Scriptic Privacy & Terms
1. ABOUT US
1.1 Welcome to the privacy policy for Scriptic Limited, a company registered in England under company number 11061425 with its registered office at 86-90 Paul Street, London, England, EC2A 4NE (referred to in this privacy policy as “us”, “we”, or “our”).We are the controller and are responsible for your personal data,
1.2 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 via applications such as ‘Dead Man’s Phone’ on the application ‘Scriptic: Crime Stories’, (“Games”), access www.scriptic.com (“Website”), 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
2.1 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 Website.
2.2 Our Games and our Website are not intended for, and should not be used by, children under the age of 13. We do not knowingly collect personal data from children under 13.
2.3 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. THIRD-PARTY LINKS
3.1 Our Games and our Website 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.
4. DATA WE COLLECT ABOUT YOU
4.1 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).
4.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Contact Data, such as your email address;
(b) Profile Data, such as your username (such as user scriptic ID), password, preferences and feedback;
(c) 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; 20145098-1
(d) Technical Data, including your geographical location (such as country, region and city), 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);
(e) Financial Data, such as the costs, currency code and amount of Scriptic coins when you make an in-Game purchase;
(f) Transaction Data, such as the transaction ID, time of transaction and product ID and other information as provided on the receipt of the transaction from third parties such as Google and Apple when you make an in-Game purchase;
(g) Marketing and Communications Data, including your preferences in receiving marketing
from us and our third parties and your communication preferences.
4.3 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.
4.4 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.
5. IF YOU FAIL TO PROVIDE PERSONAL DATA
5.1 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 Website , 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.
6. HOW DO WE COLLECT PERSONAL DATA?
6.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Name, 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 such as linking your Apple ID;
● make any purchases in-Game;
● give feedback or contact us directly;
● subscribe to our publications or marketing via our mailing list;
● enter a competition, promotion or survey. 20145098-1
6.2 Automated technologies or interactions. As you interact with our Games and our Website, we will automatically collect Technical Data about your equipment, actions and patterns. We collect this personal data by using server logs and other similar technologies.
6.3 Third parties or publicly available sources. We will receive personal data about you (such as Transaction Data when you make in-Game purchases) from various third parties as set out below:
● Google Play Services;
● Apple App Store Services; and
● Netflix.
Technical Data (such as User ID and geographical location such as country, region and city for analytics, debugging and fixing issues with our Games) from third parties such as:
● Firebase Analytics (based outside the UK);
● Adjust (based outside the UK); and
● Mixpanel (based outside the UK).
7. HOW DO WE USE YOUR PERSONAL DATA?
7.1 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:
(a) 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.
(b) 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.
(c) Where we need to comply with a legal obligation to which we are subject.
7.2 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.
8. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
8.1 We have set out in the table below, 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.
8.2 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.
9. COOKIES
9.1 Our Website 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 Website. 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. Please see our Cookies Policy for more information.
10. MARKETING
10.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
10.2 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.
10.3 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
11. OPTING OUT
11.1 You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
11.2 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.
12. CHANGE OF PURPOSE
12.1 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.
12.2 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.
13. TRANSFERS OF YOUR PERSONAL DATA
13.1 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 7 in order to allow us to conduct our business activities and provide our Games, our Website and other services to you, enforce our rights or to comply with legal or regulatory obligations. Such third parties include:
(a) suppliers and service providers who we engage to process data on our behalf (such as, for example, Apple or Google and analytics providers such as Firebase Analytics, Adjust and Mixpanel.)
(b) prospective buyers of our business or assets in the event that we sell any of our business or assets; and
(c) regulators, government bodies, law enforcement agencies, and our legal and other professional advisors. 20145098-1
13.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
13.3 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:
(a) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government; or
(b) 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.
13.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
14. SECURITY
14.1 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.
14.2 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.
15. RETENTION
15.1 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.
15.2 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.
16. YOUR LEGAL RIGHTS
16.1 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.
16.2 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.
16.3 Subject to certain legal conditions, you have a number of rights in respect of the personal information we hold about you. These include:
(a) access: you have the right to request, free of charge, access to a copy of the personal information that we hold about you; 20145098-1
(b) correction: you can ask us to change, correct, or complete any inaccurate, incomplete, or out-of-date personal information that we hold about you;
(c) 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.
(d) 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;
(e) 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
(f) 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
(g) 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.
16.4 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.
16.5 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. 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.
17. CONTACT
17.1 If you have any queries regarding this policy please contact us on: support@scriptic.com
17.2 If you believe that we have not been able to assist with your complaint or concern, 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).
18. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
18.1 We keep our privacy policy under regular review and we may update this notice to reflect changes in our practices. The updated version will be available on our Website.
18.2 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 by contacting us.
LAST UPDATED: August 2023