The types of personal information we may collect about you include:
When you use our game ‘Down in Bermuda’ via the Apple Arcade we collect personal information to provide the game to you and to improve your experience of the game, including:
your teamplayerid from the Apple Game Centre;
your Apple Game Centre player alias;
details of your device model on which you play the game;
your in-game language selection; and
your game progression data. While we collect data about your progression through and achievements in the game. This game progression data is not stored by us and is stored on Apple services such as iCloud for game saves and Game Center for achievements. We do not store personal or gameplay data on our servers and its use is governed by Apple’s policies.
If you contact us with an enquiry or support request, we collect personal information to respond to your enquiry or request, including:
your contact details, including email address and/or telephone number; and
information you provide to us through your enquiry or support request.
We may also collect any other personal information we otherwise request and/or which is otherwise provided to us. We may collect these types of personal information directly from you or from third parties.
Collection and use of personal information
We may collect, hold, use and disclose personal information for the following purposes:
to enable you to access and use our Services and any associated applications, such as the Apple Game Centre;
to contact and communicate with you in response to any enquiry or support request you make; and
to comply with our legal obligations and resolve any disputes that we may have.
Disclosure of personal information to third parties
We may disclose personal information to:
third party service providers for the purpose of enabling them to assist us in providing our Services to you, including (without limitation) Apple;
our employees, contractors and/or related entities;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred; and
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.
List of third parties:
Upon written request, we will provide you with a list of the third parties we use to process your personal information.
For Australian users: Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act and if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.
How we treat personal information that is also sensitive information
Unless otherwise required or authorised by law, we will not collect sensitive information or special categories of data about you without first obtaining your consent.
How we process personal information
In order to provide our game to you and assist with any support requests we will process your personal information (this includes personal information of children) on the legal basis of performing a contract and/or support of internal operations of the game.
Connecting to iCloud and Game Center and the collection of your teamplayerid and Game Center alias are not strictly necessary to the functionality of the game but may improve your experience. We will process this personal information (this includes personal information of children) on the legal basis of our legitimate interests and/or to support internal operations of the game.
If we need to rely on consent, we will ask you for consent to process any of your personal information for that specific purpose before we process your personal information for that reason. If you are under 16 years of age, we will ask for your parent or legal guardian’s consent on your behalf.
We will rely on a legal obligation to process your personal information where we are subject to a legal obligation.
Our commitment to you
Your personal information will:
be processed lawfully, fairly and in a transparent manner by us;
only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;
be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal information was collected; and
be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Your rights and controlling your personal information
Your choice when using Apple:
You may decline to store personal information in iCloud or to send personal information 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 Game Centre leaderboards and your achievements will not be sent to Game Center.
Information from third parties:
Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe:
To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.
Objecting to processing:
You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.
You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Access, erasure and data portability:
You may have the right to request details of the personal information we hold about you, or to request that we erase the personal information we hold about you, or that we transfer this information to a third party. Some personal information may be stored by Apple within iCloud or the Game Centre. To request access, erasure or data portability of this other personal information, please contact Apple directly.
If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant authority in the country in which you are based.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see ‘access, erasure and data portability’ above for further information.
In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
When you use our website
Collection of Personal information
The types of personal information we may collect about you include:
information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; and
additional personal information that you provide to us, directly or indirectly, through your use of our website, associated applications and/or accounts from which you permit us to collect information.
We may collect the above personal information (this includes personal information of children) and process the above personal information for our legitimate interest to facilitate access and use of our website and/or to support operations of our website.
Cookies and web beacons
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
We may use web beacons on our website from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
Links to other websites
For any questions or notices, please contact our Privacy Officer at:
Yak & Co Pty Ltd ACN 166 476 946
Last update: 19 September 2019