This notice explains how Rovio Entertainment Ltd (referred to as “we” in this notice) collects, stores, uses, or otherwise processes the personal data of end users of Rovio games available on the Apple Arcade service (referred to as “you” in this notice), and what rights you have if we are processing your personal data.
In this notice, “Games” refers to those of our games which are available on the Apple Arcade service. The expression “your data” is used when referring to personal data that relates to you as an identified or identifiable individual.
It is important that you read this notice before accessing or using the Games so that you are aware of how and why we may use data relating to you. In addition to this notice, we encourage you to carefully review our Terms of Service, which govern your use of the Games.
By “data controller,” we mean an entity that determines how and why personal data is processed. We are the data controller for the activities described in this notice. Our company name is Rovio Entertainment Ltd. Our address is Keilaranta 7, FI-02150 Espoo, Finland.
In matters related to this notice, you can reach us by email at [email protected]. If you have any questions or concerns about the way we use your data, you may also contact our Data Protection Officer by email at [email protected].
When you play our Games, we may process your data in ways that enable us to perform our contract with you and to provide the Games to you (for example, to save your game progress).
If you contact our player support team with a matter relating to the Games, we may process any information included in the support request to handle the request. We do this based on our legitimate interest to make sure you have the best possible user experience in the Games.
Based on our legitimate interest to safeguard our operations, we may also process your data to:
Finally, we may process your data as necessary to:
In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
We do not use your data to make automated decisions which significantly affect you. By an “automated decision”, we mean a decision made by an information system without any human intervention.
We may collect and process an online identifier generated through Apple’s Game Center together with relevant analytics data to keep track of your progress in the Games. We may also collect analytics data or information related to technical issues encountered in the Games, but this information does not uniquely identify you or the device you use.
We may process any information included in the communications you send to our support team, such as your email address, the message body, and any attachments you choose to include.
We do not collect any other data relating to you in connection with the Games. Other data about how you play the Games (for example, your game account and related information) may be stored locally on your device or on Apple’s servers. We have no access to such data.
We may collect your data directly from you / your device by automatic means when you play our Games.
Additionally, we may collect your data directly from you when you submit it to us through our support channels or otherwise. Providing this data to us is not mandatory. However, we may be unable to provide you with meaningful support without the information required to handle your request.
We may share your data with third parties to achieve the purposes described in this notice. This may include sharing data with the following types of recipients:
In connection with the processing activities described in this notice, your data may be transferred to and/or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA”). These countries may have data protection laws that differ from the laws of your country. In these cases, we will provide appropriate safeguards to protect your personal data. These safeguards may include compliance with the European Commission’s standard contractual clauses for transfers of personal data. Upon request, we can provide you with details on the applicable safeguards.
We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to comply with any legal requirements.
After the applicable retention period, we will either delete or de-identify your data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).
We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the processing activities described in this notice. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary, but typically include, for example, encryption in transit, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.
If we are processing your data, you have the right to:
To exercise any of your rights, you may also contact us at [email protected]. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide sufficiently detailed information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf. While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations.
Should you be unsatisfied with how we fulfilled your request, you may appeal the decision you have received using the internal appeal process we have established. To do so, please submit a new request after you have received a decision from us on your earlier request. In the new request, you should state that you wish to appeal an earlier decision and that you are asking for the matter to be considered in accordance with our internal appeal process. You may be asked to provide information about the earlier request and decision that reasonably allows us to identify them. Once you have submitted the appeal and provided information to adequately identify the earlier request and decision, we will process your appeal as soon as practicable.
Finally, you always have the right to lodge a complaint with your local data protection authority (such as the Office of the Data Protection Ombudsman in Finland) regarding our processing of your data. However, we ask that you reach out to us first to allow us to address your concerns.
Our Games are generally intended for adults and designed primarily with adults in mind. When you access and use our Games, we may ask you to confirm your age to us or your age may otherwise become known to us. If we discover that you are a minor or do not meet an age threshold we apply, we may take steps to limit, suspend, or terminate your access to the Games where we believe that to be necessary due to applicable regulatory or platform requirements or to provide you with an appropriate experience. If your access to the Games is not suspended or terminated, we will limit the use of your personal data to what is necessary for the internal operation of our Games and other uses permitted by applicable laws, regulations, and platform policies. This may include removing access to certain parts or features of the Games.
We may update this notice from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available to you in the Games.