No Way Home Privacy Policy

SMG Studio Pty Ltd (ACN 164 622 566) of 4.06 / 22 Mountain St, Ultimo, NSW 2007, Australia, sells the mobile game called “No Way Home” (referred to as “Game” within this document) via Apple Arcade (referred to as the “Service”). This Privacy Policy is specific to No Way Home (the Game).

This document informs you of our privacy policy regarding our collection, use and disclosure of personal data when you use the Service and the Game. By using the Service and / or playing the game, you agree to this policy.

Last updated: 29/11/2019

DEFINITIONS

Personal Data
Personal Data means data about an individual who can be identified from those data, those data in cross-reference to other data collected within the Game or the Service by us, or from those and other information either in our possession or likely to come into our possession via usage of the Game and / or the Service.

Usage Data
Usage Data is data collected automatically, either generated by the use of the Service, from the Service infrastructure itself (for example, scores and achievements) or from the Game.

Cookies
Cookies are small files stored on your device (computer or mobile device).

TYPES OF DATA COLLECTED AND USE

Personal Data

Whenever you use the Game, information about your device, such as the Universal Unique Identifier (UUID) and Game Center teamPlayerID, are collected. Those are persistent identifiers in connection with your iCloud Game saves, in connection with Game Center Leaderboards and in connection with Achievements. Such is transmitted to, processed and handled by Apple, as well as stored to your device.

Usage Data

When you use the Game, we collect non-personally identifiable player information such as device type, level progress, scores, achievements, unlocked levels (stages) and items. Any such information is stored on your device and in Apple’s iCloud and Game Center services. It is used for services such as iCloud for saved games and Game Center for achievements and leaderboards (if applicable).

Tracking Cookies Data

No Cookies or comparable tracking technologies are used by the Game to track user activities.

USE OF DATA

Usage Data, as set forth above is collected when you play the Game, stored on your device and directly transmitted to iCloud and Game Center. We do not retain any Usage Data and we do not retain any Personal Data. We do have access to such data, but such access is used only for supporting your use of the game.

SUPPORT

Support inquiries are handled via Freshdesk, a customer support framework provided by Freshworks. The 3rd party privacy policy can be found here:

https://www.freshworks.com/privacy/

Any related correspondence, which will contain the user’s email address, is archived upon solution and deleted upon request.

Transfer of Data

Personal Data and Usage Data is transmitted to Apple for iCloud for the purposes of saving games and to Game Center for achievements and leaderboards (if applicable). No other Data is transferred to any other party.

Disclosure of Data Collection and Handling

Personal Data collected by us is transmitted to Apple Servers for iCloud for saved games and Game Center for achievements and leaderboards, as may be applicable. We do not retain any Personal Data or Usage Data to provide any third parties who may seek such data. However we may collect, retain and disclose prospective Personal Data and Usage Data provided by you and to which we have access under the good faith belief that such action is necessary:

To comply with a legal obligations;
To protect and defend our rights;
To prevent or investigate possible wrongdoing in connection with the Game or Service;
To protect the personal safety of users of the Game, Service or the public; and
To protect against legal liability;

SECURITY OF DATA

Protection of any personally identifying Usage Data or Personal Data is our highest priority. Such Data as set forth above is shared with Apple only. Our use of any such data is limited to supporting integration with Apple’s iCloud, leaderboard and achievement tracking (if applicable). We don't store Usage Data or Personal Data.
Please keep in mind:
No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use to protect your Personal Data with best effort commercially feasible, we cannot guarantee its absolute security.

OPTING OUT OF DATA COLLECTION

You may decline to store data in iCloud or to send data to Game Center. To turn off iCloud data storage, you must turn off iCloud in Apple Settings for our game. As a result, you will only be able to play in single player offline mode. To stop sending data to Game Center, you must sign out of Game Center in Apple Settings. As a result, you will not appear on leaderboards.

POLICY REGARDING THE TRACKING RESTRICTIONS UNDER THE CALIFORNIA ONLINE PROTECTION ACT

We do not track users of the Service or Game.

CHILDREN’S PRIVACY

While we do collect some limited Personal Data and Usage Data, no such data is stored on our servers, shared by us with any third parties other than Apple.
All such data is used only for the purposes of support for the internal operations of the Game and Service as set forth in the exception to the Children’s Online Privacy Protection Rule (“COPPA”) at 16 C.F.R. 312.2. Furthermore, such data collection and use is collected with a Legitimate Interest as set forth in the EU General Data Protection Regulation (“GDPR”).

If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us via the means provided at the bottom of this document.
If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to cease such collection of Personal Data and delete it immediately. A note of deletion has to be retained on our side.

If a minor would contact us regarding a support issue, that issue would be handled as all support requests. All data will be archived upon resolution and deleted upon request.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Last updated: 29/11/2019

CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us:

SMG Studio Pty Ltd
4.06 / 22 Mountain St
Ultimo, NSW 2007
Australia

http://smgstudio.com/support/
 

SMG GDPR CPO (Chief Privacy Officer)
Ashley Ringrose – Studio Head
ringrose@smgstudio.com

SMG GDPR DPO (Data Protection Officer):
Johann Ertl - Senior Producer
johann.ertl@smgstudio.com