Effective As Of Thursday, November 14, 2019

PRIVACY SETTINGS

This Privacy Policy notice will sum up the information CyberWolf Studios uses, why said information is used, and what your rights are as an individual. CyberWolf Studios will be referred throughout as "we""us", or "our". The Privacy Policy applies to our brand, websites and mobile games; the latter will have an additional section towards the end of the page. These may collectively be referred to as "services".

Here at CyberWolf Studios, we respect your privacy and take it very seriously. This Privacy Policy serves to enable us to be completely transparent about what data we require, why we require it, and what safety measures we use to protect it.

In this section, we have allowed you, as an individual, user to opt in or out of services we offer, so you are able to customise the experience to the way you want it.

CYBERWOLF STUDIOS PRIVACY POLICY

Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

Responsibilities

The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to CyberWolf Studios collecting/processing their personal data.

All staff of CyberWolf Studios who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject's attention and their consent to the processing of their data is secured.

Who are we?

We are CyberWolf Studios, an Indie Games Development studio. Although our address is situated in Bristol, our founders are actually scattered all over the UK. We develop our own in-house games, primarily for mobile. In the future we will be open to contract work.

Our Data Protection Officer (DPO) and data protection representatives can be contacted directly here:

  • Our contact page on this site
  • An email to khobdey@cyberwolfstudios.co.uk

What data do we need?

The only way CyberWolf Studios currently collects data from you is through the contact form on the Contact Us page. We detail what this data is used for below, however it must be known that at current this data is not given to any third party, nor do we store it in any database. It only comes to us as part of an email service so that we can respond to you.

The personal data that is currently collected from this form is as follows:

  • First Name
  • Surname
  • Email

This data is collected for the following purposes:

  • So that your experience when you contact us can be personalised.
  • Allows us to contact you back to respond to your message, if required.

Our legal basis for collecting the personal data:

  • Your Consent
  • Public task (so you can contact us, and we can reply in return)

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • The data collected is necessary in order to contact you in return
  • It is collected in your interest to provide a more personalised experience when we contact you back

The special categories of personal data are:

  • Biometrics, so we can contact you (after you have contacted us) and identify you when we do

Consent

By consenting to this privacy notice, you are giving us permission to collect and process your personal data specifically for the purpose identified. Consent is required for CyberWolf Studios to process all types of your personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent to various services by using the settings above.

Disclosure

CyberWolf Studios uses third parties on this website, however we will not pass any data over to them without first obtaining your consent (as per the services toggles at the top). The following third parties are used on this site:

  • Google Analytics

Google is a trusted third party, and you can find it's Privacy Policy here. We use this to help us identify what audience we have and thus ensure that we try and cater towards them. It is important for you to know that we have enabled a setting in Analytics that reduces the accuracy of your location tracking through your IP address, thus giving you more privacy. Again, none of this data will be sent to Google unless you enable the setting.

Retention Period

CyberWolf Studios will keep emails for up to two years, unless you request otherwise.

Your rights, as a data subject

At any point while we are in possession of or processing your data, you, the data subject, have the following rights:

  • Right of access - you have the right to request a copy of the information that we hold about you.
  • Right of rectification - you have the right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten - in certain circumstances, you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing - where certain conditions apply to have the right to restrict the processing.
  • Right of portability - you have the right to have the data we hold about you transferred to another organisation.
  • Right to object - you have the right to object to certain types of processing such as direct marketing.
  • Right to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by CyberWolf Studios (or any third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and CyberWolf Studios' data protection representatives Data Protection Officer (DPO).

PRIVACY STATEMENT

Personal Data

Under the EU's General Data Protection Regulation (GDPR) personal data is defined as:

"Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy statement tells you how we, CyberWolf Studios, will collect and use your personal data. At the moment there are three activities in which we collect your information;

  • Queries through our contact page
  • Google Analytics
  • Any complaints that might be made

Why does CyberWolf Studios need to collect and store personal data?

In order for us to provide you personalised responses to your queries, we need to collect personal data for when you make complaints and/or send us a query. We also wish to analyse where our audience are coming from so we can try and cater to as wide an audience as possible, thus improving the experience on our site for everyone. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes, CyberWolf Studios would contact you for additional consent.

Will CyberWolf Studios share my personal data with anyone else?

We may pass your personal data on to third party service providers contracted to CyberWolf Studios in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on our behalf. At the moment, the only case of this is Google Analytics. When they no longer need your data to fulfil this service, they will dispose of the details in line with CyberWolf Studios' procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will CyberWolf Studios use the personal data it collects about me?

CyberWolf Studios will process (collect, store and use) the information you provide in a manner compatible with the EU's General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. CyberWolf Studios is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practises. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will CyberWolf Studios contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

CyberWolf Studios at your request, can confirm what information we hold about you and how it is processed. If CyberWolf Studios does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the Data Protection Officer, where applicable
  • The purpose of the processing is based on the legitimate interests of CyberWolf Studios or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet the minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict, or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn't collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

CyberWolf Studios accepts the following forms of ID when information on your personal data is required:

  • Passport
  • Driving license

Document owner and approval

The Data protection Officer (DPO) is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

MOBILE GAMES PRIVACY POLICY

Overview

This section is specific to the mobile games we have released, and should be treated as an addition to everything else on this page rather than its own isolated section.

Platforms and IAPs

Our games can be found on many different platforms, so for simplicity we have listed these platforms here along with their respective privacy policies. When it comes to In App Purchases (IAPs), they are controlled through the supporting platform. We do NOT store your purchases on a database, or anywhere else for that matter. Nor do we store your purchasing details, such as your card or service details, such as PayPal.

Advertising

In some of our games, we have chosen to use the free model. It allows us to target a wider audience, but unfortunately requires us to produce revenue in other ways. One of the ways in which we create revenue is through advertising.

So far, we have used the Unity Ads service to supply our advertising, the privacy policy of which can be found here. We use Unity Ads as they are a trusted service. It should be noted that, by default, targeted advertising within our games is enabled through Unity Ads. You can, at any point, turn this off when an advert is shown. Turning this off will disable targeted advertising for this device, and will therefore receive randomised adverts instead. We advise keeping this turned on so as to see adverts for external services that may be of more interest to you.

Analytics

Our games may also make use of data analytics, which is essentially collecting data when certain events occur in-game. For example, when selecting a different character in Pixel Path, we track what character is selected. This allows us to see which characters are popular, so that in future we can release new characters that may also be popular.

Currently, our games use Unity Analytics for this service as they do not pry and only collect the essential data. Their privacy policy can be found here.

Notifications

If any of our games use notifications, you will have the ability to turn them off through the settings on your mobile device. We use notifications to alert you of various goings on within the game world that we wouldn't want you missing out on.

What Information Do We Collect?

There is a range of data that is collected for various reasons (see the next part for details), here is a list of what is collected by us or our third parties.

  • Device Identifiers
  • IP Address
  • Mobile Network Information
  • Time spent on the game
  • Scores achieved within games
  • Cookies

Please note that this is not a comprehensive list, we just wanted to highlight the important data collection aspects. For a more concise listing, we would advise looking into the privacy policies of the various third parties we use. These have been lsited and linked throughout this page.

Use of Information

The information collected above is used for the following reasons:

  • To deliver and improve our services
  • Allow you to personalise your experience; such as advertisements, content, or features
  • Save and associate your progress in our games either on the device or on the cloud of the platform you are signed into i.e. Google Play Games Services
  • For analytics reporting so that we can see what is working well, and what is not

IN CLOSING

Please note that we have the right to modify and update this as we deem necessary. So we recommend checking back here regularly to make sure you are still happy with the policy. If you are on the site after we have changed our policy, you will receive the notification to accept once again. This is to bring attention the fact that a change has occurred. If you use one of our services, we would advise checking back regularly.