Midoki | Privacy Policy

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by Midoki Limited (‘Midoki / ‘we’ / ‘us’). Our registered office is at One Eastwood Harry Weston Road, Binley Business Park, Coventry, West Midlands, CV3 2UB. We are a company registered in England, with company number 07882357.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the "Game(s)"), as well as any other online features relating to the Games including our website (http://www.midoki.com/index.html) (the “Website”), our online forums (http://forum.plunderpirates.com/index.php) (the “Forums”) and user support centre (the “Support Centre"). Together the Game(s), the Website, the Forums and Support Centre are referred to as the “Online Services”.

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

What information we may collect about you;

How we will use information we collect about you;

Whether we will disclose your details to anyone else; and

Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use. These are linked below:

In respect of the Game(s): http://www.midoki.com/eula.html;

In respect of the Forums:

http://www.midoki.com/forum/index.php?threads/guidelines.37/.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.

Information provided by you when using the Online Services

(“Basic Information”)

We will collect, or you may submit, the following information when you play our Games or use the Forums and Support Centre:

your mobile device’s unique device ID (Device ID);

your mobile device, make and model;

your IP address;

your user preferences;

your first and last name (Support Centre and Forums only);

your email address (Support Centre and Forums only);

your date of birth (Forums and US versions of the Games only);

your gender (Forums only);

your user name and password (Forums only); and

Core information milestones related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad).

Contact information provided by you when using the Forums or Support Centre

(“Contact Information”)

We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Forums or Support Centre or via piratesupport@midoki.com or info@midoki.com.

This may include:

your email address;

your name or username;

your password; and

your IP address.

Information used for the purposes of serving advertisements

(“Advertising Data”)

We work with a third party advertising network called Unity Ads.

Unity Ads will collect your unique device identifier (for example IDFV for iOS devices and Android ID for Android devices).

If you would like to find out more about the way Unity Ads collects and processes your information please refer to https://unity3d.com/legal/gdpr.

Information collected for the purposes of providing analytics

(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

your Device ID;

your user ID (which is generated by us and allocated to you when you first play our games);

your device operating system & version;

your device make and model;

game play attempts, progression and results;

session game time start, end and duration;

purchase transaction types and spend you have made using virtual items in the Games;

the country of your Device;

the time, date and install source of your first download (e.g. from a clicked advertisement);

advertisements viewed and clicked; and

identification of crashes and defects.

We use the following third party analytics providers

Google Analytics; and

Crashlytics.

Crashlytics is owned by Google. Google may collect analytics data on our behalf and in accordance with our instructions, and its applicable privacy notice. If you would like to find out more about the way Google collect and process this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://policies.google.com/privacy.

Information provided by you when you respond to a job vacancy or apply for a job

("Job Vacancy Information”)

We may ask you for, or you may submit, certain information to us whenever you respond to a job vacancy or apply for a job through the Website or via jobs@midoki.com. This will normally include your CV or a portfolio of your work which may contain personal and non-personal information such as:

your name;

your date of birth;

your email address;

your qualifications;

details of your previous work and/or employment; and

any other information you include in your CV.

Information about you collected from third parties

(“Third Party Log In Information”)

When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook cookies within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.

Content created by our users which we host and display on the Forums and in the Support Centre

(“User Content”)

When users submit their own User Content to the Forums or Support Centre, this content may contain personal and non-personal information. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.

To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Games and Online Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services (for example, by understanding which aspects are popular with users), and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Games and Online Services.

To respond to your enquiries and requests for support and to enable you to use the Forums

We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre or Forums or through piratesupport@midoki.com and so you are able to use the Forums, in accordance with the terms of use agreed between us.

To engage current users and to improve the monetisation of the Games via in-app purchases

We may process information (including some Analytics) to encourage engagement from our less active users. This may include the implementation of dynamic pricing models, so that certain offers are aimed at different users depending on the amount of in-app purchases users have made within the Games so that we can offer temporary promotional discounts.

For advertising purposes

We may process Advertising Data to show you advertisements for third party services; including advertising that may reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.

We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may withdraw it at any time.

To fill any job vacancies

We may process Job Vacancy Information so that we are able to take steps prior to entering into a contract with you, including assessing your skills, qualifications and suitability for the role and/or communicating with you about the recruitment process. We may also need to process this information to enter into a contract with you.

We also have a legitimate interest in processing Job Vacancy Information during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process more efficiently, assess and confirm a candidate's suitability for employment and decide to whom to offer a job.

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.

We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).

4. COOKIES AND BEACONS

The Online Services use ‘cookies’ and similar technologies. Cookies are small text files that are placed on your computer and mobile device by software that you install. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may also be stored in your internet browser by or on behalf of third parties, such as Google or providers of advertising services.

We use cookies/beacons in order to:

learn about how the Online Services are being used and which types of individuals are using it;

record which other websites and/or platforms have referred users to the Online Services;

optimise and improve the Online Services;

make it easier for you to fill in forms via the Online Services;

enable the Online Services to remember your preferences; and

provide you with relevant advertising.

5. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Midoki, our customers, or others.

Digital Content Stores: Where the Games are downloaded though Google Play and/or iTunes, we may disclose your personal information to Google and/or Apple respectively for the purposes of facilitating any in-Game payments made through these platforms.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to receive promotional or other marketing material from us via social media (such as Facebook and Twitter) then you can opt-out by changing your social media account settings.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let us know by sending an email to info@midoki.com.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

you consented to our processing the personal data, and have withdrawn that consent;

we no longer need to process that personal data for the reason it was collected;

we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Midoki or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

the personal data was unlawfully processed;

you need the personal data to be deleted in order to comply with legal obligations;

the personal data is processed in relation to the offer of a service to a child.

Obtain a machine readable copy of your personal data, which you can use with another service provider

If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

8. DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

9. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at info@midoki.com.

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. INTERNATIONAL DATA TRANSFERS

The online Services are hosted by servers located at a data centre in France while our back up data is hosted by Amazon Web Services.

Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to info@midoki.com.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to Midoki at info@midoki.com. We will endeavour to respond to any query or questions within three business days.