Privacy & Terms

  1. ABOUT US

    1. Welcome to the privacy policy for Electric Noir Studios Limited, a company registered in England under company number 11061425 with its registered office at 27 Unit 8, 27 Corsham Street, London, England, N1 6DR (referred to in this privacy policy as “us”, “we”, or “our”).

    2. We respect your privacy and are committed to protecting your personal data. This privacy policy will explain how your personal data will be looked after or used by us when you download, access or play our games (including ‘Dead Man’s Phone’), access any of our websites (including www.electricnoirstudios.com, www.scriptic.com) contact us, or otherwise interact with us. It also tells you about  your privacy rights and how the law protects you. Please take the time to read and understand this privacy policy.

  2. PURPOSE OF THIS PRIVACY POLICY

    1. This privacy policy aims to give you information on how we collect and process your personal data through your use of our games and our websites.  

    2. Our games and our websites are not intended for, and should not be used by, children under the age of 16. We do not knowingly collect personal data from children under 16.

    3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

  3. CONTROLLER

    1. We are the controller and are responsible for your personal data.  

    2. If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Electric Noir Studios Limited

Email address: privacy@electricnoirstudios.com 

Postal address: 27 Unit 8, 27 Corsham Street, London, England, N1 6DR

  1. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  1. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 

    1. We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

    2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  2. THIRD-PARTY LINKS

    1. Our games and our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave a platform operated by us, we encourage you to read the privacy policy of every third party platform you visit.

  3. DATA WE COLLECT ABOUT YOU

    1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

      1. Identity Data, such as your first name and last name;

      2. Contact Data, such as your email address;

      3. Profile Data, such as your username, password, preferences and feedback;

      4. Usage Data, meaning information about your interactions with and within a game, such as the date and time you accessed the game, the amount of time you spend in the game, the amount of time you spend on an element within the game, and your interactions with other users in a game;

      5. Technical Data, including your geographical location, IP address, login data, information about the device you use to access our game or our website (such as your hardware model, operating system, mobile network information, unique device identifiers); and

      6. Marketing and Communications Data, including your preferences in receiving marketing from us and our third parties and your communication preferences.

    3. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific game feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

    4. We do not collect any special categories of personal data about you (which means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

  4. IF YOU FAIL TO PROVIDE PERSONAL DATA

    1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our games, our websites, any updates or any additional content or services you have requested). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

  5. HOW DO WE COLLECT PERSONAL DATA?

    1. We use different methods to collect data from and about you including through:

      1. Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • download a game from an App Retailer or other online platform;

  • register details with us to use a game or connect a third party account;

  • make any purchases in-game;

  • give feedback or contact us directly;

  • subscribe to our publications or marketing;

  • enter a competition, promotion or survey.

  1. Automated technologies or interactions. As you interact with our games and our websites, we will automatically collect Technical Data about your equipment, actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

  2. Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

    1. Technical Data from analytics providers such as:

  • Google Play Services and Firebase Analytics (based outside the UK);

  • Adjust (based outside the UK); and

  • Mixpanel (based outside the UK).

  1. HOW DO WE USE YOUR PERSONAL DATA?

    1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

      1. Where we need to perform the contract we are about to enter into or have entered into with you, or to take steps at your request before entering into such a contract.

      2. Where it is necessary for our legitimate interests (or those of a third party). 

‘Legitimate interest’ means our interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  1. Where we need to comply with a legal obligation to which we are subject.

  1. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

  1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

    1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  1. COOKIES

    1. Our websites use cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse and also allows us to improve our websites. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

    2. We use the following cookies:

      1. Strictly necessary cookies. These are cookies that are required for the operation of our website. 

      2. Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

      3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

      4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

    3. Please note that the following third parties may also use cookies, over which we have no control:

      1. Vimeo – to enable video content to play and collect analytics data.

    4. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

    5. You can choose which cookies we can set by changing the settings on your browser. 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 websites.

  2. MARKETING

    1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    2. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

    3. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  3. OPTING OUT

    1. You can ask us or third parties to stop sending you marketing messages at any time by logging into the relevant game and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

    2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

  4. CHANGE OF PURPOSE

    1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  5. TRANSFERS OF YOUR PERSONAL DATA

    1. We do not sell your personal information. However, we may disclose it to certain third parties for the purposes set out in the table in Section 10 in order to allow us to conduct our business activities and provide our games, our websites and other services to you, enforce our rights or to comply with legal or regulatory obligations. Such third parties include:

      1. our group of companies (i.e. our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006);

      2. suppliers and service providers who we engage to process data on our behalf (such as, for example, Apple or Google);

      3. prospective buyers of our business or assets in the event that we sell any of our business or assets; and

      4. regulators, government bodies, law enforcement agencies, and our legal and other professional advisors.

    2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 

    3. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

      1. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

      2. where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

    4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

  6. SECURITY

    1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  7. RETENTION

    1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

    3. In some circumstances you can ask us to delete your data. See Section 17 below for further information.

    4. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  8. YOUR LEGAL RIGHTS (INCLUDING RIGHT TO ACCESS YOUR INFORMATION)

    1. In some situations, you can ask for access to your personal data, correct your data, delete your data, or object to our use of your data. If you wish to exercise any of those rights, please contact us using the contact details set out at the top of this privacy policy.

    2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    3. Subject to certain legal conditions, you have a number of rights in respect of the personal information we hold about you. These include:   

      1. access: you have the right to request, free of charge, access to a copy of the personal information that we hold about you;

      2. correction: you can ask us to change, correct, or complete any inaccurate, incomplete, or out-of-date personal information that we hold about you;

      3. erasure: you can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.

      4. objection: you can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You can also object to our use of your personal information for direct marketing purposes;

      5. restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it; and

      6. transfer: In certain circumstances, you can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form; and

      7. withdraw consent: If you have given us your consent to use your personal information (for example, for marketing purposes), you can withdraw your consent at any time.

    4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    5. Please also be aware that not all of those rights are absolute and there may be circumstances in which we will not fully comply with your request because of a specified legal ground or exemption.  

    6. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

LAST UPDATED: 5/04/2022] 

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