Culture Warz Privacy Policy
Policy version: 15/04/2023
Culture Warz (the app) is provided by Rear Admiral, trading as Rear Admiral Games Limited (‘we’, ‘our’ or ‘us’).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your information).
It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of your information obtained via the app, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
If you are aged under [13] you must not use the app as it is not designed for you. We do not intend to collect the information of anyone under 13. If you are aware that any information of anyone under 13 has been shared with the app, please let us know so that we can delete that data.
If you are aged over [13] you may use the app. This version of our privacy policy is primarily written for adults, including parents and guardians of child users.
If you are aged under 18, we recommend that you speak to an adult that you trust if you have any difficulties reaching an informed decision regarding the activation of any use of your information or our treatment of your information.
What this policy applies to
This privacy policy relates to your use of the app only.
The app links to [insert, eg other apps, websites or services owned and operated by certain trusted third parties] to [insert details (eg make additional products, information and services available to you)]. These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.
Information we collect about you
The information we collect about you depends on the particular activities carried out through the app. We will collect and use the following information about you:
| Category of data | More details |
|---|---|
| Identity and account data you input into the app Registration is mandatory in order to use the app |
|
| Data collected when you use specific functions in the app |
|
| Other data the app collects automatically when you use it |
|
| Data collected when you permit the collection of location data |
|
Sometimes you can choose if you want to give us your information and let us use it. Where that is the case we will tell you and give you the choice before you give the information to us. We will also tell you whether declining to share the information will have any effect on your use of the app.
We collect and use your information for the purposes described in the section ‘How and why we use your information’ below.
Location services/data
The app will request your consent to use location services to precisely identify your location each session (i.e. each time the app is opened or has been placed in the background). We require access to that data in order to support technical diagnostics.
The location services in the app will not operate unless location services/data are generally enabled on your device. If you do not provide your consent, you may use the app but that will mean that we will be unable to provide support with technical diagnostics. To withdraw your consent at any time you will need to opt out via the options menu in the app (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn).
We will not process your location data other than for technical diagnostics and/or analytics.
How your information is collected
We collect information from you when you use the app.
How and why we use your information
Under data protection law, we can only use your information if we have a proper reason, eg:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your information for and why.
| What we use your information for | Why we use your information |
|---|---|
| Providing the functionalities of the app to you | Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —for our legitimate interests, ie to be as efficient as we can so we can deliver the best app experience to you |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the app or service or other important notices | Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to provide the best service to you |
| Protect the security of systems and data used to provide the app and its services | To comply with our legal and regulatory obligations We may also use your information to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Operational reasons, such as improving efficiency, training and quality control or to provide support to you | For our legitimate interests, ie to be as efficient as we can so we can deliver the best app experience to you |
| Statistical analysis to help us understand our customer base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best app experience to you |
| Disclosures and other activities necessary to comply with legal and regulatory obligations, eg to record and demonstrate evidence of your consent to our use of your information where relevant | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former customers | For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information. |
| To share your information with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases, information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
Marketing
We will use your information to send you in-app updates about in-app offers, in-app promotions or new in-app features.
We have a legitimate interest in using your information for marketing purposes (see above ‘How and why we use your information’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by choosing to do so in the app’s options menu.
We will always treat your information with the utmost respect and never sell or share it with other organisations for marketing purposes.
How long your information will be kept
Your Information is kept for as long as you are using our app, and then for up to three years from the date you stop interacting with the app.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
- Access to a copy of your information
- Correction (also known as rectification)
- Erasure (also known as the right to be forgotten)
- Restriction of use
- Data portability
- To object to use
- Not to be subject to decisions without human involvement
- The right to withdraw consents
You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email us and:
- provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your information secure
We have appropriate security measures to prevent your information from being accidentally lost, or used or accessed unlawfully. We limit access to your information to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where legally required to do so.
How to complain
Please contact us via our contact form if you have any questions about this privacy policy or the information we hold about you.
You also have the right to lodge a complaint with the Information Commissioner (https://ico.org.uk/make-a-complaint or 0303 123 1113).
Changes to this privacy policy
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the app or by other means, such as email.
