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Privacy Policy

Effective September 21, 2019

Welcome to Subtle Boom. Your privacy is important to us.


Subtle Boom Pty Ltd ("us", "we", or "our") operates the Fledgling Heroes game (hereinafter referred to as the "Service").


This page informs you of our policy regarding the collection, use and disclosure of your personal information when you use our Service and how you can exercise your privacy rights. The Service is also governed by our Terms of Service


We use your personal information to provide and improve the Service. By using the Service, you agree to the collection and use of personal information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.


1. What Personal Information We Collect

While using our Service, we may collect personal information about you, such as: 

  • an account identifier when you access the online features of the Service. For example, a Game Center player identifier

  • support messages when you request technical support, make a compliment or complaint, or otherwise contact us directly


2. How We Use Your Information

We use your personal information for the following purposes:

  • your account identifier is used to authenticate you as a player, and may be associated with other data described in this policy

  • to provide customer support, to improve our Service

  • to detect and prevent illegal activities (e.g. hacking or cheating) 

  • to comply with our legal obligations

  • to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person


Your account identifier is not shared with other players. However, any content you share may be read, collected, or used by them. Please take care about the protection of your own personal information when using these features.


3. Collection and Use of Non-Personal Information

We may also collect data that does not directly identify you and is only used for the purposes of providing the features outlined in this policy:

  • your permission setting, which controls how visible your profile and levels are to other players, and can be changed at any time from the in-game privacy settings

  • character avatar and rank which is used for your online profile that may appear to other players, for example when viewing your uploaded levels

  • levels that you upload for sharing with other players. This includes configuration and data required to reconstruct the level on other devices, and does not include any plain text entered by you

  • level play statistics to help us determine the difficulty of player-created levels, including, but not limited to, the number of attempts and completions. This improves the Service for all players by filtering player-created levels according to their desired difficulty

  • level ratings and tags that you provide to improve the Service for other players, and to help us curate levels

  • language when uploading support messages, to allow us to translate your messages and our response

4. Opting-out of Information Collection

Before we begin collecting information associated with your account identifier you will be notified and can choose not to share your information. You can change your choices through the in-game settings. These settings may be synchronised with other devices that you use to access the Service with your account identifier.


If you choose not to share your information, you can still access the offline features of the Service which include playing all included story levels, creating your own levels and customising your character styles.


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 Service. 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.


5. Protection of Personal Information

We take the security of your personal information seriously and only collect the minimum of what is required for the Service.  We use a variety of security technology and measures designed to help protect your personal information from unauthorised access, use or disclosure. For example, we use industry-standard encryption when transmitting your personal data and it is stored in a secure third-party service provider that conforms with our privacy requirements, and does not use your data except to provide the Services and Technical Support Services required to operate this Service.


6. Retention of Personal Information

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your personal data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Unless legally obligated otherwise, we will delete or de-identify your data no more than 180 calendar days after you last access the Service.


Your personal data may be deleted at any time upon your request, made via the in-game settings or support system, or by contacting us using our support email. Please note data deletion requests can take up to 30 days.


7. Transfer of Data

Your information, including personal information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organisation or a country unless we are reasonably satisfied there are adequate controls in place including the security of your personal data and other personal information.


8. Disclosure of Personal Information

8.1  Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. with any competent law enforcement body, regulatory authority, government agency or court of law).


8.2  Legal Requirements

We may disclose your personal information in the good faith belief that such action is necessary to:

  • to comply with a legal obligation

  • to protect and defend our rights or property

  • to prevent or investigate possible wrongdoing in connection with the Service

  • to protect the personal safety of users of the Service or the public

  • to protect against legal liability


9. The European Union General Data Protection Regulation (“GDPR”)

9.1  Legal Basis for Processing Personal Information under the GDPR

If you are from the European Economic Area, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it.

We may process your personal information because:

  • we need to perform a contract with you

  • you have given us permission to do so

  • the processing is in our legitimate interests and it is not overridden by your rights

  • to comply with the law


9.2   Your Data Protection Rights under the GDPR

If you are a resident of the European Economic Area, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal information.


If you wish to be informed about what personal information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you - whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you

  • The right of rectification - you have the right to have your information rectified if that information is inaccurate or incomplete

  • The right to object - you have the right to object to our processing of your personal information

  • The right of restriction -you have the right to request that we restrict the processing of your personal information

  • The right to data portability - you have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format

  • The right to withdraw consent - you also have the right to withdraw your consent at any time where we relied on your consent to process your personal information


Please note that we may ask you to verify your identity before responding to such requests.

You also have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area.


10. Children's Privacy

While our Service is directed at a general audience, we understand that children may want to participate in the optional online features of our Service. To facilitate this we have shaped our Privacy Policy and Terms of Service to provide a safe and family-friendly environment that protects the privacy of all users.


We protect children’s privacy and preserve your rights as a parent in the following ways:

  • we don’t collect more information than is necessary to provide the Service

  • we do not disclose data collected from anyone to third parties that may use the data for any other purpose than to provide the Service

  • you may review your child’s personal information, direct us to delete it, and refuse to allow further collection or use of the child’s information


If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, beyond the limited information outlined in this policy we will take steps to delete the information as soon as possible. If you believe that we have inadvertently collected such information, please contact us so we can promptly delete the information from our records.


If you have any questions, requests or feedback please contact us using the contact information below. 


11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you where we deem necessary to do so. Changes to this Privacy Policy are effective when they are posted on this page. Please check back regularly for updates. 


12. Contact Information

If you have any questions relating to the Service, or if you have any requests for resolving issues with your personal information, we encourage you to primarily contact us through the in-game support message system. This usually allows for faster responses and resolutions to your queries.


Alternatively you can contact us using:


Our Privacy Officer will respond to your query within a reasonable time after we receive it, provided you supply return contact details. If you do not provide return contact details, we will be unable to respond to your complaint, although we will consider its content. 

© Subtle Boom 2019

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