Altitude Games Privacy and Data Protection Policy

 

 Last Updated: 26 March 2024



This Privacy Policy is provided by Altitude Games Pty Ltd (ABN 18 664 934 123), a company incorporated in Australia (“Altitude Games, us,” or “we”), and covers www.altitude-games.com and www.sweepz.com (collectively, the “Websites”) and all applications, software, and services (e.g., games) made available by us via the Websites or a mobile app store  (collectively, the “Services”).

 

This Policy does not apply to the practices of any third party that we do not own or control. You must check the privacy policies and practices of these third parties to understand how they treat personal information collected about you.

 

PART A: LAWFUL BASIS FOR PROCESSING (GDPR)

 

We only collect and process personal information about you where we have lawful bases to do so. Lawful bases include where you have given consent, for purposes related to our contract with you, and in where it is necessary for the purposes of our legitimate interests.

 

Where we rely on your consent, you have the right to withdraw your consent at any time.

 

Your use of Services constitutes your consent for the processing of your personal information for the purposes and in the manner stated in this Policy (including the transfer to and storage of such information in Australia, Canada, United States, or any other country where Altitude Games may store or transfer such information) unless you withdraw your consent.

 

Where we use your personal information to provide our Services, fulfill your specific requests, purchase orders, and to send you purchase confirmation and other account-related information, our legal basis for processing your data for such purposes is to fulfill our contractual obligations to you.



PART B: WHAT INFORMATION DOES ALTITUDE GAMES COLLECT AND HOW IS IT USED?

 

1., User-Provided Information

 

Altitude Games obtains the information you provide when you download, or register on, any Services, as well as the information you agree to allow us to collect when you log in using your Facebook or other social network account. Please keep in mind that, for Services where registration is optional, you may not be able to use some of the features offered by our Services unless you register with us.

 

When you register with us and use our Services, you generally provide (a) your name, email address, user name, password, and other registration information, (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use the Games from us, (c) information you provide us when you contact us for help, (d) credit card information for purchase and use of the Services, and (e) information you enter into our system when using the Services, such as contact information. In some cases, you may provide us with information based on permissions you provide, such on your mobile device (e.g., for current geolocation), or where notice is otherwise provided to you.

 

All credit card information storage and processing is outsourced to our third-party partners. 

 

  1. Automatically Collected Information

 

In addition, we and our third-party partners (e.g., analytics providers, ad networks, information technology providers, fraud detection, session replay services) may collect certain information automatically, including, but not limited to, the time and duration of your visit of our Services, how often you use our Services, information about your interaction with our Services (e.g., what you’ve viewed or clicked on, or submitted within, our Services), browser, gaming, or other session recording, your preferences, and device metadata such as your hardware model, device type, operating system version, browser type, user agent string, and IP address (note that we may also extrapolate non-precise geolocation from IP address).

 

  1. 3. Information Collected From Other Sources

 

We also obtain information from third parties, which we often combine with information we collect either automatically or directly from you. For example, we may receive the same categories of information described above from the following third parties:

 

  • Other Users who Interact with our Services:  We may receive your information from other users who interact with our Services.
  • Business Partners:  We may receive your information from our business partners, such as companies that offer their products or services on our Services or on other properties (e.g., digital properties, offline locations) or marketing/advertising and analytics partners, including third-party brands/agencies or other partners that facilitate the buying and selling of advertising inventory on our Services, measure of the effectiveness of those related ad campaigns, or inform business analytics (e.g., view rates, bounce rates, audience composition). 
  • Social Media Networks:  When an individual interacts with our Services through various social media networks, such as when someone logs in through a social network, “Likes” us on Facebook, or follows us or shares our content on Google, Facebook, Instagram, Twitter, or other social networks, we may receive some information from those social networks including your profile information and any other information you permit the social network to share with third parties. We use this information to allow you to log into your account, to communicate or interact with individuals on the social network, to better understand the demographics of our visitors, and to personalize content and advertising.  Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information or linking or connecting them to other services.
  • Information We Receive From Authentication Services:  Some parts of our Service may allow you to login through a third-party social network or authentication service such as Facebook or Google. These services will authenticate the individual’s identity and provide the option to share certain personal information with us, which could include a name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and the individual’s privacy settings on that third-party digital property. We use this information to authenticate the individual’s account, to provide our Services, to communicate with our users, and for advertising and marketing purposes.
  • Service Providers:  Our service providers that perform services on our behalf, such as payment processors or surveys and third parties who conduct marketing/advertising and analytics activities on our behalf, collect personal information and may share some or all of this information with us.
  • Information Providers:  We may, from time to time, obtain information from third-party information providers to correct or supplement personal information we collect.  For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., interests, preferences).
  • Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

 

  1. How does Altitude Games use and disclose information obtained in connection with the Services?

 

We may use your information for various purposes, including:

 

  • To fulfill your requests and provide our Services to you.  This includes:
  • Making our Services available to you;
  • Coordinating access to your accounts, including by way of authentication protocols;
  • Responding to requests, suggestions, questions, and comments, and providing other types of support;
  • Fulfilling your payments and transactions;
  • Sending you service/transaction-related messages, such as changes to your account;
  • Enable you to interact with other players in the game, including by sharing your profile information (including picture, name or username, country location), game status, and scores with other players; and
  • Communicating about, and administering your participation in, events, conferences, tournaments, leaderboards, programs (e.g., loyalty/rewards programs), contests, surveys, polls, panels, questionnaires, and other offers or promotions.
  • To personalize your experience on our Services:  This includes providing you with more personalized content, features, or ads on our Services.
  • For marketing purposes:  We may send you communications about new features, updates, products, and special offers.  We may also use your information to serve you ads about our products or other products or services we (or our advertising partners, such as other third-party brands/agencies) think you might find interesting, whether such ads are provided on our Services or on third-party services (e.g., our ads on social media networks).  We may also use individual and aggregate information about you to inform our, and our third-party partners, marketing and advertising campaigns and to measure their effectiveness. 
  • To communicate with you:  For example, we may communicate with you about your account activities, such as by providing you transaction confirmations or other related information.  If you register with us, we may enroll you in our email newsletters or other periodic electronic communications and may also send you user surveys and promotional communications.  We may communicate with you by email, push notifications, texts, or other means.  
  • To monitor, improve, and develop our products and services:  We may use your information to understand our users and to tailor or optimize our Services.  For example, we may analyze statistics and trends to make our Services better and to develop or better personalize the Services or new services or features.
  • To protect the security and integrity of our business (e.g., enforcement of our various terms), comply with legal requirements and obligations, corporate transactions, or as otherwise permitted by law:  We may use your information to protect our company, our affiliates, our users, and our Services.  We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, protect and defend our rights and property, or the rights or safety of third parties, enforce our Terms of Service, this Policy, or agreements with third parties, detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law.  We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets and may use information in connection with or as an asset in such a corporate business transaction.  Personal information may also be used in the event of insolvency, bankruptcy, or receivership.
  • For any other purposes with your consent, at your direction, or where notice is provided:  We may use and disclose your personal information for any other purposes with your consent, at your direction, or where notice is otherwise provided.

To carry out the above purposes, we may disclose your information (e.g., the information described in this Policy) to third parties, such as our marketing, analytics, and other business partners (e.g., other entities that provide their own products and services, ad networks, social media platforms), and also with service providers that operate on our behalf (e.g., fraud prevention, certain marketing or analytics vendors, payment processors, web hosting, cloud storage, information technology services). As necessary, we may need to coordinate with law enforcement, regulators, or other parties for legal reasons (e.g., as required by law or subpoena) for purposes related to protecting the security and integrity of our business (e.g., enforcement of our various terms) and to comply with legal obligations.

 

PART C: WHAT ARE MY DATA RIGHTS?

 

Note: When reaching out to [email protected] to exercise the applicable rights below, we may require that you verify your identity with us for security purposes before further acting on such rights. Further, you may not be entitled to the below rights depending on which jurisdiction you are in. Certain rights may be further subject to exceptions permitted under law. 

 

  • Right of Access: If you want to request access to, and a copy of, your personal information, including the purposes of processing your data and to whom the data has been disclosed, please contact us at [email protected].
  • Right to Data Portability: You can request a copy of your information in a commonly used electronic format so that you may transfer it to another organization. To request this right, please contact us at [email protected]
  • Right to Rectify or Change Data: If you wish to rectify any inaccurate personal information concerning you, you may be able to correct some data via your account if you have one. Otherwise, please request this right by contacting [email protected].
  • Right to Object to, Restrict, or Limit the Use of Data: You can ask us to stop using some or all of your personal information (e.g. if we have no lawful basis to do so), or to limit our use of it (e.g. if your data is inaccurate) including for the purposes of direct marketing. To exercise this right, (i) in relation to email marketing opt-outs, please use the unsubscribe mechanism found in such emails, (ii) in relation to push notifications, please use your device controls, (iii) in relation to text messages, please use the opt-out keyword in such texts, or (iv) please request this right by contacting [email protected] if (i) through (iii) in this section do not apply.
  • Right to Delete: If you would like us to delete your information, please request this right by contacting [email protected] and we will respond in a reasonable time. Please note that certain information may be required to participate in certain Services. Further, we may need to retain certain information, even in light of a deletion request, where permitted by applicable law. 

 

 

When you opt out of receiving interest-based advertisements per the above mechanisms, this does not mean you will no longer see advertisements from us (or our third-party partners) or on our Services in general. It means that the online ads that you do see from self-regulatory program participants (or other participants that may provide an opt-out mechanism) should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding those options or programs. In addition, third parties may still use cookies or other tracking technologies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs.

PART D: DATA RETENTION POLICY, MANAGING YOUR INFORMATION

We will retain your information for a period of time to reasonably fulfill the purposes specified in this Privacy Policy, unless a longer retention period is required or permitted by law.

 

We will take reasonable steps to destroy or permanently de-identify any personal information where a) we no longer need the personal information for any purpose for which your information was collected or for a related purpose and b) we are not required by law, a regulator, or a court/tribunal order, to retain your information.

 

PART E: STORAGE AND TRANSFER OF YOUR INFORMATION

 

Altitude Games operates in several international jurisdictions and personal information we collect may be transferred to, stored, and processed by third parties in the European Union, the United States, Canada, Australia, the Philippines, or any other country in which we or our partners maintain facilities. We will ensure that transfers of personal information to any country or organization are subject to appropriate safeguards to the extent required by applicable law. Additionally, when transferring personal information from the European Union, we may use standard contractual clauses approved by the European Commission or otherwise adopt other means in accordance with European data protection laws for ensuring adequate safeguards.

 

PART F: CHILDREN

 

We do not use the Services to knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.

 

PART G: SECURITY

 

We use commercially reasonable physical, electronic, and procedural safeguards to protect the information we collect, process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information to operate, develop or improve our Services. 

 

Please be aware that, although we endeavor to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches and Altitude Games cannot ensure or warrant the security of your personal information.

 

PART H: CHANGES

 

This Policy may be updated from time to time for any reason.

 

We will notify you of any changes to our Policy by posting the new Policy on the relevant Service. You are advised to consult a copy of this Policy (which will be made available on the relevant Service) regularly for any changes, as continued use is deemed approval of the Policy as it may be amended from time to time.

 

You agree that your continued use of the Services after we publish or send a notice of our updated Policy means that the collection, use, and disclosure of your information is subject to the updated Privacy Policy.

 

PART I: CONTACT INFORMATION

If you have any questions regarding our Policy, please contact us by email at [email protected].

 

Altitude Games Pty Ltd

2/92 Forrest Street

Cottesloe, WA 6011 Australia

[email protected] 

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