PRIVACY AND DATA POLICY

ISSUED BY DOUBLE ELEVEN LTD

BLINDFIRE

Last updated: April 2023

1. INTRODUCTION AND GENERAL TERMS

These terms (the “Privacy Policy”) apply to the use of Double Eleven Ltd. (“Double 11” / “we” / “us” / “our”) videogame “BlindFire” made available for Playstation 5 and Xbox Series S/X, Windows, Steam, (the “Game”) and other online services relating to the Game (together, “Services”) for which this Privacy Policy is made available. Our registered office is at Boho X, Boho One, Gosford Street, Middlesbrough, Cleveland, TS2 1BB. We are a company registered in England and Wales.

If you have any questions or comments about this Privacy Policy, or if you want to exercise your right to object to the processing of your personal data, you can contact us at datacontroller@double11.com

This Privacy Policy is applicable to BlindFire only (and not all Double Eleven games). To find out more about how we use personal data in our other games, please visit https://www.double11.com/privacy/.

We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose and means for which personal data you supply through this Services is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018 (as each may be amended, replaced and/or superseded from time to time).

Please read this Privacy Policy carefully as it contains important information about the following:

What information we may collect about you;
How we will use information we collect about you;
Whether we will disclose your details to anyone else; and
Your choices and rights regarding the personal data we hold about you.

This Privacy Policy should be read in conjunction with our Terms of Use as may be applicable in respect of the Service. Where Terms of Use are applicable, they will be made available via the Service.

The Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Service.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following personal data from you when you use our Services (together, the “Services Information”):

Information that may be provided by you

(“Contact Information”)

Where you sign up for news or beta notifications, we will collect:

Your full name; and
Your email address.

Where you contact us for support or to provide feedback, we may collect:

Your full name;
Your address (if you choose to provide this);

A unique support code;

Your email address;
Your telephone number (if you choose to provide this); and
Your correspondence with us.

Information about your in-Game activities

(“Game Analytics”)

We may collect technical information about use of our Services through the use of tracking technologies and analytics. Personal data we may collect in this way includes the following:

Platform ID (we may have access to this but do not store it);
Session game time start, end and duration;
Game play frequency;
The time, date and install source of the player's first download;
Identification of crashes and defects. This may contain information about a device model;
‘Events’ related to your Game and Services usage, such as achievement of a milestone and the occurrence of other particular events during your usage (such as session durations, progress, page and menu usage, buttons clicked and screens viewed, timings and choices for different parts of the Services).

Information collected via our Social Media channels

(“Social Media Information”)

The Services may contain links to our social media pages and content. Third party social media websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.

Should you visit our social media pages and choose to follow or connect with us on social media, we may receive personal information from the social media providers (depending on your social media privacy settings), including:

your name (and/or your social media unique username);
your email and/or postal address;
your telephone number(s);
IP or MAC address;
your gender and/or age; and
your general interests and preferences (e.g. Likes, Shares, Posts).

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Services to you

We will process information about you (including the Submitted Information and certain Game Analytics information) to deliver our Services to you under the Terms of Use agreed between us.

The processing of information in this way is necessary, for example, for us to record your progress and current status within a part of the Services (such as the Game), in order to provide you with updated parts of the Services (such as for security patches or content updates) and to ensure the Services deliver the features promised and function properly. For these purposes, we rely upon the legal basis of performance of a contract (being performance of the Terms of Use agreed between us) and our legitimate interests (being our commercial interests in providing enhanced services and functionality to you).

In-Game Leaderboards

When using our Services, in some cases your personal data may appear in player leaderboards. This functionality may either be optional or automatic and an essential part of functionality for our Service. Please be aware that, if scoreboards are an essential part of our Service, we may not be able to turn off this functionality without it affecting your user experience.

We undertake this processing to perform a contract with you, being the terms of use agreed between us.

To provide Multiplayer Functionality & Servers

We will process information for providing the multiplayer functionality of the Game and enable players to rent games servers. Players will be able to make their servers and gameplay private, invite or restrict entry to other players and/or apply other modifications to the Game.

For this purpose, we rely upon the legal basis of: (i) performance of a contract (being performance of the terms of use agreed between us); and (ii) our legitimate interests (being our commercial interests in providing multiplayer functionality to you).

To respond to your enquiries and requests for support

We may process certain of your Services Information (including your Contact Information and certain other Services Information) so that we are able to properly respond to your enquiries, feedback and support requests, in accordance with the Terms of Use agreed between us.

For the above purposes, we rely upon the legal basis of performance of a contract (being our Terms of Use with you for the Service) and our legitimate interests, being our commercial interests to improve our Services and respond to your queries and requests for support.

To keep you up to date about the Game

Where you have consented, or where it is otherwise lawful for us to do so, we may use your Contact Information to send you emails in order to keep you informed about news and updates for or in connection with the Game.

We hope that you would like to receive our updates, but we do not want to send you emails that you don’t want. If you would like to be removed from our list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.

In line with the legitimate interest we have in promoting our business, we will use the email address you gave us via our website to provide you with this information.

There may also be circumstances where we will ask you for your prior consent in respect of our use of your personal data for direct marketing. Where we rely upon your consent to do this activity, you can withdraw your consent at any time by unsubscribing at the bottom of an email from us or sending us an email to datacontroller@double11.com.

Operating our Social Media Channels and Online Advertising

We may process personal data, including without limitation the Social Media Information, to engage with users on our social media channels, and to find out how users interact with our social media channels and content.

We process this personal data on the basis of our legitimate interests, being our interests in engaging with our users and promoting the commercial success of our Game (including by improving our advertising and marketing).

Social media networks may also display our paid advertising to you. For this, we select the audience which we would like to reach with our advertising, based on criteria such as location, age, interest in games. Further details about the way in which social media websites may collect and process your information when targeting display advertising to certain audiences, can be found in their respective privacy policies. Social media sites will also likely give you control over the use of your personal information for advertising purposes through the privacy settings in your social media account.

We may also seek to understand which publisher of our marketing materials referred you to the Game and, for example, to which marketing campaign that referral related. This information is helpful for our purposes of understanding which marketing and promotion activity is successful.

To prevent fraudulent or illegal activity

We may process your Services Information for our legitimate interests of ensuring that your use of our Services is lawful and in compliance with our agreement (being the Terms of Use agreed between us), to prevent disruption to our Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.

To help us to understand usage of the Service, improve the Services and to help us to fix any problems

We may process information about you (being any part of the Services Information) so that we can understand usage of our Service, analyse and improve our Services and develop new services or new parts thereof.

This processing is necessary for us to pursue our legitimate interests, being our commercial interests in: (i) ensuring that our Services functions properly so that you and other users have the best experience; (ii) improving the quality of our Service; (iii) identifying and correcting any bugs or problems with the Services or any part thereof; and (iv) developing and creating new services in the future.

Where our processing activity relates to detecting and fixing problems with the Service, we also rely upon the legal basis of performance of a contract (being our Terms of Use with you for providing the Service).

User-generated content

When using our Services you may decide to post data that may or may not contain personal data, in accordance with the rules of our Services and where this functionality may be made available.

We cannot control the dissemination via the public internet of personal data you may decide to post or make available to other users. Please exercise care before sharing your personal data with others.

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it. Activities which are carried out by or in collaboration with third party service providers include the provision of hosting and storage services.

Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal data to third parties (e.g. our licensors, app operators, stores or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Double11, our customers or others.

Digital Content Stores: Where the Games or in-Game virtual items are downloaded through a digital content store (including Xbox and PlayStation), the relevant platform providers will collect personal information for the purposes of facilitating any payments made through these platforms. Further details about the way in which those platforms collect and process your information can be found in their respective privacy policies.

Support Centre: We use a third party platform provider called Zendesk to manage any support requests, queries and issues raised by users through the Support. Further details about the way in which Zendesk may collect and process your information can be found in their privacy policy at https://www.zendesk.co.uk/company/customers-partners/privacy-policy/.

5. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply with requests without undue delay and within one month at the latest.

To make a request, please let our Data Protection Officer know via datacontroller@double11.com.

Ask for a copy of personal data we are processing about you and have inaccuracies corrected or request erasure

You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. You can request a copy by emailing datacontroller@double11.com.

We will use reasonable efforts, to the extent required by law, to comply with requests to supply, correct or delete personal data held about you on our files (and request that any third parties to whom it has been disclosed to do the same).

Object to us processing personal data about you

You can ask us to restrict, stop processing or delete your personal data if:

you consented to our processing the personal data and have withdrawn that consent;
we no longer need to process that personal data for the reason it was collected;
we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Double11 or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed;
you need the personal data to be deleted in order to comply with legal obligations; and/or
the personal data is processed in relation to the offer of a service to a child.

You can request account deletion by sending an email to datacontroller@double11.com.

Obtain a machine-readable copy of your personal data, which you can use with another service provider

If (i) we are processing personal data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. Contact information for the Information Commissioner’s Office, the UK’s independent authority setup to uphold information rights, is available here: https://ico.org.uk/.

6. DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.

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 requirements. Where the Game is made available to you as part of Beta testing, at the end of the ‘lifespan’ of such beta test, we may irrecoverably delete all relevant Service-related data (such as user accounts and progression).

7. CHILDREN

We do not use our Services to knowingly solicit information from, or market to, children under the age of 13. Our terms of use prohibit users aged less than 13 years from accessing our Services. In the event that we learn that we have collected personal data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at datacontroller@double11.com.

8. SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

Please be aware that, while we make the security of our Services and your personal data a high priority, no security system can prevent all security breaches.

Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Service; subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.

9. INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the maintenance of the Services, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at datacontroller@double11.com.

10. CONTACT INFORMATION

All questions, comments or enquiries should be directed to Double11 at datacontroller@double11.com. We will endeavour to respond to any query or questions within a reasonable amount of time.