Privacy Policy

Last updated: 2021-10-25 (Changes since 2021-07-05: added AppsFlyer and Facebook, more examples of device characteristics)

This Privacy Policy applies to your ("you", "the User", "the Player") use of the service Drill Wars ("the Service", "the App", "the Game") by Pixel Ceremony Oy ("the Company", “us”, “our” or “we”).

This privacy policy describes:

  • What personal data we collect about you and why.
  • How we protect your personal data.
  • Who we share data with.
  • What rights you have regarding the data collection.

The latest version of this privacy policy is available at https://drillwarsgame.com/privacy-policy. If we make any material changes, we will post a message in the Service that you will see when you start the app. Your continued use of the Service is subject to the latest privacy policy.

The data we collect

The following details the data we collect, how long we retain the data (at maximum), and why we collect it. In addition to the retention periods mentioned below, your data may survive in backups for up to 90 additional days.

When we say that we gather data for "analytics", we mean that the data is used for statistical and marketing purposes so that we can make informed choices when improving the Service and future products and services. Analytics data is primarily viewed in aggregated form so that data from an individual user cannot be distinguished. Analytics data may be shared with third parties as detailed below.

Our employees may view your data, including "analytics" data, individually only when:

  • the Game is in the pre-release "beta" phase, or
  • it is necessary to fulfill a support request by you, or
  • it is necessary to investigate an issue you report in a feedback form, or
  • it is necessary to investigate a technical issue, or
  • it is necessary to investigate cheating, fraud or threats to the security and stability of the Service or its users, or
  • it is necessary to investigate violations of the Terms of Service, including but not limited to abusive behaviour in the in-game chat.

In these cases, we will avoid looking at all of your data and only look at what is necessary to resolve the issue at hand.

Legal basis to collect and process your data

To perform our contract of delivering you the Service, we may process your data such as account credentials to enable your access to the Service, or communications between You and us (e.g. for troubleshooting purposes). We may also use your data to send you necessary communications relating to the Service (for example technical notices, security alerts etc.). You may revoke your consent at any time (to learn how, see Your rights and options).

Some of the data we process on other grounds, which means we do not require your consent to do so. For example, we have a legal obligation to keep the receipts of in-app purchases (which may include personal data) for accounting purposes.

Based on our legitimate interest, we may process some data for example for analytics, development and maintenance purposes. The data we use for these purposes does not identify you directly, and we only use it to make Drill Wars better for everybody, which is why we deem it reasonable and justified. Based on our legitimate interest we may also use some data for advertising purposes. However, you have the right to disagree, in which case you can object to such processing. To learn how to object, see "Your rights and options" below.

Personal data collected by us

Data Retention* Reason GDPR Legal Basis
The player name you choose 10 years This is shown to other players in multiplayer and in ranking lists. Contract
Hashed device identifier, shared by all applications made by the Company on your device. 10 years This identifies you to us when you've not logged in via an authentication provider. Contract (for authentication),
Legitimate interest (for analytics)
Randomly generated player identifier 10 years This identifies you independently of the authentication mechanism used. Contract
In-game chat logs 2 years Full logs of chats that you participate in. Contract**
IP address 30 days (technical logs only) For approximate geolocation, and for investigating technical problems, cheating, fraud and attacks. Contract
Geolocated country 2 years For multiplayer matchmaking and for analytics. Contract (for matchmaking)
Legitimate interest (for analytics)
Device ID for advertisers (on iOS) or Google Play advertiser ID (on Android) 2 years + third party retention Collected by third party analytics providers and advertisers, detailed below. Also used to pay for any ads that might have led you to install the App. Legitimate interest (analytics)
Android ID (on Android) or device fingerprint (on iOS) 2 years Used to pay for any ads that might have led you to install the App, if an advertiser ID is unavailable. May also be used by third party analytics and ad providers. Legitimate interest (analytics)
Gameplay recordings 2 years*** We may occasionally look at and record games. These recordings may be permanently published for marketing purposes. Legitimate interest (analytics, marketing)
Receipts of in-app purchases 6 years For accounting purposes, analytics, and fraud detection. Legal obligation (accounting)
Legitimate interest (other uses)

* Retention figures indicate how long we may keep the data by default since your last use of the App. Your data may survive in backups for up to 90 additional days.

** To resolve disputes and other issues regarding harassment, abuse and other behaviours forbidden in the Terms of Service.

*** Gameplay recordings where your in-game character and player name appear may be permanently published for marketing use. You may contact us to prohibit such publication.

Non-personal data linked to personal data

Data Retention* Reason
Gameplay statistics 10 years For multiplayer matchmaking, for displaying ranking lists, and for analytics.
What you write in the feedback form 2 years For development.
App usage events (e.g. "player X defeated player Y", "achievement Y unlocked", "entered menu Z") and their times 10 years For analytics.
Platform type (e.g. 'Android' or 'iOS') 10 years For analytics.
Device model and characteristics (e.g. display size, OS version, time zone, mobile service provider) 10 years For analytics.
Technical errors (e.g. "null pointer exception") 2 years For analytics.

* Retention figures indicate how long we may keep the data by default since your last use of the App. Your data may survive in backups for up to 90 additional days.

Data obtained from third parties

Advertisement platforms that led you to discover and install the Service may provide us with additional data about you. This data may include personal information, such as your gender, your interests or your broad age range. This data sharing is governed by the privacy policy of the platform where the advertisement is shown. We may connect this data with your profile in order to better understand how and where to market the Service. We retain this data for up to 2 years.

Data shared with third parties

We share some data with third parties that help us provide the Service or to do analytics processing.

Unless specified otherwise, the third parties listed here are classified as both "data controllers" and "data processors" under the GDPR. As a brief and incomplete summary of what this means, "controllers" may use the data for their own purposes while "processors" may only operate on the data under our express instructions.

Data Third party Further information
Any analytics data mentioned above, including device identifiers and attributes, and IP address Unity Ads Used to attribute installs to ad clicks, and to display in-game ads. Unity Ads may collect data about your device, your IP address and your interaction with the game and its in-game advertisements. They may share this data with ad publishers and attribution companies. You may limit ad tracking in your device's settings, or by tapping the data privacy icon when you first see and ad by Unity.
Their Privacy Policy: https://unity3d.com/legal/privacy-policy
Any analytics data mentioned above, including device identifiers and attributes, and IP address AppsFlyer Their privacy policy: https://www.appsflyer.com/legal/services-privacy-policy/
Opt out: https://www.appsflyer.com/legal/opt-out/
Any analytics data mentioned above, including device identifiers and attributes, and IP address Facebook Facebook may combine data about your activity in the Game with data about your other activities on Facebook.
Their privacy policy: https://www.facebook.com/about/privacy
Any analytics data mentioned above, including device identifiers and attributes Game Analytics Uses IP address to infer your country. Does not store IP address. Retention: 2 years.
Their Privacy Policy: https://gameanalytics.com/privacy
Any analytics data mentioned above, including device identifiers and attributes Google For linking actions in the game to Google ads. Google may also collect data to further personalize their products for you and to improve their products and services.
You may limit ad tracking in your device's settings.
Google's data sharing documentation: https://support.google.com/analytics/answer/9190671
In-app purchase receipts Google Play Your use of in-app purchases is governed by Google Play's Terms of Service.
In-app purchase receipts Apple App Store Your use of in-app purchases is governed by Apple's Terms of Service.
All data Google Cloud Platform Acts as a data processor only.
All data Hetzner Online GmbH Acts as a data processor only.

How we protect your data

We employ technical and administrative safeguards to protect your data against unauthorized access, alteration and loss. We implement a set of industry best practices, such as encryption and minimisation of access, in reasonable proportion with the sensitivity of the data we process.

All employee access to in-game chat logs requires a written justification and is logged.

Third party controllers and processors may transmit and process data outside the EU. We've taken steps to ensure that all transmission to and processing by third parties is done securely and complies with the GDPR.

Your rights and options

Under the GDPR, you have the following rights on all data that we hold on you or that any third party we've shared your data with holds on you:

  • You may request a copy of all the data.*
  • You may request the deletion of all the data.
  • You may request that we correct any incorrect data.
  • You may request that we transfer your data directly to another company or entity.*
  • You may restrict the processing of data e.g. if you need the data kept as evidence for a legal claim. Please see Article 18 of the GDPR for the exact conditions.
  • You may object to processing for direct marketing purposes.
  • You may object to processing for analytics purposes.
  • You may revoke your consent at any time, in which case we will cease any further processing of your data and erase it, unless we have a justified reason or legal obligation to keep the data.

* We will do this if feasible with reasonable efforts. Please note, that this "right of portability" applies to the data you have provided us, and thus may not apply to all the data we have about you.

If you would like to exercise these rights or revoke your consent, please send an e-mail to support(at)pixelceremony.com. Fulfilling these requests may require certain actions within the App by you. We aim to fulfill these requests within 30 days, unless we are overwhelmed by the amount of such requests.

After a data deletion request has been fulfilled, your data may survive in backups for up to 90 additional days. If we restore a backup containing data you requested to be deleted, we will delete your data again.

Data deletion requests are device-specific if you've not logged in with an authentication provider, such as Google Play Games or Apple Game Center.

If you resume your use of the app after a data deletion request has been fulfilled, more data may be collected.

We may keep a record of all correspondence regarding these requests for up to 2 years.

Age limits

We do not knowingly collect or solicit personal data about anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected personal data about a child under the age of 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.

Contact

If you have questions or would like to exercise your rights regarding personal data we collect, please contact us at support(at)pixelceremony.com

  • Name of data controller: Pixel Ceremony Oy
  • Business ID: 2738036-5
  • Address: Pohjoiskaari 15 A 2, 00200 Helsinki, Finland