Privacy Policy

This privacy policy will explain what information we collect online, why we collect it, and the choices we offer to you.

This privacy policy (“Policy“) describes the data practices of Digital Confectioners Limited. (“DiCo“) and DiCo’s subsidiaries (collectively, the “we“, “us“, or “Company“), covering DiCo’s services under DiCo’s control, including this website, any products, mobile applications, console or PC applications (collectively “Services“). By using the Services, you are consenting to this Policy and the processing of your data in the manner provided in this Policy. If you do not agree with these terms, please do not use the Services.

This Privacy Policy was last updated on August 8, 2018.

Information we collect

We may collect information about the Services you use and how you use them, such as the selections you make on our Services. We collect Personally identifiable information (“PII“), device-identifiable information (“DII“), and log information about your interactions as described below.

PII is information that can be used to identify or contact you online or offline, such as your name, address, email, and payment information. We may collect PII when it is provided to us, such as when you use our Services, attempt to contact us, submit a resumé or job application, or connect with us on social media or through one of our partners. For example, you may see a “Log in with…” button, which means we request PII from a partner to streamline the login process. You may be presented with a “request for permission” screen by a third party asking to share your ID, profile picture, and other listed information with us.

We may also create or collect DII, such as your Steam or other gamer ids, cookies, statistical identifiers, unique device and advertising identifiers, usernames, and similar identifiers that are linkable to a browser, device, or external account. We may also receive other information related to that ID, such as your IP address, user agent, timestamps, precise and imprecise geolocation, sensor data, apps, fonts, battery life information, and screen size.

Your account may include PII or DII, and may be linked to your gameplay data, such as in-game gameplay performance history, in-game communications (such as text chat), game event progression history, game event voting history, progression and rewards history, cosmetic skin crafting request details, configuration information, rewards inventory, play time, screenshots, workshop items, and more. By creating an account, you agree to send us such information, allow us to collect it, and to share it publicly with your username (e.g., on leaderboards).

Our Services also collect information about your interactions, including navigation paths, search queries, crashes, timestamps, purchases, clicks and shares, and referral URLs. We may combine this data with PII and DII. For efficiency, information about your interactions may be transmitted to our servers while you are not using the Services. We may also partner with third parties that collect additional information – please see their privacy policies for more details and see below for your choices regarding these parties.

How we use the information we collect

We use the information we collect from our Services to provide, maintain, protect and improve our Services, to develop new Services and offerings, and to protect us and our users.

PII is primarily used for business purposes, such as for sending you occasional newsletters and updates, hiring, responding to inquiries, logins, and providing Services. When you contact us, we may keep a record of your communication as well as the other information to help solve any issues you might be facing. We may use your email address to inform you about our Services, such as letting you know about changes or improvements. Please keep in mind that comments sections, forums, and other similar areas of our Services are public. Any information posted in those areas is viewable and usable by anyone that has access.

We make your gameplay data, such as achievements and missions, public and accessible via an API. Such gameplay data is not linked your name or email address.

We share PII with companies, outside organizations, and individuals for limited reasons, outlined below:

  • With your consent – We will share PII with companies, outside organizations or individuals if we have your consent to do so.
  • For external processing – We provide PII to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
  • For legal reasons – We will share PII with companies, outside organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public as required or permitted by law.
  • In case of a sale or asset transfer – If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including PII collected from you through your use of our Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on one or more of the Services.
  • In aggregated form for business purposes – We may share aggregated information and DII with our partners such as businesses we have a relationship with, advertisers or connected sites. For example, we may share information to show trends about the general use of our services.

We use DII to operate our Services and manage user sessions, including analyzing usage of our Services, preventing malicious behavior and fraud, improving the content, to link your identity across devices and browsers in order to provide you with a more seamless experience online, and helping third parties provide relevant advertising and related metrics. We share DII with third parties primarily for advertising and analytics purposes, for external processing, and for security purposes.

Third Parties

While we strive to work with reputable companies with good privacy practices, this Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you on the Services. We also do not control the privacy policies and your privacy settings with third-parties, including social networks and ad networks. We may use third parties to help offer you more tailored ads and better Services, such as obtaining analytics about the users of our site and to help tailor advertising to your preferences. For further information, please see the relevant privacy policies for each third party and industry codes of conduct. While we strive to work with reputed partners with strong privacy and security practices, we are not ultimately liable for their actions or practices.

Legal Bases for Processing

The data we process may qualify for multiple legal bases for processing under Article 6 of the General Data Protection Regulation (and similar laws that specify legal bases for processing). Below are our primary legal bases for each type of data for users covered under such laws:

It is contractually necessary and a legitimate interest to process your username (aka, your Gamertag), cookie data, IP address, game network IDs, gameplay data (e.g., achievements), tagline, user agent, virtual currency, and similar information to fulfill our obligations to provide you with high quality games and related services, such as forums and help emails. Gameplay data may be accessible publicly.

We have a legitimate interest in processing groups and relationships of users to enable matchmaking features, including related features such as debugging and analytics.

We have a legitimate interest and a contractual necessity in processing user chat data within the games, to enable social and similar features, and as necessary to moderate content that violates our terms of service.

Where users login with social media accounts, those companies have obtained consent on our behalf to use that data as described above. Consent is also obtained to add and engage with friends and other scenarios as appropriate.

We have a legitimate interest in conducting analytics, measuring usage and conversions, detecting fraudulent users, implementing data security measures, and analyzing game telemetrics to improve our services. We and our subprocessors have measures in place to protect your privacy.

We have a legitimate interest in processing users’ purchase history for the purpose of providing users help in diagnosing and fixing purchase and payment issues.

We have a legitimate interest in sending periodic emails and direct marketing to inform registered users of updates and offers. We make clear disclosures when users sign up and offer opt-outs for anyone not interested.

For HR and internal operations (including chat), we have a contractual necessity and legitimate interests to process the data of applicants and staff, such as for resumés and applications, payroll, internal chat and communications, and project management.

We have a legitimate interest in processing users’ personal data, including PII, to provide customer support and answer sales questions, including data such as emails, names, and other details as necessary to answer user questions. Similarly, we have a legitimate interest in processing personal data (e.g., names, social media profile data, and chat data/metadata) for the purpose of responding to questions and messages on our social media accounts.

Choice

If you do not allow us to collect information in accordance with this Policy, DiCo may suspend your access to any or all of the Services.

If you wish to cancel your account, you can do so by accessing our platform or contacting us for assistance with the process. Our email is included at the end of the privacy policy.

Like many other companies, we do not honor DNT flags but instead, offer other choices with respect to third parties. Many third parties participate in self-regulation to offer you a choice regarding receiving targeted ads. Please note that you’ll still see generic ads after opting out, but they won’t be based on your activities online. On the web, you can opt out of participating companies by visiting the following sites:

If you wish to similarly opt out of cross-app advertising on mobile devices, you can enable the “Limit Ad Tracking” flag on the device. Enabling “Limit Ad Tracking” sends a flag to third parties that you wish to opt out of targeted advertising on that device, and major mobile platforms require companies to honor this flag. Screenshots on how to find these options on various devices are available here: networkadvertising.org/mobile-choices. For options on other platforms or devices, please see their respective privacy policies to learn about the choices they offer.

Users covered under the EU General Data Protection Regulation (or similar laws) have the right to access their data, rectify mistakes, erase their data, restrict certain processing (i.e., opt-out), export their data, withdraw consent, and lodge a complaint with a supervisory authority. Before using these rights, we may ask you to verify your identity to ensure that only you can use these rights on your own account.

Accessing and updating your information

We aim to provide you with reasonable opportunity to access, update, and delete to your PII. In some cases, we may have to keep that information for legitimate business or legal purposes. When updating your information, we may ask you to verify your identity before we can act on your request.

Information security

We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold and undertake reasonable security measures with appropriate confidentiality, integrity, and availability protections. However, since no software or storage system is 100% secure, we cannot guarantee for the security of your information associated with the Services, or any other service for that matter. You can help protect your account information by using unique and hard-to-guess passwords. We store data for up to 10 years from the last login or contact from a user, or if we otherwise have a valid business reason or legal reason for keeping such data, for reasonable time periods.

Children

Our Services are not directed toward children under 13 and we will not knowingly collect information for any child under the legal age to provide consent to data processing (13 in the US and up to 16 in the EU). If you are the parent of a child under the age required to provide consent and have a concern regarding your child’s information on our Services, please contact us at the email listed at the bottom of this Policy.

Changes

Our Privacy Policy may change from time to time. We will post any changes on this page, including material changes. Please check back periodically to view changes to our privacy policy.

Questions?

If you have questions, you can find our current contact details at digitalconfectioners.com/contact.