PRIVACY AND DATA POLICY
ISSUED BY HELLO GAMES LTD
Last Updated: 12 October 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by HELLO GAMES LTD (‘Hello’ / ‘we’ / ‘us’). Our registered office is at Dolphin House, 3 North Street, Guildford, Surrey, England, GU1 4AA. We are a company registered in England, with company number 06663645.
- What types of information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal information you have provided to us.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
Information provided by you when using the Games
We may collect the following information from you when you play our Games:
- Your username (or gamertag);
- the names of planets, alien bases, flora and fauna you discover in No Man’s Sky;
- player ID;
- your mobile device’s unique device ID;
- your console’s unique device ID;
- your platform player ID, as may be allocated to you by third party platforms such as PlayStation, Steam or Xbox;
- any third party platform profile display names;
- your user preferences, including your language and country; and
- core milestones related to your gameplay, such as your overall progression to a particular level or stage, or the completion of certain activities during your gameplay (for example, completing a tutorial or passing a level).
Information provided by you when you contact us or use the Help Centre
We may ask you for, or you may submit, certain information to us whenever you contact us through the Help Centre.
This may include:
- your name;
- your email;
- location data specifying the city in which you are located;
- the type of device you’re using to play a Game;
- your platform player ID, as may be allocated to you by third party platforms such as PlayStation or Steam; and
- debug logs, which are records of technical information relating to software operation and errors that may have occurred during that operation.
Information provided by you when using the Forums
In order to set up an account to use the Forums, we will collect the following information from you:
- email address;
- password; and
- a unique Forum User ID which identifies your account.
If you wish to do so, you may also provide the following information when using the Forums:
- date of birth;
- a link to your website;
- details relating to your accounts for the following: Yahoo Messenger; AOL; Facebook; Google+; Skype; Twitter; YouTube and ICQ.
Information collected for the purposes of providing analytics
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
- how many times you visit the Website;
- which pages you go to;
- traffic data;
- your IP and MAC address;
- your internet service provider;
- your Device ID;
- your Console ID;
- your user ID (which is generated by us and allocated to you when you first play our Games);
- your device operating system & version;your device make and model;
- game play attempts, progression and results;
- session game time start, end and duration;
- the country of your device; and
- identification of crashes and defects.
We use the third party analytics provider Google Analytics, as well as data provided by third party platforms such as PlayStation and Steam.
Google and Steam may collect analytics data on our behalf and in accordance with our instructions, and their applicable privacy notice. If you would like to find out more about the way Google and Steam collect and process this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://policies.google.com/privacy and https://store.steampowered.com/privacy_agreement/.
We also obtain data in respect of software crashes from Microsoft and Sony. This includes technical information about your device, the software and applications running on your device and your user ID.
Content created by our users which we host and display on the Forums and in the Help Centre, or which is submitted to us through the Website
When users submit their own User Content to the Forums or Help Centre, this content may contain personal and non-personal information.
You may also submit information to us through our Website, for example by emailing us at our general contact email address firstname.lastname@example.org or applying for a job at email@example.com.
This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Online Services to you
To record discoveries in No Man’s Sky
On of the key elements of our Game No Man’s Sky is exploration. When exploring the No Man’s Sky environment, you may discover planets, alien bases, flora and fauna. If you are the first to do so, your discovery will be named after you, based on your No Man’s Sky username. Those names are viewable by other players.
If you decide to stop playing No Man’s Sky, we will continue to use your username as the basis of the name of your discoveries. We do this in the pursuit of our legitimate interests.
To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content, Registration Information, and Analytics) so that we can analyse and improve our Games and Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Games and Online Services.
To respond to your enquiries and requests for support and to enable you to use the Forums and Help Centre
Zendesk helps us to operate our Help Centre and process Support Information for us. Studios Alice & Smith and Moov2 help us offer our Forums and process Forum Information and User Content for us.
We may use User Content, which may include CV data or other information you submit to us in application for a job, and references obtained from third parties, for recruitment. We do this in the pursuit of our legitimate interests.
Authentication – To log you into our Website and Games and keep you logged in.
Preferences – To remember information about you such as your preferred language and configuration.
Analytics – To help us understand how you use our Games and Website, and how often, so we can improve them to deliver a better experience for our users. To carry out research and statistical analysis to help improve our content, products and services.
Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Games and Website.
We work with third parties who may also set cookies on our Website, for example Google Analytics, Facebook, Twitter and YouTube, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Games and Website.
5. DATA SHARING
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Hello, our customers, or others.
Digital Content Stores: Where the Games are downloaded through Steam, Xbox Live and/or PSN, we may disclose your personal information to Valve Corporation, Microsoft, Sony, Google and/or Apple respectively for the purposes of facilitating any payments made through these platforms.
Help Centre: We use a third party platform provider called Zendesk to manage any support requests, queries and issues raised by users through the Support. Further details about the way in which Zendesk may collect and process your information can be found in their terms at https://www.zendesk.co.uk/company/customers-partners/privacy-policy/.
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you would like to exercise any of your rights in respect of your personal data, please contact us at firstname.lastname@example.org.
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know by sending an email to email@example.com
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
- you consented to our processing the personal data, and have withdrawn that consent;
- we no longer need to process that personal data for the reason it was collected;
- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Hello or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed;
- you need the personal data to be deleted in order to comply with legal obligations;
- the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
- If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
- If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
- If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
8. DATA RETENTION
If you would like us to delete your Forum account or any User Content that you have posted, please let us know by sending an email to firstname.lastname@example.org
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
11. INTERNATIONAL DATA TRANSFERS
It is possible that your personal information may be transferred outside of the EEA by third parties that process personal data on our instructions, such as Microsoft Azure, Zendesk, Google, Valve Corporation, Microsoft, Sony and Apple. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.
Our servers are hosted by Microsoft Azure located in Virginia, USA.
Where we transfer your information outside of the EEA, we implement appropriate safeguards to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to email@example.com.
All questions, comments or enquiries should be directed to Hello at firstname.lastname@example.org. We will endeavour to respond to any query or questions within three business days.
© 2018 HELLO GAMES LTD. All trade marks are the property of the relevant owners. All rights reserved.