Privacy policy | Reality - Big Data Games

General info

Hello, it’s Reality Games. Please read these Terms of Service, Privacy Policy and any other documents referred to below carefully (collectively called as the “Terms”). It governs the privacy terms of our website, located at reality.co, our games, and any other services and tools provided by us (collectively the “Services”).

About Reality Games

The Services are operated by Reality Games (London) Ltd. We are registered in England and Wales under company number 08983817 and have our registered office at Office 212, 15 Ingestre Place, Soho Ingestre Place, London, England, W1F 0JH. Reality Games (London) Ltd. is a personal data controller (shortly “Data Controller ”). Your personal data is also processed by Reality Games SA, ul. Jana Nowaka-Jeziorańskiego 3, 31-154 Kraków, Poland; KRS: 0000912367 (“Data Processor”).

Your privacy

We follow all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. The collection, processing of your personal data takes place in compliance with the provisions applicable under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

We collect and process your personal data, basing on:

your consent (art.6 point 1. a of GDPR);
for the purpose of execution of a contract between you and us (please refer to our Terms of Service available here)
in order to notify you about changes to our service;
our legitimate interest.

By “legitimate interest” we understand marketing purposes, analytical purposes (to improve our apps and services, to prevent cheats in our apps) and protection of personal data. We always take into account your interests and fundamental rights and freedoms, which prevail over the “legitimate interest” as a basis of processing of personal data.

We may use the personal data we collected from you to personalize the communication to you (including marketing communication). We may use the algorithms which would allow us to analyze your personal aspects, for example we may analyze your behaviour and decisions when using our apps to offer you targeted purchases or personalize your game experience

Personal Data processing

Personal data is only collected so far as it is technically required to provide the Services, improve it and run analyses. In no case will the data collected be sold or unlawfully passed on to third parties for any other reasons.

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly.

What type of data we collect and process?

We collect and process the following data from you:

Information that you provide by filling in forms on our services (like: first name, last name, your email address, your username, your photo). This includes information provided at the time of registering to use our services, subscribing to our service, posting material or requesting further services. We may also ask you for information, and when you report a problem with our services.
If you contact us, we may keep a record of that correspondence.
Details of transactions you carry out through our site and of the fulfillment of your orders.
Details of your visits to our services including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Your unique ID (ID of user logged in to Google Play, Game Center, etc).
Unique device ID (if you are not logged in to any of the above services).
IP address.
Information concerning usage of our services (how and when you use the services, your language).
Location related info (Country, time zone etc).
Device model & device properties (GPU, resolution, operating system, etc).
All game-related info (Save, highscores, progress, progress history, items etc).
Session numbers with timestamp; session detailed process (e.g. user entered this level, user lost this level, user entered this screen etc).
Purchases with timestamp; what player purchased, when, purchases count etc.
Information related to usage of social media, if you connected your social media account to our services

Only part of the above mentioned data qualifies as the personal data. Some of the data we collect do not allow us to identify you, and a collection of such data is not intended for identification of an user.

We may collect and process additional data, for example, if you contact our support.

Acess data/server log files

We and/or our web-space providers collect data about every access to our services (that includes our websites) (via what is referred to as server log files). This data includes: user’s activity data in applications, including progress in the game, ID numbers generated automatically, the user’s operating system, the referrer URL (the previously visited page), the IP address and the requesting provider. We only use the log data for analyses, bug tracking, for the purposes of operating, fraud prevention, securing and optimizing the offer and/or the product.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services. Examples of cookies we use: session cookies (we use these cookies to operate our Services)
and preference cookies (we use these cookies to remember your preferences and various settings).

Acess data/server log files

Transfer of the Personal Data to the third parties

We have the right to disclose your personal data to our service providers, which we use to provide our services, functionalities and apps to you. We use only trusted service providers who implemented sufficient technical and organizational means to assure that processing of personal data meet safety standards and your rights are sufficiently protected. The service providers, which process your data on our behalf include:

service providers providing the analytical tools,
service providers providing data storage services,
service providers for advertisement services,
payment services providers,
service providers helping us to manage our newsletter and communication with you,
social media we use for marketing.

We inform you that our service providers implemented their own policies and rules concerning protection of personal data. For more information please visit websites of the service providers

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Below you find a description of the categories of our service providers:

Unity Analytics, Game Analytics
This is an integrated service that allows us to track you as a certain user. This service identifies the user by unique ID (assigned to the device). It stores and processes data about users behaviour in game. It also stores and processes user’s IP to establish user’s country of origin.

Firebase, Google Cloud
This is the service that allows us to track you as a certain user. This service identifies the user by unique ID (assigned to the device). It stores and processes data about users behaviour in game. It also stores and processes user’s IP to establish user’s country of origin, installed application information, gender and your age for statistical purposes. Firebase allow us also to get info (via Big Query) about your behaviour in the game. It’s possible to log in to Firebase database via external providers (e.g Google, Facebook) or login/password pair where your e-mail address is passed to authenticate you.

AdMob, Meta, Liftoff, Ironsource, Unity, Applovin, Google Ad Manager, DT Exchange, Pangle, InMobi, Mintegral, BidStack

These are mobile advertising platforms. Sending your personal data (in order to personalize advertisements) will require your additional consent. Exemplary data that may be collected: installed packages information, email address, phone number, name, social media account information, device ID.

https://applovin.com/privacy
https://facebook.com/about/privacy
https://developers.ironsrc.com/ironsource-mobile/unity/ironsource-mobile-privacy-policy/
https://unity3d.com/legal/privacy-policy
https://vungle.com/privacy/

AppsFlyer
AppsFlyer’s Services enable us to attribute and track the performance of our advertising campaigns and applications, including their effectiveness, usage, installations and downloads.
https://www.appsflyer.com/services-privacy-policy/

Google Play, Apple iTunes
These are app stores where you can download our app and they are also our payment processor.

Facebook SDK, Facebook Stetho, Facebook Graph API, Foursquare OAuth
This is a service that allows us to track you as a certain user, provide you authentication or debugging functionality. This service identifies user by unique ID (assigned to the device). It stores and processes data about users behaviour in game. It also stores and processes user’s IP to establish user’s country of origin, gender and age.
Our app can request additional data about the user (such as friends list) from Facebook SDK. Each time such request is made Facebook SDK requests user for consent before providing us with any information.

Adwords
Adwords is an app add-on used to attribute users that have discovered our app via the Adwords advertisement services. The attribution is performed based on a referral ID or other link that informs where the user has found our app.

Google Play Games, Game Center
Google Play Games and other such services listed above are designed to enrich player experience by providing functionality of leaderboards, cloud saves, friends and such. In some games we provide information that allow to identify the user and some of its actions (like unlocking achievements) to utilize such functionalities.

Foursquare Labs
The Service incorporates software from, and interacts with, Foursquare Labs, Inc. in order for the App to provide certain location services and exchange data with Foursquare. Foursquare may collect and use information that does not personally identify you, such as your device type, advertising identifier on your device and device usage information (for example, a date/time stamp and your location when the App communicates with Foursquare). All such information is used by Foursquare for its own purposes in accordance with Foursquare’s privacy policy (available at https://foursquare.com/legal/privacy), as updated from time to time.

OVH SA, Hetzner
It’s computing platform, also a cloud computing platform. We use it to store and process all our users’ data. This data are necessary for us to provide our services.

Helpshift
This is a ticketing system for customer support. Any mailing communication is stored there, including email addresses, attachments etc.

Zendesk
This is a ticketing system for customer support. Any mailing communication is stored there, including email addresses, attachments etc.

2040
The 2040.io provide us automatic chat bot functionality and help us with customer support using artificial intelligence. Following data is collected: User information – name and email address, playerId and other information that you provide us during communication.

Mailchimp
By our newsletter we inform you about us and our offers, changes, promotions etc.
To effectively provide this service we use Mailchimp services. If you would like to receive the newsletter, we would require a valid email address from you as well as information that will allow us to verify if you are the owner of the stated e-mail address and/or if its owner agrees to receive the newsletter.
If you wish to get more information about Mailchimp privacy policy you need to visit https://mailchimp.com/legal/privacy/

GetResponse
By our newsletter we inform you about us and our offers, changes, promotions etc.
To effectively provide this service we use GetResponse services and their subprocessors.

Cision
By our newsletter we inform you about us and our offers, changes, promotions etc.
To effectively provide this service we use Cision services and their subprocessors. Cision is a global communications group of companies that enables to distribute meaningful public relations and marketing communications to the public, and measure the impact of those communications.

inBrain
inBrain.ai is a people-based insights and survey monetization platform that connects and rewards real people to surveys designed for them. inBrain.ai facilitates research for market research firms and brands by connecting them to consumers on monetizable mobile applications. By providing infrastructure for mobile research, inBrain.ai delivers high-quality data to firms, revenues to publishers, and opportunities for consumers. Read more https://www.inbrain.ai/

APPLE, GOOGLE AND AMAZON ARE NOT A SPONSOR NOR ARE INVOLVED IN ANY WAY IN THIS CONTEST/DRAW. NO APPLE PRODUCTS ARE BEING USED AS PRIZES

Transfer of the Personal data to third countries

We can transfer your Personal data to so called “third countries”, that is countries outside European Economic Area (such as United States of America). In case of such transfer we will base on European Union standard contractual clauses or Privacy Shield Framework.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including personal data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your personal data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

What are the purposes of processing your Personal Data?

We collect and process information held about you in the following ways:

To provide and maintain our Services
To provide customer support
To ensure that content from our services is presented in the most effective manner for you and for your supported hardware
To provide you with information, products or Services (in particular the apps we develop) that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
To carry out our obligations arising from any contracts entered into between you and us;
To allow you to participate in interactive features of our Services, when you choose to do so
To carry out traffic and software usage analysis
To notify you about changes to our Services
To improve and modify our products and Services (e.g. bug fixing, updates, apps development)
To manage your account you set up with us
To allow you and to manage your activities in our products and Services
To provide technical assistance
To provide you with our newsletters to which you subscribe and targeted marketing information
To notify you of changes to our Services and upcoming game releases.We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they
may contact you about these or in order to carry out usage, traffic analysis. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Data profiling

We gather and use personal data, such as your location, to offer special deals, sales, and bargains to you. You have the right to resign from profiling offers, but by opting out, you accept that the price of in-game virtual goods may increase significantly. If you wish to quit profiling, please, contact us at dpo@reality.co.

Where we store your Personal Data?

The data we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”). They may also be processed by personnel operating outside the EEA who work for us or for one of our suppliers. Such personnel may be involved in, among other things, processing your order, processing payment details and providing support services. By submitting your personal data, you consent to such transfer, storage or processing. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy. In case of such transfer we will base on contractual clauses which give personal data the same protection as it has in the United Kingdom or the EEA.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or services, you are
responsible for keeping this password confidential. We ask you not to share a password with anyone.

Reality Games and our partners will take any reasonable actions regarding collecting and processing personal data, in a safe way using generally available technology that according to our knowledge could provide such a security and is known to be efficient and technically stable.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long we will keep your Personal Data?

We keep your personal data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf. Of course, if we collect and process your personal data on your consent, we can do this as long as the contract between us is valid or until you withdraw your consent. When we no longer need to use your personal data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems within 5 years.

Your rights

You have the right to:

The data subject is entitled to obtain confirmation from the Controller as to whether personal data concerning him or her is being processed, and if this is the case, he or she is entitled to access it and the information provided in this provision.
access to their personal data, to rectify (correct, complete) them, to limit their processing or to delete them.
to transfer personal data provided to us, if the processing of such data is based on consent or contract and by automated means.
of these data is carried out on the basis of consent or agreement and by automated means.
to withdraw the consent given for the processing of personal data at any time. Revocation of consent to processing will not affect the lawfulness of the processing that was carried out before its withdrawal;
to object if your personal data is processed on the basis of the legitimate interest of the Administrator.

If you have any questions or requests regarding your personal data, please, contact us at dpo@reality.co or you can:

Lodge a complaint with the supervisory authority in charge of personal data protection if the processing of your personal data is deemed to violate the GDPR. The supervisory authority on the territory of the United Kingdom is the Information Commissioner’s
Office (Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF United Kingdom, https://ico.org.uk/).
Contact the EU Representative, EDPO. (Avenue Huart Hamoir 71, 1030 Brussels, Belgium, https://edpo.com/).

Amendments to Privacy Policy

Any personal data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.