Privacy Policy

BACKGROUND:

Scary Beasties understands that your privacy is important to you and that you care about how your Personal Data is used. We respect and value the privacy of all of our customers and will only collect and use Personal Data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

Scary Beasties Limited is a limited company registered in England under company number 06452322.

Registered address: 3rd Floor, 35 Little Russell Street, London WC1A 2HH

VAT number: GB 935 3403 34

Email address: contact@scarybeasties.com

Postal Address: 3rd Floor, 35 Little Russell Street, London WC1A 2HH

2. What Does This Notice Cover?

This Privacy Notice explains how we use any Personal Data received by Scary Beasties: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your Personal Data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The Personal Data that Scary Beasties uses is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

        1. The right to be informed about our collection and use of your Personal Data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
        2. The right to access the Personal Data we hold about you. Part 10 will tell you how to do this.
        3. The right to have your Personal Data rectified if any of your Personal Data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
        4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your Personal Data that we have. Please contact us using the details in Part 11 to find out more.
        5. The right to restrict (i.e. prevent) the processing of your Personal Data.
        6. The right to object to us using your Personal Data for a particular purpose or purposes.
        7. The right to data portability. This means that, if you have provided Personal Data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that Personal Data to re-use with another service or business in many cases. We do not use your Personal Data in this way.
        8. Rights relating to automated decision-making and profiling. We do not use your Personal Data in this way.

For more information about our use of your Personal Data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the UK’s Information Commissioner’s Office (ico.org.uk)

If you have any cause for complaint about our use of your Personal Data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

The following Scary Beasties applications collect Personal Data:

  • Clods Wallup iOS and Android game.

Clods Wallup is a free-to-play game that generates revenue by serving targeted advertisements to players. These advertisements are enabled through our use of third-party software provided by a company called Unity.

To use its services, Unity requires the collection of Personal Data from your device as a default setting. Among other things, this may include Unique Device Identifiers, an IP address and information about your make and model of device. Scary Beasties itself does not store this data and cannot access it.

Unity allows you to set your preferences about the Personal Data Unity collects by tapping on the Data Privacy icon or “i” button which can be found on any Unity advertisement that you see. Unity provide further information in the Unity Privacy Policy and in the Unity GDRP FAQs as follows:

How are players able to opt-out of data collection?

When a player sees an ad served through Unity, there is a privacy icon that links to view her privacy settings.  Within these settings the player can opt-out or modify her preferences, and also view the Unity Privacy Policy. This appears on the end card of each ad they see in each game.

What happens if a player opts-out of data collection?

The player’s data is deleted and the player only sees non-targeted ads or ads based solely on contextual data.”

By downloading the Clods Wallup app you are agreeing to Unity’s collection of your Personal Data as described above and as set out in more detail in their Privacy Policy.

Other than as listed above, Scary Beasties does not collect any Personal Data via its mobile and online games or its websites.

If you choose to contact Scary Beasties via support@scarybeasties.com, any other Scary Beasties email address, by telephone or by post, we may store some or all of the following Personal Data:

  • Name;
  • Date of birth;
  • Gender;
  • Address;
  • Email address;
  • Telephone number;
  • Business name;
  • Job title;
  • Profession;
  • Details about an individual’s use of any of the applications for which we provide Support.

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using Personal Data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your Personal Data, or because it is in our legitimate business interests to use it. Your Personal Data will be used for the following purposes:

  • Supplying our support services to you. Your personal details are required in order for us to correspond with you regarding any issues or questions you may have regarding the apps for which we supply support services.
  • Communicating with you. This may include responding to emails, calls or written correspondence from you.
  • To inform our publishing partners of relevant information where we are responsible for supplying support services for an app store publishing account that does not belong to Scary Beasties.
  • Via third party software provided by Unity, the applications specified in Section 5. above may collect Personal Data for the purpose of supplying you with targeted ads. Scary Beasties does not store this data and cannot access it.

Other than as described herein or as required by law, we will not use your Personal Data for marketing purposes and we will not pass on your Personal Data to any third party.

7. How Long Will You Keep My Personal Data?

We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Personal Data will therefore be kept for the following period:

  • In relation to Personal Data made available through email, telephone or postal correspondence, two years from the point at which the reason for the communication has been resolved.
  • In relation to Personal Data collected for any application set out in Section 5, it will be stored by Unity for such time as they deem permissible and in accordance with Section 10 of the Unity Privacy Policy.

8. How and Where Do You Store or Transfer My Personal Data?

In relation to any Personal Data collected by Unity in the applications specified in Section 5, Unity states in its Privacy Policy that it “has implemented and maintains a framework consistent with applicable law for transfers of data outside of the country of collection, including for transfers out of the EEA. For further information, please see Section 9. of the Unity Privacy Policy.

In relation to any other use, we will only store or transfer your Personal Data in the UK. This means that it will be fully protected under the GDPR. Personal Data supplied via email will normally be stored within secure servers with copies potentially stored on password-protected devices. Personal data supplied in writing will be filed and stored in a secure place at Scary Beasties’ offices or in secure off site storage.

9. Do You Share My Personal Data?

We will not share any of your Personal Data with any third parties for any purpose, subject to two important exceptions:

  1. In some limited circumstances, we may be legally required to share certain Personal Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
  2. Where we supply application support services to a third party publisher and you have contacted us in relation to this service, we may be required to disclose your Personal Data in order to deal effectively with your query or issue.
  3. In relation to the applications specified in Section 5 above, the Unity software that is embedded in our application allows Unity to collect Personal Data.

10. How Can I Access My Personal Data?

If you want to know what Personal Data we have about you, you can ask us for details of that Personal Data and for a copy of it (where any such Personal Data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

We will respond to your subject access request within as short a time frame as possible and in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

In relation to Personal Data stored by Unity via an application specified in Section 5, please follow the instructions described by Unity as to how to delete your Personal Data as follows:

How are players able to opt-out of data collection?

When a player sees an ad served through Unity, there is a privacy icon that links to view her privacy settings.  Within these settings the player can opt-out or modify her preferences, and also view the Unity Privacy Policy. This appears on the end card of each ad they see in each game.

What happens if a player opts-out of data collection?

The player’s data is deleted and the player only sees non-targeted ads or ads based solely on contextual data.”

11. How Do I Contact You?

To contact us about anything to do with your Personal Data and data protection, including to make a subject access request, please use the following details for the attention of The Data Protection Officer

Email address: contact@scarybeasties.com

Telephone number: +44(0)20 7580 7272.

Postal Address: Scary Beasties,

2nd Floor, 35 Little Russell Street,

London WC1A 2HH.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects Personal Data protection.

Any changes will be made available at www.scarybeasties.com/privacypolicy

Last updated: 17 November 2020