PRIVACY POLICY

Support Information

We provide our support services via email (info@fireproofgames.com). Whilst it is entirely up to you to decide what information to provide to us in a support request, we may ask you for:

This may include:

• your name
• your email address;
• the Game causing an issue for you;
• the device model on which the Game is being played; and
• a description of the issue you are experiencing.

If you don’t provide this information, we may not be able to help. If you are under 18 years of age please ask a parent or guardian to contact us on your behalf.

Game Analytics

The Games The Room 2 and The Room 3 may automatically collect limited technical information about your use of the Games due to Flurry Inc’s analytics technologies being implemented in these Games.

Personal data that may be collected includes the following:

• your Device ID;
• 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;
• the time, date and install source of your first download; and
• identification of crashes and defects.

We do not view or use this data. It is collected because it is not technically possible to remove the Flurry technology from the relevant Games. However, the data is not viewed or used by us and deleted as soon as possible. Please reach out to Flurry Inc directly, if you have any questions.

Where you access the Game though a Store or third party distribution platform, these third parties may conduct their own analytics. This will be explained in their own respective privacy policies.

Website Analytics

When you visit our Website we collect technical information about your use of the Website through the use of Google Analytics Cookies (see more on cookies in section 6 below). Read Google’s overview of privacy and safeguarding data here.

This Google Analytics cookie is used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve our services. The cookie collects information on the number of visitors to our website.

The duration of the cookies is up to 24 months.

Sales Performance Data

The Stores allow us to see data in regards to how our Games are selling in the relevant Store in different territories. This is made available to us in aggregated form and we are not able to single out any one individual from this data, except as set out for the Google Play Store below.

Google Play allows us to see a list of customer orders of our Games. Each order is tied to an order number. When accessing an order number, we are also able to see previous purchases from the same customer. However, we do not see any directly identifying information such as the customer’s name, email or postal address. For purchases made from customers in the US, we are able to see their postcode, city and state (but no exact address or name). This order information in Google Play allows Fireproof to administer refunds, declined orders, monitor order statuses and it can help us spot fraudulent patterns.

If you post or upload any content about the Games on Facebook or Twitter, this will be under Facebook and Twitter’s privacy policies which can be found at https://www.facebook.com/full_data_use_policy and https://twitter.com/en/privacy.

Where you follow us or interact with our content, we may be able to see personal information from your social media profile (depending on your social media privacy settings), including:

• your name (and/or your social media unique user name);
• your email and/or postal address;
• your location;
• your telephone number(s);
• IP or MAC address;
• your gender and/or age;
• your correspondence with us through those channels; and
• your general interests and preferences (e.g. Likes, Shares, Posts)

Job Vacancy Information

We may ask you for, or you may submit, certain information to us whenever you respond to a job vacancy or apply for a job through the Website. This will normally include your CV or a portfolio of your work which may contain personal and non-personal information such as:

• your name;
• your date of birth;
• your email address;
• your qualifications;
• details of your previous work and/or employment; and
• any other information you include in your CV.

We will use information about you (including Game Analytics) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games.

We may process information about you (including Game Analytics, Website Analytics and Sales and Usage 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.

We may process Support Information so that we are able to properly respond to your enquiries and support requests.

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.

We may run online marketing campaigns on third party platforms (including Facebook and the Playstation Store). In order for our campaign to be more effective we target it to users based on broad categories such as specific regions or countries, age groups, users with an interest in VR or mobile games. Targeting is based on information collected and held by the third platform.

We do not share any personal data with them for advertising purposes or access their information. In order to find out how advertising is targeted and how your data is used to do so, please check the privacy policy of the platform on which you have seen our display advertising.

We may process Job Vacancy Information so that we are able to take steps prior to entering into a contract with you, including assessing your skills, qualifications and suitability for the role and/or communicating with you about the recruitment process. We may also need to process this information to enter into a contract with you.

We also have a legitimate interest in processing Job Vacancy Information during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process more efficiently, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We work with the Stores to assist us with fraud prevention and the detection of any illegal activity.

Group members, personnel, suppliers or subcontractors: We seek to keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

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 Fireproof, our customers, or others.

Digital Content Stores: Where the Games are downloaded through a Store, your personal information may be independently collected by the companies that run the Store (being Valve Corporation, Microsoft, Sony, Google, Apple, Facebook, Nintendo and/or Amazon respectively). Please check their respective privacy policies for details on this. Stores share Sales Performance Data with us as set out in section 2 above.

Support Services: We use a third party platform provider called Zoho to manage any support requests, queries and issues raised by users which are sent to info@fireproofgames.com.

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).

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 Fireproof 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.

• 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.

• 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. We are registered with the UK regulator, the Information Commissioners Office (ICO).

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve the Online Services in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. To find out more about cookies, including how to see what cookies have been set, visit https://www.allaboutcookies.org/.

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

We will hold Job Vacancy Information for a period of two years so that we can contact previous candidates when any new job opportunities arise at Fireproof which we think would be of interest or suitable for them.

We will hold any correspondence sent to info@fireproofgames.com or via the Support Services (which may include Contact Information) for a period of 12 months from the time we consider the correspondence ‘closed’, so that we can refer back to any previous support/help requests made by users. This enables us to offer our users the best level of support and help.

At the end of these periods or once you withdraw your consent, your data is deleted or destroyed.

This page tells you a lot of things about how we use information about you, when you play one of our games or spend time on our website. To help you understand all this, we have written down some key things here.

If you ask us a question or tell us about an issue by email, we collect your email address and anything you include in the email. We only use this to properly respond to your email.

The Room 2 and The Room 3 collect information about how you play them. For example, what device you are using to play the game and how much time you spent on different parts of the game. This is because of the technology in the game. We don’t use this information, it is automatically stored and then automatically deleted.

When you visit our website, we collect information about how you use our website but we only know that a person did certain things on our website, we don’t know your name and can’t connect this information to you. We just want to know how people use our website in general so we can make sure it’s great to use.

If you have bought our game through Google Play, Google lets us see the order and what other games have been bought by the same person. When seeing these orders, we don’t know your name and can’t connect this information to you.

The law gives you rights about your information. You have all the same rights as adults!  For example, you can ask us to delete all the data that we have about you or ask to see all the data we have about you. Make sure to ask a parent or guardian, if you want to use one of these rights or you’re not sure about what they are or mean.

We work with a handful of other companies to help us run the website and our games. To do this, we give them access to some of the information we hold. The information they get from us is not shared with anyone else and they are only allowed to use it to help us, and not for anything else.

If you have any questions about any of this, you should speak to your parent or guardian or ask us about it by sending us an email to datacontroller@fireproofstudios.com.

Please also remember that if you are under 18, you must get your parent’s or guardian’s permission to play our games.

Our terms of use prohibit users aged under 18 years from accessing our Online Services without their parent’s or guardian’s permission.

Depending on which Game a child is seeking to access, and via which Store they are accessing it, such Game may have an age rating. If so, this must be adhered to – a child must be at least as old as the age rating prescribed in order to play.

In the event that we learn that a child is in contravention of the above, we will delete their information as quickly as possible. If your child is accessing our Online Services without your permission or in contravention of the age rating, please contact us about this as soon as possible via datacontroller@fireproofstudios.com.

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.

Our servers are located in Germany and the UK.

As set out in Section 4 above, we use a third party platform provider called Zoho to manage any support requests, queries and issues raised by users which are sent to info@fireproofgames.com. Zoho are based in India and as such Support Information may be transferred there.

Where we transfer your information outside of the UK and/or EEA, we will have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data.  If you would like to find out more about these safeguards, please let us know by writing to datacontroller@fireproofstudios.com.  It is possible that your personal information may be transferred outside of the UK and/or the EEA by the Stores. 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 internationally.