Privacy policy

2UP Games Privacy Policy

Last updated on 10 November 2020

A quick summary: this document explains:

what information we and our partners collect when you use 2UP Games’s games and services;
where that information is stored and how it is protected;
how we use that information;
how long we retain that information; and
your rights in relation to that information.

This Privacy Policy explains to you how your personal information is collected and stored and what happens to it regarding the 2UP Games Services. Because we know legal wording is not much fun, we have included a short and informal summary of each section (but the full version is the legally binding one). If you have any queries you can contact us at info@2up.games

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1. WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS

This Privacy Policy explains the different kinds of information 2UP Games can collect from you when you're using the 2UP Games Services. Legally, we cannot and will not collect personal information about children below 13 without parental/guardian involvement. We will comply with applicable privacy laws, including the EU’s GDPR.

1.1. About Us. We are 2UP Games Limited, (incorporated and registered in New Zealand with NZBN number 9429048208765 of Auckland, New Zealand (“2UP Games”).

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1.2. Which services does this Privacy Policy apply to? All of our video games, our websites, user accounts, customer and technical support, official forums, wikis, blogs, social media services and other products and services - “2UP Games Services” for short.

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1.3. What information does this Privacy Policy apply to? Specifically, this Privacy Policy governs personal data (or, in the USA, personally identifiable information) and applicable non-personal information (or, in the USA, non-personally identifiable information), which we collect from you when you are using the 2UP Games Services ("personal data" means information which, on its own or in combination with other information, can be used to identify you).

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1.4. What about children? We recognise we have a special obligation to protect personal information obtained from children. Legally you must be at least 13 years old to use the 2UP Games Services (but this might be older depending on whether or not a particular 2UP Games Service has a required minimum age rating) as per our Terms of Service. We do not knowingly collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact info@2up.games.

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‍1.5. What about GDPR? We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal information contained in this Privacy Policy which is used by 2UP Games in connection with the 2UP Games Services, 2UP Games is the data controller under EU data protection legislation.

2. WHAT INFORMATION IS COVERED?

We may collect certain information when you use the 2UP Games Services such as your name and email address (more information below). We do not receive or store your payment details. Please also read our Cookie Policy.

What information might we collect from you? When you sign up for, download, use or play the 2UP Games Services then we will collect certain information from you. The information that we collect varies depending on the particular 2UP Games Services used, but this may include:

Technical Details. When you use, play or access the 2UP Games Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any device identifier; your operating system, browser type or other software; and your hardware or other technical details.
Your Activities. When you use, play or access the 2UP Games Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences; in-game purchases; achievements; scores; gameplay statistics; time spent playing; and your geographical location data.
Your Communications. If you contact us (e.g. via email or call for customer support) or post in chat sessions, forums, on our social media pages, or other areas of the 2UP Games Services, we may collect and maintain a record of your contact details and the content of your communications.
User Accounts and Newsletters. To access certain 2UP Games Services (e.g. games or forums) you may need to create a user account. Or if you sign up to a newsletter, you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable 2UP Games Services (e.g. when you sign up for a newsletter) and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.
Third Party Accounts. In certain circumstances (e.g. joining our forums) you may be able to log into certain 2UP Games Services via third party accounts (e.g. Facebook, Twitter). If you choose to do so, you are asked to share certain information with us (the exact information will depend on the particular third party account displayed to you on the permissions page when you attempt to log in, but may include your name, location, gender, birth date, email address, photo, profile URL and friends list).

Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.

2.2. What about the storage of payment details? The processing and storage of payment details is a matter for the relevant platform and the applicable payment methods/processors. 2UP Games will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g. Apple’s App Store or Google Play) via the user account you have associated with that platform account. If you make in-game purchases within a 2UP Games game or product, we are notified by the payment processor once a transaction takes place but we will not receive any of your actual payment details.

2.3. What about cookies? We and third parties on our behalf also collect information about you via cookies and other advertising tracking technologies. You can find out more about our use of cookies and such technologies in our Cookie Policy. The Cookie Policy forms part of this Privacy Policy.

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3. WHERE IS YOUR INFORMATION STORED?

We will store your information in a secure cloud service. We will do our best to keep this information secure. No information security system is perfect so please remember to be careful.

‍Where will your information be stored?

The information we hold will primarily be stored in a secure cloud service. By submitting your personal information, you explicitly agree to such transfer, storing or processing of data inside and outside the EEA. We will take all steps reasonably necessary to ensure that this information is treated securely and in accordance with this Privacy Policy.

All information we hold is stored on our secure servers which we own or license from appropriate third parties. We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.

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4. HOW IS YOUR INFORMATION USED?

We will use your information to run, maintain and improve the 2UP Games Services as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may share information with partners in order to run our services.

4.1. How might your information be used? We may use the information above in order to (for example):

Perform our agreement with you: provide the 2UP Games Services to you, including: to carry out our obligations arising from any contracts between you and us; allow you to participate in interactive features of the 2UP Games Services when you choose to do so; and provide you with communication systems.
For our legitimate commercial interests: monitor the performance of the 2UP Games Services and user acquisition; ensure that the 2UP Games Services are presented in the most effective manner for you and your device(s); enforce our Terms of Service and other policies; notify you about changes to the 2UP Games Services; provide, maintain, protect and improve the 2UP Games Services; and to protect 2UP Games and 2UP Games Services users.
Comply with our legal obligations: where we are required to do so by law; and comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
Based on consent: provide you with marketing information about products or services that you request from us or which we feel may interest you where you have asked us to do so; and send you push notifications on mobile devices where you have agreed to this.

4.2. Will we ever share any of your information with other parties?

We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
We may engage third party service providers in the course of providing the 2UP Games Services to you (e.g. data storage, server hosting, live operation, customer and technical support, game analytics, advertising etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.
We may work with third party service providers (e.g. ad network and measurement services) to display advertising on the 2UP Games Services and to manage our ads on third party sites. We may share certain information (such as your email address, country of residence and your age) with third parties so that we can better target ads and content to you. You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device and you may be able to opt-out from the collection of information by some of our advertising partners as further detailed in our Cookie Policy.
We may share your information within the 2UP Games company group for the purpose of providing the 2UP Games Services.
In the unlikely event of a reorganisation or merger of 2UP Games we may transfer personal information to an involved third party who will protect this to at least the same level as we do in this Privacy Policy.

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5. HOW YOU USE YOUR INFORMATION AND THIRD PARTIES?

You have the option to share your own personal information with other parties, in which case it will be governed by those parties’ own privacy policies – make sure to take a look at them.

Please remember that any communications you have via the 2UP Games Services may reveal details about you. Also, any information you post publicly will be publicly available to other people. We are not responsible for your use of any otherwise private personal information which you make available, or the activities of other users or other third parties to whom you give or make available your information or content. The 2UP Games Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.

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6. DATA RETENTION

We retain your information for as long as needed to provide the 2UP Games Services to you or longer where permitted by law.

How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all 2UP Games Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.

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7. YOUR RIGHTS

You have rights about how your personal information is used, which can vary depending on where you live. If you have any questions, please contact us at info@2up.games.

7.1. Can you ask us to stop processing your personal information? You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications. Our Cookie Policy also details how you can deactivate certain types of cookies and other ad tracking technologies that may be used in providing certain 2UP Games Services.

7.2. What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the new GDPR) you have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain 2UP Games Services may no longer function properly or be completely unavailable to you.

7.3. Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact: info@2up.games.

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8. OTHER

We can change this Privacy Policy, but if we do we will put the changed version online. Please feel free to contact us if you have any questions with regards to the changes at info@2up.games. Please read our Terms of Service at 2up.games/terms-of-service

8.1. Will we ever change this Privacy Policy? Possibly, but if we do we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on you and us 30 days after we post it online. You are welcome to contact us if you have specific questions about the changes at info@2up.games. If you do not agree to those changes, regardless of whether you email us then unfortunately you must cease using all 2UP Games Services.

8.2. Are there any other documents you should read? We'd also like to remind you that our Terms of Service has more information about how we operate the 2UP Games Services (2up.games/terms-of-service)