Privacy Policy

These terms apply to the use of the Ping Online Communications (“Ping Creates” / “we” / “us”) services and as further detailed below. Our registered office is at 9 Atholl Place, Dunblane, FK15 9AQ. We are a company registered in Scotland, with company number SC371730 and VAT number GB 988 5609 48.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of our games, and websites.

We are committed to protecting the privacy and security of the personal data of our customers (“you” or “your”). As the “controller” for the purposes of the General Data Protection Regulation 2016/679 (“EU GDPR”), the GDPR as it forms part of the laws of England, Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR” and together with the EU GDPR, the “GDPR”), and the UK Data Protection Act 2018 (“UKDPA”), we are responsible for ensuring that your personal data is processed in accordance with applicable data protection laws.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal data we hold about you.

This Privacy Policy should be read in conjunction with our Terms and Conditions as may be applicable in respect of the Service. Where Terms and Condition are applicable, they will be made available via the Service.

The Service may contain hyperlinks to services owned and operated by third parties. Where this is the case, please review any third-party’s own privacy policies for further information about their purposes, how they use personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk. For information about our cookie practices, please see below and our Cookie Policy.

This Privacy Policy describes how we collect, use, and disclose personal data about you when you use our games (“Services”).

Collection of Personal Data

We collect personal data from you when you use our Services. This may include the following types of personal data:

• Contact information, such as your name, email address, and phone number (for example when you submit a support enquiry with us);
• Your account username;
• Your account password; and
• Your date of birth

Technical and usage data

We may collect technical and usage information about your activities within our Services, including the games you play, how you interact with our Services, and other similar information (“Technical and Usage Data”). Personal data we may collect in this way includes:

• Payment information, such as your credit card number and billing address
• Gameplay information, such as your game progress, achievements, and preferences
• Device information, such as your device type, operating system, and unique device identifier (UDID)
• Log information, such as your IP address, browser type, and access times
• Error and crash data (identifying a Service crash event);
• Advertising identifier numbers (such as IDFA (iOS devices) and ADID (Android devices))

Analytics and profile information

We may collect, or create by analysis of other Services Information, analytical information in connection with your Service usage including without limitation:

• When you first launched / began using the Service;
• Whether you use our free Services, or whether you use paid-for Services and how much you spend;
• Whether you discovered our Service organically, or whether you discovered the Service through an advertising campaign;
• What your Service usage habits are (for example, whether you use the Service in a particular way or only use a part of the Service and how often you use it); and
• We may associate your account with a user segment group which we think have shared characteristics, such as perceived interest in a particular type of gameplay or particular parts of our Services.

Direct marketing subscriptions

Some of our services, such as our websites, may offer direct marketing subscription services for you to sign-up to (to obtain news and updates from us, for example). The personal data we may collect from you for this type of service will be clarified on the relevant Service (such as in sign-up or tick-box information). It may include, without limitation, your name and email address.

Use of Personal Data

We use personal data for the following purposes:

• To provide and improve our Services
• To communicate with you about our Services
• Whether you discovered our Service organically, or whether you discovered the Service through an advertising campaign;
• To process your payments
• To personalize your gaming experience
• To analyse how you use our Services
• To comply with legal obligations

Cookies

A cookie is a text file placed onto your device when you access our Services. We use cookies and other similar or equivalent online tracking devices such as standard development kits (for mobile) to deliver, improve and monitor our websites, applications and games, including in the following ways:

Analytics

To help us understand how you use our Services, such as how often, so we can improve Services and deliver a better experience and also for us to carry out research and statistical analysis to help us develop new content, products and services.

Advertising

To help us deliver in-Service advertising to you, such as in our games (which may be served by, or facilitated by, third parties). These are also used to help us and our partners and vendors measure the effectiveness of advertising and whether it was actually served to you.

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your advertiser ID, IP address, your browser and/or other internet log information, this will not usually identify you personally.

Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Services or may not have the same quality of experience.

We may work with third parties who may also set cookies and equivalent technologies on our Services, for example: Unity, Google Analytics, Google AdWords, YouTube, Facebook, Twitter and LinkedIn, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Services.

For more information, please refer to our cookie policy.

Disclosure of Personal Data

We may disclose personal data to the following types of third parties:

• Service providers who help us operate our Services
• Payment processors who help us process your payments
• Analytics providers who help us analyse how you use our Services
• Law enforcement or government authorities when required by law or necessary to protect our rights or the rights of others

Personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our company, our personnel, our advertising and analytics service providers and our other 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.

Payment providers : Where you instigate a payment with us, your payment related information will be processed by third-party payment providers.

Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, 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: 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 data to third parties (e.g. our licensors, app operators, stores or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Ping Creates, our customers or others.

Digital Content Stores: Where our Service (or a part of it) is accessed through a third party store service such as (without limitation) an iOS, Amazon or Android application store, we may disclose your personal data to the relevant store/platform for the purposes of facilitating any in-Service payments made through these platforms.

Data Retention

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law or necessary to protect our rights or the rights of others.

Your Rights

You have the following rights over the way we process personal data relating to you, as set out in the list below. We aim to comply with requests without undue delay and within one month at the latest.

You have the following rights with respect to your personal data:

• To access and receive a copy of your personal data
• To correct any inaccurate or incomplete personal data
• To object to the processing of your personal data
• To request the deletion of your personal data
• To withdraw your consent to the processing of your personal data
• Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us.

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. Contact information for the Information Commissioner’s Office, the UK’s independent authority setup to uphold information rights, is available here: https://ico.org.uk/.

Technical and Usage Data

We may collect Technical and Usage Data to help improve our Services, analyze usage patterns, and identify areas for improvement. This data may be collected through the use of cookies, pixel tags, or other similar technologies. We may also collect Technical and Usage Data through our server logs and other similar technologies. We may use this information to provide and improve our Services, to personalize your experience, and for other similar purposes.

Children

Ping Creates takes the protection of the personal data of children very seriously. In accordance with the nature of our Service, we may process a limited amount of personal data about your child regarding their use of our Service. We do so only for the purposes set out in this Privacy Policy.

Your prior consent would be required in order for us to collect any other personal data from your child or in order to disclose, use or otherwise process your child’s personal data in a way not set out in this Privacy Policy. In the event that we learn that we have collected personal data from a child other than as intended in accordance with this Privacy Policy, we will delete that information as quickly as possible.

Security

Ping Creates will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

Please be aware that, while we make the security of our Service and your personal data a high priority, no security system can prevent all security breaches.

Note that the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Service; subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or legal obligations. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, contact us. We will endeavour to respond to any query or questions within a reasonable amount of time.