Privacy Policy

Privacy Policy

The Fates

Last updated: February 27, 2021

 

The Fates, including its subsidiaries and affiliates (hereinafter “TF“) understands the importance of protecting your personal information (the “Personal Information“). We have adopted this privacy policy (the “Policy“) to explain how we collect, store, use and share the Personal Information that you provide to us or that we collect when you use the websites, applications, games, features, or any other function controlled by TF, as described in the Policy (the “Services“).

IF YOU DO NOT AGREE TO THE POLICY, YOU MUST NOT USE THE TF SERVICES.

A summary of the Policy is available below. In case of inconsistency between the summary and the Policy, the Policy will prevail.

 

Summary of the Policy

 

What Personal Information is collected by TF?

-Identification and contact data (e.g. internal identifier);

-Connection data (e.g. IP address);

-Location data (e.g. country of origin);

-Device and platform data (e.g. platform ID), and all other Personal Information detailed at sections 3 and 4 below.

 

For what purposes is the Personal Information used?

-Provide and operate the Services, including for the purposes of providing online leaderboards;

-Customize and improve the Services;

-Analyze and provide statistics of the use of the Services;

-Manage clearly unlawful conduct and misuse of the Services;

-Send newsletters and promotions;

-Treat job applications, and for other purposes detailed at section 1.

 

Is the Personal Information shared with third parties?

We may engage subcontractors to collect and process your Personal Information on our behalf and for our benefit, in order to provide certain services such as sending e-mails and processing payments. These subcontractors may be located in other countries, including outside the European Union. When the Personal Information is shared with our subcontractors, we take reasonable contractual measures to adequately protect the Personal Information. See sections 5 and 6 for more information.

 

How can you contact TF or exercise your rights related to your Personal Information?

Attn: Legal Department

By email at: libby@twistofthefates.com

 

Policy

 

TF has adopted this Policy to explain how we collect, store, use and share the Personal Information that you provide to us or that we collect when you use the Services. The definitions used in this paragraph have the meaning given in the preamble of the short version of the Policy.

IF YOU DO NOT AGREE TO THE POLICY, YOU MUST NOT USE THE TF SERVICES.

 

1. Use of Personal Information

TF may use your Personal Information for the following purposes:

-provide and operate the Services for example, to put you in touch with other players (matchmaking) if you have made such request, evaluate your progress in the game or for providing leaderboards;

-customize and improve the Services and the user experience;

-handle any transaction related to the Services;

-contact you to provide you with customer and/or technical support;

-analyze and report on the use and trends of the Services;

-ask for your opinion about the Services and conduct surveys on the Services;

-send you confirmation notices, updates, and security alerts;

-manage abusive uses of Services such as managing player bans;

-cease the clearly unlawful behavior of players;

-send advertisements, newsletters, promotions, rewards, and other types of content or features that match your profile and interests, including offering to participate in contests;

-customize the Services and the games, in particular by providing features, content or ads which correspond to your interests and/or your preferences;

-process job applications sent to TF;

-any other purpose described in the Policy, such as the pursuit of other legitimate commercial interests related to the use of the game and/or Services or when we collect your Personal Information with your consent for specific purposes.

If you choose to receive our newsletters and news releases, the Personal Information you have provided us will allow us to send you messages regarding new features, updates, contests and events that may be of interest to you in connection with the Services and Games. You may opt out of this service from TF at any time.

For some of our games and/or websites, except in the event that you do not give your consent, we may share or match some of your Personal Information with selected partners to provide you with personalized ads and/or content or better targeted our marketing efforts.

In any case, we will only use your Personal Information when necessary to achieve the purposes described above and the legitimate interests of TF, or where permitted or required by law.

2. Personal Information Processed

We may collect, process, use and/or share, depending on the game or Service used, Personal Information collected automatically, that you have provided to us, or that has been provided by third parties, including:

-your identification data, for example, your surname and first name, date of birth, including your account information such as  your internal identification code and/or the identification code associated with the game platform used or your device;

-your contact details, for example, your address and email address;

-your connection data, for example, your IP address and logs;

-the history of your purchases as part of our Services;

-your game history for example, your score and your level;

–information you provide us in response to surveys, contests or other promotional activities;

-data concerning our ongoing commercial relationship, for example, your billing history or items purchased;

-information you provide when contacting our support services;

-approximate location data, derived from your IP or device settings;

-any other data that you provide us as part of the Services, or that we collect with your consent to provide you with the Services or for specific treatments.

We may also collect and store information through technologies detailed at section 3.

You may choose not to provide certain Personal Information, but you may not be able to use certain Services or features. You can contact us as provided in section 14 for any questions.

Public data, including user-generated content, online forums, blogs, chat and profiles

You may communicate Personal Information when you provide content on the Services, as part of games, or in online forums, blogs, discussion platforms, public user profiles or other similar forums on our Services or as part of our games, such as chats (the “Forums“). The Personal Information you disclose in the Forums becomes public data and may be read or used by other users without your consent. If you decide to disclose Personal Information on the Forums, you do so at your own risk and we are not responsible for the use of such Personal Information by third parties.

 

3. Collection of Personal Information

We collect your Personal Information when you send it to us expressly and directly or when we use the technologies described below which collect such Personal Data.

We collect your Personal Information when you:

-use the Services, create a user account or public profile;

-make purchases in our online stores or purchase virtual items in our games;

-create content as a user;

-use the interactive content of the Services or view ads, including personalised ads, on the Services or those of our partners;

-subscribe to an email newsletter and other promotional content;

-contact TF’s customer support, social media, or request technical assistance;

-respond to a survey, register for a contest, an event or a promotional activity;

-participate in a forum or chat online using our Services;

-apply to become a beta tester or participate in a play test;

-register a product online or download patches and demos;

-are not in compliance with the Terms of Use and/or code of conducts of our games, Services, Forums, websites, in the event we must keep your Personal Information to apply sanctions.

We may also collect your Personal Information when the following technologies and/or services are used:

 

3.1. Analytics technologies

We use internal analytics technologies and those of third parties to collect Personal Information generated by your device and/or operating system through log files. This Personal Information may include, when available, the IP address and device ID, as well as game statistics (including scores, rankings, and your public external identifier). This Personal Information is collected to manage and improve the Services, ensure the security of the players, as well as offer adapted and personalized content.

Third-party analytics tools (including, but not limited to, DeltaDNA) may associate the Personal Information they collect in connection with the Services, with personal information that they independently collect on other services, as governed by their individual privacy policies. TF does not collect or access any data that may be independently collected by these third parties. As these third parties operate independently from TF, a list of these companies and information on how to opt-out, if applicable, is available at the link indicated at section 5.

 

3.2. Cookies, Analytics Metric Tools and Other Technologies

Cookies, or similar technologies, are small computer files stored on your hard drive via your web browser. We use cookies for several purposes depending on the game and in particular to adapt our content to your interests as well as to provide and manage the use of the Services, such as reCAPTCHA.

We may also use certain cookies on our websites that can only collect generic Personal Information in order to save your browser configuration and personalize the appearance of these websites. We also use anti-cheat technologies in Services that use cookies, as described below.

You may decline the storage of cookies by changing the configuration of your web browser. However, if you decline, the Services and/or our websites and/or certain features may not work properly. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.

 

3.3. Ads Serving Technologies, Including Interest-Based Ads

Our Services, specifically some of our mobile applications, may integrate ad serving technologies, including for personalised ads, from our suppliers (including, but not limited to, UnityAds) that may use pixels and/or other similar technologies for these purposes. Data collected by these third parties may include, without limitation, (i) your age and/or sex, (ii) your IP address and/or country, (iii) the advertisements placed and their location in the Services or the game, (iv) the duration of visibility of an advertisement as well as the number of views, (v) the identifiers and settings of your device, (vi) your use of the Services, products, and/or other websites (including third party websites) you have viewed (as well as the date and the time of such viewing), and/or (vii) your responses to the advertisements, if any, to allow our suppliers to calculate the number of views of the advertisements or to present ads in a format that best suits your device.

For some of our games and/or websites, except in the event that you do not give your consent, we may share or match some of your Personal Information with selected partners to provide you with personalized ads or better targeted our marketing efforts.

Advertisements and content from our Services and games may be tailored to your interests, for example, you could view an offer for a game that might interest you.

Third-party advertising networks may associate the Personal Information collected in the context of delivering ads to you with data that they have collected independently from other services over time as part of their own privacy policies. As these third parties operate independently from TF, a list of these companies and information on how to opt-out, if applicable, is available at the link indicated at section 5.

TF does not collect or access data that may be independently collected by these third parties. To learn more about some of these ad network practices, you can visit www.networkadvertising.org, www.aboutads.info/choices, or www.youronlinechoices.com.

 

3.4. Anti-cheating services

For certain games, we use anti-cheating services (“Anti-Cheating Services“) that are operated by third parties (including, EasyAntiCheat and Battleye) via a client software (the “Software“) that is integrated in the game. When you start a new game session, the Software may automatically load and install its latest version on your device. When using the game, the Anti-Cheating Services may scan the game’s binary files and the device’s memory to detect and prevent cheating in the game (the “Objective“). By installing or using any TF game, you agree that the Anti-Cheat Services may collect, store and publish Personal Information for the sole purpose of fulfilling the Objective and also to identify players who cheat in games and prohibit them from doing so. This Objective is necessary to pursue our legitimate interests and to ensure the safety of the players in the game. If you think that your access to our games has been blocked by mistake by the Anti-Cheating Services, please contact us at libby@twistofthefates.com.

 

3.5. Social Media Features

If you choose to use social media features in some of our games or Services, especially mobile games, you may be required to connect to a social media network through these games or Services. You may be able to use these social media features to connect to the game, find out if your friends play certain games, and invite them to join you in these games. The social media network can then provide us with Personal Information such as your social media network user ID, your profile picture (to create your avatar in certain games) and the user IDs and profile pictures of your contacts on the social media network, and any other Personal Information that you have consented to transfer to us from your social media network. In order to limit the Personal Information that is transferred to us via social networks, please modify your sharing settings in your account on the appropriate social media websites.

 

4. Legal Basis of Personal Information Processing

The processing of your Personal Information is justified by the following legal bases:

  • for the execution of your contract with TF to provide you with the Services;

  • for the pursuit of TF’s legitimate interests as well as your own interests, to ensure that the Services function in the best possible way;

  • because it requires your consent, for example to send you newsletters;

  • because it is necessary for the respect of legal and regulatory obligations, for example, to stop the clearly unlawful conduct of a player within a game.

 

5.Personal Data Shared with Third Parties

Subcontractors

We may, from time to time, hire subcontractors to provide us with certain services, such as sending e-mails, process payments, host data, and provide customer support. Solely for providing us these services, our subcontractors may have access, collect and/or store Personal Information.

Partners

We may also provide Personal Information to our business partners helping us offer the Services and games to you, such as the platforms on which you play our games, solely for these purposes.

We may share Personal Information that does not identify you directly, which is anonymized or aggregated, with third parties, for example to analyze trends in the use of the Services.

Cross-Platform Sharing

Some of our games or Services may allow you to connect and play with users from a platform different than yours or to connect your account on different platforms. When you play with someone on another platform, that other platform may receive certain Personal Information such as your platform’s ID. To allow your cross-progress in a game to continue between platforms, as well as allow certain purchases made on one platform to be available on another platform in your account, certain Personal Information may be shared with your platforms strictly as necessary to enable these features. The Personal Information shared with these platforms is subject to their respective privacy policies, as detailed below.

 

Disclosure for Legal Purposes

We will never share Personal Information that identifies you directly, with other third parties without your consent, except as required by law or where it is reasonably necessary to enforce our rights. Unless required by law, TF is not obligated to notify you of such disclosures of Personal Information.

General Information and List of Third Parties

We do not share, sell (as this term is defined under applicable privacy laws, such as the California Consumer Privacy Act) or disclose your Personal Information except as described in this Policy.

In addition, we do not control the data sent by your web browser to third parties who receive this information in your normal course of activity on the Internet.

All the third parties with who your Personal Information may be shared have the same obligations as TF to comply with applicable data protection laws. We also take reasonable contractual measures to ensure that these third parties adequately protect the Personal Information, including as detailed at section 6.

A list of our suppliers or partners which may have access to your Personal Information for the purposes of allowing us to properly operate our games and Services, is available at https://www.TF.com/partnerprivacy/

 

6. Location and Transfer of Your Personal Information

The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners in the United States, such as Amazon Web Services, as well as on our servers or our partners’ servers in Canada (which is a jurisdiction with an adequate level of protection recognized by the European Commission) or in Europe.

Some of our subcontractors may be located in other countries, including outside the European Union. By using the Services and the games, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country.

TF takes reasonable contractual measures to ensure that our subcontractors adequately protect your Personal Information and treat it solely for us and for the purposes set out in the Policy. Further, in the event of transfer to countries outside of the European Union, the protection of your Personal Information is ensured by “standard contractual clauses” approved by the European Commission. Our subcontractors are prohibited from using your Personal Information for any other purpose without your consent.

To obtain a copy of these warranties or information on how to access them, contact libby@twistofthefates.com.

 

7. Retention Period of Personal Information

TF keeps your Personal Information for a period not exceeding that required for the purposes for which the Personal Information is processed, and in accordance with applicable legal requirements.

Your data will be kept in TF’s active database, for example:

-for the time necessary to provide the Services,

-for the duration necessary to solve your technical problems or your request,

-for the time needed to compile game statistics,

-for 30 days for IP addresses and logs.

At the end of this period, your Personal Information will be deleted or anonymized by TF, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed depending on your cancellation or re-enrollment in the Services, or applicable law.

 

8. Safeguards of your Personal Information

TF takes different measures for the security of your Personal Information. We follow generally accepted rules in the rpg tabletop game industry, as well as applicable regulations, to protect any loss, destruction, alteration, or unauthorized, unlawful or abusive use of the Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information however, no security measures are 100% effective. TF declines all liability if the Personal Information is subject to unauthorized use or access.

If you have any questions regarding the safeguards of your Personal Information, contact libby@twistofthefates.com.

 

9. Your Rights and Choices on Your Personal Information

How to Exercise Your Rights

For games for which you have created an account, you can access, modify, update and delete any Personal Information at any time by logging into the relevant Service and accessing your account settings.

If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, oppose to its processing or request the limitation of its processing, if applicable, or withdraw your consent, if applicable, or transfer them to another online provider, where technically possible, you may email us at libby@twistofthefates.com. Please note that the withdrawal of your consent will not compromise the lawfulness of the processing done in the past.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Process of Your Request

In the case of an email request, you must confirm your identity, as well as provide your contact information, the subject of the request and the Personal Information concerned. We reserve the right to ask you for other information to confirm your identity.

We will correct, update or delete your Personal Information or cease or limit its processing, as requested, and in accordance with our legitimate interests.

Your request will be processed within thirty (30) days of receipt, with the understanding that TF reserves the right to extend this period to two months, in accordance with applicable regulations, due to the complexity and number of requests.

Deletion of Personal Information

Please note that if you choose to delete your Personal Information, you will no longer have access to the Services and TF games associated with your internal and/or external identifier and all progress in your game or items in your account may be lost.

Please note that TF may retain Personal Information required to resolve disputes, enforce our Terms of Use, protect our legal rights, and comply with technical and legal requirements regarding our games and Services. TF reserves the right to reject deletion requests if there is a legal obligation to retain the Personal Information due to legal claims or as required by our contracts.

Give and Withdraw Consent

You may withdraw your consent at any time or object to the receipt of newsletters or advertising emails by following the steps detailed in such communications.

To withdraw your consent for the personalisation of advertisements, you may activate the settings “Limit Ad Tracking” on Apple devices or the “Opt-out of Ads Personalisation” on Android devices. In the event your consent was expressly provided to TF or its partners for ads personalisation in a game you may withdraw your consent as indicated in the related game.

 

10. Children

TF DOES NOT KNOWINGLY COLLECT OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE 13 YEARS AND LESS, OR BELOW THE MINIMUM APPLICABLE AGE IN COUNTRIES WHERE THIS AGE IS GREATER THAN 13 YEARS, DO NOT SEND YOUR PERSONAL INFORMATION TO TF.

In certain games for children, including Tree World, we collect identifying information such as user IDs and IP addresses, for the sole purpose of providing adequate functionality and support to our Services and protecting the security and integrity of the game.

The Services may contain advertisements concerning our products or services or those of third parties. When we truly know that users are 13 and under, no behavioural advertising will be displayed to these users in the Services.

 

11. Third party services

The Services may contain advertisements or links to third-party websites such as Twitter, Facebook and/or YouTube. The presence of these links on our Services does not constitute an approval, an authorization or an affiliation with the website in question. If you click on these links or use the services of a third party, you will leave the Services of TF and you must consult the privacy policy of the website in question before sharing your Personal Information.

Certain products and/or services are offered to you as part of our Services in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their treatment will be subject to their privacy policy.

We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee the same data protection practices.

 

12. Conditions of use of TF services

The terms of this Policy are incorporated into TF’s Terms of Use and all capitalized terms found in this Policy have the meanings given to them in those Terms which you may refer to at the following link: https://www.TF.com/behaviour-tou/

 

13. Changes to the Policy

We reserve the right to change the Policy at any time. If we change the Policy, we will post the changes in the Services, or any other appropriate location so that you are fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after being posted. Your continued use of our Services will be deemed as an acceptance of the changes to the Policy.

 

14. Communicate with TF

If you have any questions or concerns regarding this Policy, please contact us by email at libby@twistofthefates.com.