Privacy Policy
Last Updated Date: 4 April 2022
1. Introduction
1.1. This policy describes how Clueless Gaming and, its other group companies (collectively described as “CG”, “we”, “us”, “our”, or any other grammatical variations thereof shall unless otherwise stated) and its third party marketing and advertising partners collect, use, process and share information about you.
1.2. This Privacy Policy applies to all of our games, whether played on our websites, on mobile devices, PCs, game consoles, or other gaming platforms. It also applies to our marketing and advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy, we refer to our games, websites, marketing activities, advertising activities, and other services collectively as our “Services”.
1.3. By downloading, accessing, and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to CG’s and our advertising partners’ use of your data for targeted advertising purposes. Those sections also explain how you can withhold or withdraw your consent to use your data for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.
1.4. If we change our Privacy Policy, we will make the amended Privacy Policy available on our Services. We reserve the right to amend this Privacy Policy at any time without notice.
1.2. This Privacy Policy applies to all of our games, whether played on our websites, on mobile devices, PCs, game consoles, or other gaming platforms. It also applies to our marketing and advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy, we refer to our games, websites, marketing activities, advertising activities, and other services collectively as our “Services”.
1.3. By downloading, accessing, and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to CG’s and our advertising partners’ use of your data for targeted advertising purposes. Those sections also explain how you can withhold or withdraw your consent to use your data for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.
1.4. If we change our Privacy Policy, we will make the amended Privacy Policy available on our Services. We reserve the right to amend this Privacy Policy at any time without notice.
2. The Data We Collect
The categories of personal data we collect depend on the Services you use, and the requirements of applicable law.
2.1. Data that you provide us with:
We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, such as:
2.1. Data that you provide us with:
A. Contact information (such as name and email address or phone numbers)2.2. Data we collect automatically.
B. Player name or tag and password
C. Profile information (such as profile photo)
D. Your messages and other content you submit when you use our Services (such as chat logs and player support tickets)
E. Data you provide in connection with surveys, promotions, competitions and other events
F. Our payment service providers will collect your payment details in connection with any purchases you make through our Services
A. Data about your account and game progress, including in most cases an automatically created internal account ID2.3. Data we collect from our partners.
B. Your IP address and mobile device identifiers (such as your device or advertising ID)
C. Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
D. Data we collect with cookies and similar technologies
E. Approximate location data (as derived from IP address)
F. Data about your use of our Services, such as gameplay data, purchases made and your interactions with other players inside the Services
We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, such as:
A. Data we receive if you link a third-party tool with the Service (such as Steam, LINE, Facebook, WeChat or Kakao)
B. Demographic data (such as to determine the coarse location of your IP address)
C. Data to fight fraud (such as refund abuse in games or click fraud in advertising)
D. Data from platforms that the games run on or data from payment service providers (such as payment verification data)
E. Data for advertising and analytics purposes (such as surveys), so we can provide you a better Service
F. Data that you have made available to us from a third party service (such as Steam, LINE, Facebook, WeChat or Kakao) via your privacy settings
3. How Do We Use Your Data
3.1. We use your information to enable us to provide our websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.
3.2. Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, to our customer services or publicly on our forums. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
3.3. Some of our games may also include a video chat feature. Users of this feature may be able to participate in video chat with contacts from a platform or social network or invite personal contacts. We will collect usage information from video chat interactions with other users, for example call duration, and general location information. We do not record, collect or retain any content of your video chat interactions with other users. We do not also collect or store your date of birth information which you provide to us when activating the video chat feature for the first time. We solely use this information to determine if you are eligible to use the feature.
3.4. We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.
3.5. We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.
3.6. We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
3.7. From time to time we may run promotions or competitions during which we may collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We may also publish the names and entries of competition entrants. That information may also be combined with your game account and other account information and will be processed, stored and shared in accordance with this Privacy Policy.
3.8. We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.
3.9. We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.
3.2. Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, to our customer services or publicly on our forums. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
3.3. Some of our games may also include a video chat feature. Users of this feature may be able to participate in video chat with contacts from a platform or social network or invite personal contacts. We will collect usage information from video chat interactions with other users, for example call duration, and general location information. We do not record, collect or retain any content of your video chat interactions with other users. We do not also collect or store your date of birth information which you provide to us when activating the video chat feature for the first time. We solely use this information to determine if you are eligible to use the feature.
3.4. We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.
3.5. We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.
3.6. We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
3.7. From time to time we may run promotions or competitions during which we may collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We may also publish the names and entries of competition entrants. That information may also be combined with your game account and other account information and will be processed, stored and shared in accordance with this Privacy Policy.
3.8. We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.
3.9. We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.
4. Who Can See Your Data
Apart from CG, your data can be accessed by others in the following situations:
4.1. Other players and users.
4.1. Other players and users.
4.1.1. Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.4.2. Our service providers.
4.2.1. CG has vendors who help us to provide the Service. These vendors process your data only at and according to CG´s instructions to provide the Service, and perform tasks such as hosting, player support, advertising, analytics and fraud prevention.4.3. Other companies and public authorities.
4.3.1. In order to verify payments (with payment providers such as Paypal) and combat fraud and illegal activity, we may process and disclose data with other companies and organisations and provide it to public authorities in response to lawful requests.4.4. Advertising and Social Media partners.
4.3.2. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
4.4.1. The Service includes features from our partners, such as social media interaction tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. A list of these partners is available in the section “Your Rights and Options”. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
4.4.2. These partners may access data regarding your activities and your device (such as your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share data we have collected about you with third-party advertising partners. These advertising partners may use this data (and similar data collected from other services) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. These partners may operate under their own privacy policies. This practice is commonly referred to as “interest-based advertising” or “online behavioural advertising.” If you prefer not to share your personal data with third-party advertising partners, you may follow the instructions in the section “Your Rights and Options”.
5. International Data Transfers
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that we may use include standard contractual clauses approved by the EU Commission and other lawful safeguards.
6. Your Rights and Options
6.1. Opt out of marketing emails and other direct marketing.
6.1.1. You may opt out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications, or by changing your in-game settings. The updated settings may not be effective immediately. Note that you may still continue to receive non-promotional communications from us, such as communications regarding the Service or updates to our Terms of Service or this Privacy Policy.6.2. Push Notifications
6.2.1. We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.6.3. Opt-out of targeted advertising.
6.3.1. You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting “Limit Ad Tracking” (Apple iOS) or “Opt-out of Interest Based Ads” (Android). To opt-out from our third party advertising partners, you may refer to their privacy policies and they are namely:6.4. Your other rights.6.3.2. You can also opt out from personalised in-game offers through the options provided in the game settings (where applicable).Unity Technologies TikTok
6.3.3. Access the personal data we hold about you.
6.3.4. If you request, we will provide you a copy of your personal data in an electronic format.
6.4.1. You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent.
6.4.2. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact your local data protection authority for unresolved complaints.
6.4.3. If you wish to exercise any of your data subject rights described above, please use the support options described in “Contact Us”. We will respond to all requests in accordance with applicable laws. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorised agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law.
6.4.4. You have the right not to receive discriminatory treatment as a result of your exercise of these rights.
7. How do We Protect Your Data
7.1. Security Safeguards.
7.1.1. In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorised access or against loss, misuse or alteration.7.2. Data retention.
7.2.1. We retain your data for as long as your account is active or as needed to provide you the Service. We may for example periodically de-identify unused game accounts, and we may regularly review and de-identify unnecessary data.
7.2.2. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Children
8.1. Protecting children’s privacy online is very important to us. Generally, our Services are not directed to children under 13 (or other age as required by local law), and the Services do not knowingly collect personal data from children, except as described in the following paragraph.
8.3. If you are a parent or guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us”. If we become aware that a child has provided us with personal data contrary to the above, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.
8.1.1. For games that are not directed at children but nonetheless may appeal to them, we take additional steps to limit access to these Services based on the player’s age. For these Services, when a player indicates they are under 13 (or the applicable age in their territory), we will limit their access to certain features, such as social media and chat features, as well as certain types of notification alerts. We also limit the processing of personal data to only what is necessary to support the internal operations of our Services.8.2. Please note that for some of our Services we may use a higher age limit (such as 16) than described in the above two paragraphs. We do this to provide a safe game experience for our players and to protect young users.
8.3. If you are a parent or guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us”. If we become aware that a child has provided us with personal data contrary to the above, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.
9. Disclosure for California Residents
The following section applies only to residents of California.
9.1. Data Collection9.1.1. The categories of personal data we have collected in the preceding 12 months, and the sources of said data, are described in the section “The Data We Collect”.9.2. Data Use9.2.1. The business or commercial purposes for collecting your personal data are described in the section “How Do We Use Your Data”.9.3. Data Disclosure and/or Sale9.3.1. We do not “sell” your personal data with third parties as most people would understand that term. However, we may share your cookie information and advertising identifiers with our third-party advertising platforms to deliver interest-based advertisements, attribute installations and optimise campaign performance. To the extent that practice is considered a “sale” under the CCPA, you may opt out of said sharing by following the steps described in “Opt-out of targeted advertising” in the global Privacy Policy.
9.3.2. We do not have actual knowledge of any sale of personal data of minors under 16 years of age, as the term “sale” is defined under the CCPA. In the preceding 12 months, we have disclosed the following categories of personal data as part of our Services:
9.4. In the preceding 12 months, we have disclosed the following categories of personal data as part of our Services:
Category of Personal Data Collected
Examples of Data Collected by CG
Categories Of Third Parties Who May Receive Personal Data For A Business Purpose
Identifiers.
A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Other Players (username and profile only)
Service Providers
Business Partners
Advertising Networks (Advertising identifier and IP address only)
Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name or telephone number.
Service Providers
Protected classification characteristics under California or federal law.
Age.
Service Providers
Advertising Networks (for compliance purposes only)
Commercial information.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Service Providers
Advertising Networks
Internet or other electronic network activity.
Browsing history, information on a consumer’s interaction with an internet website, application, or advertisement.
Service Providers
Advertising Networks
Inferences drawn from other personal data to create a profile about a consumer.
Profile reflecting a consumer’s preferences, characteristics and behaviour.
Service Providers
9.5. In addition to the sharing described above, we may share any information we collect about you with our affiliates, to protect us or others, or in the event of a merger, sale, or other asset transfer. See the section “Who Can See Your Data” for more information.
9.6. Your Rights9.6.1. Your rights under California law are described in the section “Your Rights and Options”.
10. Contact Us
10.1. If you wish to exercise your rights as described in the section “Your Rights and Options”, you may send an email to our Personal Data Protection Officer at support@cluelessgaming.co. We will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and any other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship and/or the contract you have with us.
10.2. If you have any questions or concerns about this information, our privacy practices or your dealings with the Services, please do not hesitate to contact us by email at support@cluelessgaming.co.
10.2. If you have any questions or concerns about this information, our privacy practices or your dealings with the Services, please do not hesitate to contact us by email at support@cluelessgaming.co.
11. Governing Law
This Privacy Policy shall be governed in all respects by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts