This policy is effective as of December 1, 2020.
Strollhunt Limited is the developer of the Strollhunt mobile application, a location-based city exploration game that is played in the real world. For the game to be played in the real world, we need to collect and use information about you. We take privacy protection seriously and solely use this information where we have a legal basis to do so.
1. Information we collect
By signing up for our Services (the "Services"), by for example signing up for an account, you freely give us Personal Data. We collect and use that information in order to authenticate you when signing up, logging in and using the Services.
For example, by using Sign In with Apple to create an account on our Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you select the Hide My Email option provided by Apple.
Location awareness is essential to the delivery of our Services to present you with the closest Hunt(s), Playground(s) and to validate your Answer(s) to Quest(s). We therefore need to collect and use your device location information as you use our Services (and, if you allow background location access for our Services, while you are not directly using the Services).
We collect and use your interactions with our Services, such as but not limited to the Quests you have solved, the Hints you have used, the Points you have accumulated, the Hunts you have started or completed to offer you a personal experience and to improve the functioning of the Services.
We collect and use information about your mobile device (including your device unique identifier, operating system, model, configuration, settings, and information about third party applications or software installed on your device), in order to run the Services and offer you a more tailored experience.
We also use this information to display promoted locations that are presented to you as part of the game, for instance in the form of Hunts, Quests, Nearby locations or information on the map.
We also use this information in order to deliver you customer as well as technical support, when needed.
We use your device information and email address in order to send you updates and news either within the app or by email.
We use your internal account ID in order to associate with your account content that you decide to freely generate and distribute through the Services (such as new Hunts, Quests, Hints, text and image Answers, Nearby locations).
We use this information to provide features enabling you to interact and play with other users, including inviting your friends, finding your friends and being found by your friends, and sharing your game experience with them.
You freely provide us Personal Data such as your name, phone number, email address, country or city of residence when you make an in-app purchase, sign up for our communications, redeem a promotion, complete a questionnaire or communicate with us. We use this Personal Data in order to run those Services.
When you access our servers via the Strollhunt mobile application, we may automatically log the standard usage data provided by your device. This data may include your device’s Internet Protocol (IP) address, your device operating system and version, your device and advertising identifiers, your activity within the app (for instance, the screens which you view, the features you use, the links you click on, your device and in-app settings and your in-app purchases), time and date, and other details.
Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information that may have contributed to the problem. We use this Personal Data to understand who is using our Services and how in order to improve the functioning of those Services.
Our app may also access and collect data via your device's in-built tools, such as: ● Your identity
● Location data
● Storage, photos and/or media
● Background data refresh
● Mobile data
● Device/app history
What we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
We may ask for Personal Data, such as your:
● Social media profiles
● Date of birth
● Phone/mobile number
● Payment information
We collect business data. Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.
2. Legal bases for processing
We will process your Personal Data lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
● It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
● It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
● You give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
● We need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
We don’t keep Personal Data for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your Personal Data for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
3. Collection and use of information
We may collect, hold, use and disclose information for the following purposes and Personal Data will not be further processed in a manner that is incompatible with these purposes: ● For technical assessment, including to operate and improve our app, associated applications and associated social media platforms;
● To provide you with our app and platform's core features;
● To offer new or additional features;
● To process any transaction or ongoing payments;
● to enable you to access and use our app, associated platforms and associated social media channels;
● To contact and communicate with you;
● To organize and conduct in-person events;
● For internal record keeping and administrative purposes;
● For analytics, market research and business development, including to operate and improve our app, associated applications and associated social media platforms; ● To run competitions and/or offer additional benefits to you;
● For advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
● To comply with our legal obligations and resolve any disputes that we may have; and ● To consider your employment application.
4. Disclosure of Personal Data to third parties
We may disclose Personal Data to:
● Third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
● Our employees, contractors and/or related entities;
● Sponsors or promoters of any competition or event (online or offline) we run; ● Credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
● Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
● Third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you; and
● Third parties to collect and process data.
5. International transfers of Personal Data
The Personal Data we collect is stored and processed in the United States, United Kingdom and France, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your Personal Data, you consent to the disclosure to these overseas third parties.
We will ensure that any transfer of Personal Data from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Where we transfer Personal Data from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
6. Your rights and controlling your Personal Data
You have a certain number of rights associated with your Personal Data. If you wish to exercise these rights, you can email us at: email@example.com
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.
provide Personal Data to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it.
Restrict: You may choose to restrict the collection or use of your Personal Data. If you have previously agreed to us using your Personal Data for direct marketing purposes, you may change your mind at any time by contacting us. If you ask us to restrict or limit how we process your Personal Data, we will let you know how the restriction affects your use of our app or products and services.
Access and data portability: You may request details of the Personal Data that we hold about you. You may request a copy of the Personal Data we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the Personal Data we hold about you at any time. You may also request that we transfer this Personal Data to another third party.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. If you believe that we have not complied with data protection laws, you also have the right to complain to our regulator, the UK Information Commissioner’s Office, or to your local regulatory body or data protection authority.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
A cookie is a small piece of data that an app may store on your device, typically containing a unique identifier that allows the app servers to recognize your device when you use the app; information about your account, session and/or device; additional data that serves the purpose of the cookie, and any self-maintenance information about the cookie itself.
8. Business transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your Personal Data according to this policy.
9. Limits of our policy
Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
10. Changes to this policy
11. Disclosure for California residents
California law requires that we make certain disclosures about your data. We do not “sell” your Personal Data to third parties as most people would understand that term. The information listed in Section 1 falls under the following California Consumer Privacy Act (CCPA) categories: ● Identifiers
● Commercial information
● Internet or other electronic network activity information
● Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
● Protected classification characteristics under California or federal law ● Geolocation data
● Visual information.
Strollhunt Limited Data Controller