Effective Date: 9 November 2022
This Privacy Notice applies to the use of the video game Super Spatial and related in-game services (“Game”) as well as data processing activities related to the Game. The references below to the “GDPR” refer to the EU or UK General Data Protection Regulation and only apply if you are in the EU or UK.
The responsible data controller for any personal data collected and processed in connection with the use of the Game is Dazzle Rocks Oy, Erottajankatu 1-3 A 8, 00130 Helsinki, Finland (“Dazzle Rocks”, “we” or “us”).
If you have any questions about or in connection with this Privacy Notice or would like to appeal or complain about our handling of your personal data or exercise any of your rights (see 9. below), please contact us by using the following contact details:
Dazzle Rocks Oy, Erottajankatu 1-3 A 8, 00130 Helsinki, Finland Email address: info@dazzle.rocks Telephone: +358 40 1973185
This Privacy Notice applies to the processing of personal data of users of the Game. The Game is not intended for users under 13 years of age.
We collect and process your personal data only for the following purposes:
5.1 Data collected from you:
Furthermore, we process data on how you use the Game such as player statistics, currently active status, features you use and for how long, play time, game progress and similar in-game related data (“Game Progress Data”).
The processing of the Game ID and Game Progress Data is necessary for the performance of the contract (Art. 6 (1) (b) GDPR).
We also process Game Progress Data for monetization purposes, for instance to optimize in-game purchases based on playerbase interest. The processing in this regard is necessary for the purposes of our legitimate interests (Art. 6 (1) (f) GDPR) in monetizing our product, which is otherwise free to play. You can obtain more information about the balancing of interests by contacting us (for contact details see 3. above).
The processing in this regard is based on your consent, which you have given by voluntarily entering your email address on our website in order to be informed about the launch of the Game (Art. 6 (1) (a) GDPR).
We process player spending data for marketing and monetization purposes in order to analyze and optimize sales. The processing in this regard is necessary for the performance of the contract (Art. 6 (1) (b) GDPR) and for the purposes of our legitimate interests (Art. 6 (1) (f) GDPR) in monetizing and marketing our product, which is otherwise free to play. You can obtain more information about the balancing of interests by contacting us (for contact details see 3. above).
We might also review in-game text chats when we receive a complaint or information about behavior prohibited by our Terms of Service www.dazzle.rocks/tos.html such as harassment, predatory behavior or other abusive or illegal acts.
The processing in this regard is necessary for the performance of the contract (Art. 6 (1) (b) GDPR) and in some cases for our and our user’s legitimate interests (Art. 6 (1) (f) GDPR) in a safe game environment.
The processing in this regard is necessary for the performance of the contract (Art. 6 (1) sentence 1 (b) GDPR) or our and legitimate interests (Art. 6 (1) (f) GDPR) in providing customer service.
5.2 Data collected from others:
The processing in this regard is necessary for the performance of the contract (Art. 6 (1) (b) GDPR).
The processing in this regard is necessary for the purposes of our legitimate interests (Art. 6 (1) (f) GDPR) in monetizing our product.
The processing in this regard is necessary for the purposes of our legitimate interests (Art. 6 (1) (f) GDPR) in marketing our product.
Please note that we process your personal data for other purposes than outlined above only if we are obligated to do so on the basis of legal requirements (e.g., transfer to courts or criminal prosecution authorities), if you have consented to the respective processing or if the processing is otherwise lawful under applicable law. If processing for another purpose takes place we may provide you with additional information.
Any access to your personal data by us is restricted to those individuals that have a need to know in order to fulfill their job responsibilities.
We transfer your personal data for the respective purposes to the recipients and categories of recipients listed below – more details regarding the recipients and categories of recipients mentioned under 6.1 and 6.2 below can be found in Appendix A - Recipients.
6.1 Private third parties – Affiliated private bodies within our group of companies may receive your personal data as necessary for the processing purposes described above. Furthermore, unaffiliated private bodies such as service providers that we use to provide the Game or other services might receive your personal data.
6.2 Data processors – Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data on behalf of us under appropriate instructions as necessary for the respective processing purposes. The data processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data, and to process the personal data only as instructed.
6.3 Governmental authorities, courts, external advisors, and similar third parties that are public bodies as required or permitted by applicable law.
Some of the recipients of your personal data will be located or may have relevant operations outside of your country and the European Economic Area, such as in the USA, where the data protection laws may provide a different level of protection compared to the laws in your jurisdiction and with regard to which an adequacy decision by the European Commission does not exist. Countries outside the European Economic Area, which provide an adequate level of data protection from a European data protection law perspective include Andorra, Argentina, Canada, Faeroe Islands, Guernsey, the State of Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and the Eastern Republic of Uruguay. With regard to data transfers to other countries outside of the European Economic Area we provide appropriate safeguards, in particular, by way of entering into data transfer agreements adopted by the European Commission (e.g. Standard Contractual Clauses) with the recipients or taking other measures to provide an adequate level of data protection, where this is required under applicable law. We will provide you with a copy of the respective measure we have taken upon request (for contact details see 3. above).
Your personal data is stored by us and/or our service providers, to the extent necessary for the performance of our obligations and for the time necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws. When we no longer need to process your personal data, we will erase it from our systems and/or records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject. E.g., personal data contained in contracts, communications, and business letters may be subject to statutory retention requirements, which may require retention of up to 10 years. If applicable, any other personal data will in principle be deleted 2 years after the termination of the respective related contractual relationship between you and us, if applicable).
If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Pursuant to applicable data protection law you may have the right to: request access to your personal data; request rectification of your personal data; request erasure of your personal data; request restriction of processing of your personal data; request data portability; and object to the processing of your personal data. Please note that these aforementioned rights might be limited under the applicable national data protection law. For further information on these rights please refer to Appendix B - Your Rights.
You also have the right to lodge a complaint with a data protection supervisory authority. To exercise your rights please contact us as stated in section 3 above.
10.1 Cookies. When you use our Game, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close the Game. A persistent cookie remains after you close the Game and may be used by the Game at a later stage. We may use third party cookies in connection with the services provided via our Game as well. For instance, we use some analytics service providers to collect and process certain analytics data.
10.2 How we use cookies and similar technologies. We may use cookies and automatically collected information to: (i) personalize the Game, such as remembering your information so that you will not have to re-enter it during your use of, or the next time you use, the Game; (ii) (iii) monitor and analyze the effectiveness of the Game; (iii) track your entries, activities, submissions, status, the region you are from and from which services you visited the Game. Tracking technology also helps us manage and improve the usability of the Game such as to identify the most popular regions the Game is played.
This Privacy Notice may require an update from time to time – e.g. due to the implementation of new technologies or the introduction of new services. We reserve the right to change or supplement this Privacy Notice at any time. We will inform you accordingly about any updated version of this Privacy Policy via in-game notice. Appendix A - Recipients
Amazon Web Services (a cloud service where we host the Game) - https://aws.amazon.com/
Mailchimp (an email service provider we use to send out emails to you) - https://mailchimp.com/de/
Prefinery (a marketing service provider that we use to collect your email address) - https://www.prefinery.com/
Sumo Logic (an analysis provider that we use for instance for tracking location, server performance and currently active users) - https://www.sumologic.com/
Vivox Inc. (a communication service provider that we use to provide in-game voice chats) - https://unity.com/products/vivox
Unity (a game development service that we use for analytics purposes) -https://unity.com/
AppsFlyer (an analytics and link tracking service that we use to identify the region you come from) - https://www.appsflyer.com/
BigQuery / Google (a cloud service provided by Google where we store game data) - https://cloud.google.com/bigquery
Looker Data Sciences, Inc. (a data exploration and discovery business intelligence platform that we use for understanding the performance of existing product features, improve and plan new features as well as measure audience size.) - https://looker.com/
Sentry, Inc. (a crash diagnostics platform that we use for monitoring app functionality.) - https://sentry.io/
Appendix B - Your Rights
You may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.
Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.