Policy to stay informed. The date of the last modification will always be listed at the beginning of this document.
8.4 Continued Use:
By continuing to use our services after such updates take effect, users acknowledge and accept the updated Privacy Policy. If users disagree with any changes, they should cease using our services and contact us with their concerns.
9. Contact Information
If you have any questions, concerns, or feedback about this Privacy Policy or our data handling practices, please feel free to contact us:
Imago Games OÜ
Address: Harju maakond, Tallinn, Lasnamäe linnaosa, Paekalda tn 14-9, 11413
Registry Code: 16632452
Email: gaussiangames@gmail.com
10. Data Protection Officer (DPO) Details
To ensure the highest standards of data privacy and security, Imago Games OÜ has appointed a Data Protection Officer. Users can contact our DPO directly for any data protection related queries:
Email: gaussiangames@gmail.com