Legal notes and privacy
Privacy

PRIVACY AND DATA POLICY ISSUED BY MILESTONE S.r.L.

Last Updated: 7 February 2018



1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by Milestone S.r.L. (‘Milestone’ / ‘we’ / ‘us’). Our office is at Via Olona 2, 20123 Milan, Italy. We are a company registered in Italy, with company number 11669680156.

This privacy and data (“Privacy Policy”) applies and has effect in respect of all games, related online services and other software and products made available by us (together the “Game(s)”).

If you have any questions or comments about this Privacy Policy please contact us via the support page for the Game available here: http://milestone.it/supporto/?lang=en (“Support Services”)

Milestone is committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these online services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

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 information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use, which can be found here: http://milestone.it/eula/.

By accessing a Game you authorise us to collect, store, access, transfer and use your information as described in this Privacy Policy.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page 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 Games.


2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data:

Information provided by you when using the Game or the Online Service (“Submitted Information”)
We may ask you for, or you may submit (including without limitation through voice or text features) personal and non-personal information and data to us through the Online Service and/or the Game whenever you contact us, submit User Content in the Game or on the Online Service.
This may include:

  • your email address;
  • your username and account in respect of the platform on which you are using the Game (for instance your PSN ID for PlayStation and your Apple Game Centre username and account details for iOS).

We may also obtain sensitive personal data about you if you voluntarily supply it through the Game and/or the Online Service.
This could include a photograph that you have taken and uploaded to the Game (for example, when you create your User Content).
If you volunteer such information, you will be consenting to our processing it for the purpose explained to you when you supply it.

How you use our Services (“Analytics”)
We may collect technical information about your use of the Game /or the Online Service through the use of tracking technologies and analytics.

By way of example, data we may collect includes the following Analytics:

  • how many times you access the Game;
  • traffic data;
  • the devices that you use to access the Game;
  • your internet service provider; and
  • the actions you take when playing the Game.

When you install, uninstall or update the Game, a unique application number and information about your installation, for example, the type of operating system, may be sent to us.

We use the following third party analytics providers (“Third Party Providers”):

The third party analytics providers listed above will collect Analytics on our behalf and in accordance with our instructions, and their applicable privacy notice.

You can find out more about the way the Third Party Providers collect and process this information by following the above links to the privacy notice and/or terms and conditions for each applicable third party analytics provider

Information about you collected from your device or Third Parties (“Content Information”)
We may collect information about you which you make available to us and which is stored on your console, device, or your Facebook or other social media profiles. This might include images (photographs/screenshots), video or other digital content such as records of your gameplay.

When you use your PSN ID, Xbox Gamertag and/or Apple Game Centre username and account details to access our Games, and/or you connect your PSN, Xbox Live, Steam and/or Apple Game Centre account to our Games, you will be sharing additional information with us from your Apple Game Centre profile. We shall use this information in accordance with Apple’s policies and this Privacy Policy.


3. HOW WE USE INFORMATION WE COLLECT ABOUT YOU

We will use any information that we collect about you, including any personal data, for the purposes described to you at the time that we collect such information, and for the following purposes:
Submitted Information

  • to help us identify you and to open, run and monitor any accounts you hold with us;
  • administration;
  • to process your orders of Virtual Items and enquiries;
  • to monitor any User Content you contribute through the Online Service and/or the Game; and
  • to send you information about, and updates concerning, the Online Service and/or the Game;
  • to provide you with information about other games and services we offer that are similar to those that you have already purchased;
  • to make suggestions and recommendations to you and other users of the Game about goods and services that may interest you or them;
  • to allow you to participate in interactive features of the Game when you choose to do so; and
  • to notify you about changes to the Game or the services we provide.

Analytics
  • to remember you and your player profile, including your avatar and saved data;
  • to understand how, and how often, users play the Game and use the Online Service;
  • to administer the Game and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • to help us improve the Game and the Online Service to ensure that content is presented in the most effective manner for you and for your device; and
  • as part of our efforts to keep any multiplayer elements for the Game safe and secure.

Content Information
  • to allow you to share your gameplay with other users of the Game and your friends;
  • to allow you to participate in interactive features of the Game when you choose to do so;
  • to make suggestions and recommendations to you and other users of the Game about goods and services that may interest you or them; and
  • to provide you with information about other games and services we offer that are similar to those that you have already purchased.


4. WHY WE COLLECT INFORMATION ABOUT YOU

To provide our Games and the Online Service to You
As applicable, we will use information about you (including Submitted Information, Content Information and Analytics) for delivering our Games and the Online Service to you under the Terms of Use agreed between us, as well as:

  • responding to your enquiries; and
  • contacting you about matters requiring your attention.

This processing of Submitted Information, Content Information and Analytics is necessary for us to pursue our legitimate interests of making our Games and the Online Service available to you, and ensuring that our Games function properly so that you have the best experience when playing any one of our Games and using the Online Service.

To understand how users play our Games and use our Online Service
We process information (including Submitted Information, Content Information and Analytics) to understand how players use our Games or our Online Service, and to compile Analytics and statistical reports regarding that activity.
This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Games function properly so that you and other users have the best experience when playing any of our Games and using the Online Service, and (ii) improving the quality of our Games and our services, and providing a better experience to our users.

Marketing
We use various forms of marketing to provide you with promotional materials about our Games and/or the Online Service.
We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already.
Direct Marketing: We might send you marketing emails about products or services which are similar to or related to our Games or Online Service, but we shall not do so without your express consent.

Targeted Marketing: We may use the information we collect about you to serve you targeted advertisements via our Games or the Online Service. We do this to provide you with more relevant advertising content.

We work with the following third party providers to provide you with such targeted marketing:
  • Facebook

The processing of your information in this way is necessary for us to pursue our legitimate interests of ensuring that our Games remains accessible for all of our users.

5. DATA SHARING

5.1 We will share your information with third parties only in the ways that are described in this Privacy Policy, including the third party analytics providers detailed in section 2 above. If you would like to find out more about how the third parties listed in this policy use your information, this should be set out in their respective privacy policies.
5.2 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 this information.
5.3 In addition, 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).
5.4 If we are involved in a merger, acquisition, or sale of all or a portion of its 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.
5.5 We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements between us, to investigate potential breaches, or to protect the rights, property or safety of Milestone, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


6. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by changing your account settings in the Online Service at any time. Alternatively, you can contact us via the Support Service and let us know that you no longer wish to receive promotional or other marketing material from us or third parties.


7. YOUR RIGTHS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

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 without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know via the Support Services .

Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you
You can ask us to restrict, stop processing, or to 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 Milestone, 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 a legal obligations;
  • the personal data is processed in relation to the offer of a service to a child.

Obtain a machine readable copy of your personal data, which you can use with another service provider
  • If we are processing data in order to perform our obligations to you, or because you consented, if 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 is 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.


8. Data Retention

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this privacy policy. We consider that 12 months from the date of your last login an appropriate period of time to retain this data and after this date we will delete your details.


9. CHILDREN

We do not use our Games and/or the Online Service to knowingly solicit data from or market to children under the age of 16. Our Terms of Use prohibit users aged under 13 years from accessing our Games and/or the Online Service. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us via the Support Services. We will delete such information from our files within a reasonable time.


10. Security

10.1 We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and encrypted using Transport Layer Security (TSL) and Secure Sockets Layer (SSL).
10.2 Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


11. ADVERTISEMENTS AND AD SERVING TECHNOLOGY

11.1 Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not Milestone. Examples of third party providers we may use from time to time are:


11.2 If you are using an iOS device, you can find more information about how to opt out of personalised adverts by visiting https://support.apple.com/it-it/HT202074.
11.3 Third party ad providers may use precise methods to collect information as a result of ad serving through our Games and/or the Online Service. These entities may collect and use data for this purpose including software, applications, hardware, browser information, internet and on-line usage information and in-game information. This data may be used and disclosed in accordance with these Terms and this Privacy Policy of the company providing the ad serving technologies. You recognize and accept that the advertising companies who deliver ads for us may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. Although we take commercially reasonable steps to instruct such advertising companies to comply with these terms and conditions, we do not have access to or control of third party technologies.


12. INTERNATIONAL DATA TRANSFERS

12.1 Information that we collect from you will be stored outside the European Economic Area (“EEA”) on a secured server in North Carolina, USA in the first instance.
12.2 As of the date of this Privacy Policy, the servers are owned and operated by Amazon Web Services (“AWS”). AWS has obtained approval EU data protection authorities to enable the transfer of data outside the EEA using EU-approved Data Processing Addendum and Model Clauses under which AWS commits to provide adequate protection to personal data of EEA citizens that processed and storeed on AWS servers. Milestone has entered into the EU-approved Data Processing Addendum and Model Clauses with AWS to ensure such protection.


CONTACT INFORMATION

All questions, comments or enquiries should be directed to Milestone using the Support Services link http://milestone.it/supporto/?lang=en. We will endeavour to respond to any query or questions within two business days.
Milestone’s DPO/RPD can be contacted by our Support Service at http://milestone.it/supporto_form/, that will analyze all the inquiries and will provide feedback, also through the Officer, within the provisions in the existing European Community legislation on personal data protection, Regulations UE 679/2016.