Effective as of 1st December 2022
Who decides how your information is used?
StaplesVR (525 Rosebank Road, Avondale, Auckland, New Zealand, 1026) generally is the data controller responsible for making decisions about how we use your personal information . If however you are based in the United Kingdom (UK), Russia or the European Economic Area (EEA), your data controller is StaplesVR LTD in the UK.
If you have any questions or comments on this policy, you can:
The information we collect about you and how we use it
We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service:
- Some of our Services require you to register with us or sign up for an account before you can use them. Where this is the case, you provide us with information including your name and and email address. We collect and use this information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services.
- If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
- If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.
- If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.
- We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for participating Services, while you are not directly interacting with these Services), including how you move around and events that occur during gameplay. Our Services include location based games whose core feature is to provide a gameplay experience tied to your real world location, so we need to know where you are to operate these games for you, and to plan the location of in-game resources (for example artifact locations in Purakau). We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through and mobile/cell tower triangulation.
- We also collect and use your in-game actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device), to operate the Services for you and to personalize your gameplay and user experience. We will also generate an internal account ID when you use certain Services to associate you with an account.
- We further use the information above in order to provide technical and customer support to you.
- You also give us Personal Data when you make a purchase through us, subscribe to our publications, register for a live event, enter a competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, age, and email address. We use that information to fulfil those Services to you and to provide related customer support to you.
In addition, we have and rely on a legitimate interest in using your Personal Data as follows:
- Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device and advertising identifiers, age, as well as actions you take during gameplay, your in-game user settings and preferences (including avatar characteristics) and your in-app purchases to learn about our users, and understand who is using our Services and how.
- Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
- Using your email address and device information in order to share updates and news with you either within the games or by email. You can unsubscribe from these at any time in your device settings or in-app settings.
- To improve the features that we offer you through the Services, or to provide you with new or additional features for our Services.
- To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.
We will only use your Personal Data to do the following if we have your consent:
- If you elect to turn on background activity tracking in our Services we will collect your Personal Data as you use the Services as well as in the background when you do not have the Services open on your device. This includes your device location. We use background activity tracking to provide you certain functionalities in the Services such as in-game items and alerts for nearby gameplay events. You can change your mind and turn off background activity tracking at any time in your device settings or in-app settings.
- Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at any time in your device settings or in-app settings.
Who we share information with
We will not share any Personal Data that we have collected from or regarding you except as described below:
- run, operate and maintain our Services through third party platform and software tools;
- perform content moderation and crash analytics;
- run email and mobile messaging campaigns;
- perform game and marketing analytics;
- to provide measurement services
- administer live events, competitions, sweepstakes and promotions, including registering players, managing check-in and attendance, verifying eligibility and prize fulfilment;
- provide payment attribution;
- provide technical and customer support; and
- process payments
Information Shared Publicly: When you use the Services, and in particular when you play our games, or participate in our forums, the following information about you may be shared on web pages accessible to the public and therefore become publicly available: your username, and public messages.
Information Shared with Third Parties. We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.
Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.
How your Personal Data is transferred
How we keep your Personal Data safe
We have appropriate legal, organizational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to 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. 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.
How long we will keep your Personal Data
When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.
Your rights and choices
You have certain rights in relation to your Personal Data. This means you can:
- Request access to the Personal Data we hold on you by emailing email@example.com
- Ask us to stop processing your Personal Data, including for direct marketing and promotional purposes such as tailored rewards, promotions, and other offers, by emailing firstname.lastname@example.org
The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.
We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction