INTRODUCTION 


PRIVACY POLICY 
Wildboy Studios Limited (we, us, our) complies with the New Zealand Privacy Act 1993 and the General Data Protection Regulation of the European Union (GDPR) when dealing with personal information. 
Personal information is information about an identifiable individual (a natural person), and includes personal information, personally identifiable information and equivalent information under applicable privacy and data protection laws. 
This policy does not limit or exclude any of your rights under the New Zealand Privacy Act 1993 or the GDPR. For further information on the New Zealand Privacy Act 1993, see www.privacy.org.nz. For further information on the GDPR, see https://ec.europa.eu/info/law/law-topic/data-protection_en
You have the right to object to the processing of your personal information in certain circumstances. Information on your right to object, and your other rights, is set out below. 


WHEN DOES THIS PRIVACY POLICY APPLY 
This Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf when you access ATONE: Heart of The Elder Tree (our Game) on Apple Arcade. 
If you visit our website, or engage with us in any way other than in connection with your use of our Game our standard privacy policy applies which can be found at www.atonethegame.com
To the extent that any personal information is collected by us and where we decide the purpose and means for which personal information you supply through our Game is processed, we are the “controller” for the purposes of 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 

        ▲  your choices and rights regarding the personal information we hold about you. This Privacy Policy should be read in conjunction with the Apple Arcade’s terms of use. 

 
CHANGES TO THIS POLICY 

We may make changes to this Privacy Policy in the future, which will be made available to you 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 our Game. 
This policy was last updated on 19th September 2019. 


INFORMATION WE COLLECT ABOUT YOU AND WHY 
In order to provide our Game to you the following information is collected and processed when you use our Game. 
When you use our Game (Game Information): 
We do not collect your personal information through our Game. We do not collect, transmit, store or have access to any personal information that is stored with Apple Services. 
Our Game collects non-identifiable information about your use of our Game such as: 
        ▲  your Apple Game Center ID: we use a one-way hash of your device name to uniquely associate save data with your device and, if you are logged in to identify you as a player, a unique ID from Apple Game Center. These are both stored within the filenames of your save data on your local device and, if you have iCloud syncing enabled, the filenames are also used to identify your save data within iCloud. to store save data to your iCloud. 

        ▲  Game session information: Game event related information, e.g. your completion of a Game milestone and your in-game progression, if you are signed into Apple Game Center on your Apple device 

        ▲  Game crash data: if you experience a Game crash or bug the relevant Game data will be collected by Apple and provided to us for the purpose of fixing the crash or bug. 
Any personal information relating to your Game Information is stored solely on Apple’s services, e.g. iCloud for game saves, Apple Game Center for Game achievements and Apple support tools for game crash issues (together Apple Services). We do not collect, transmit or store your personal information on our servers. 
Customer Support: 
If you contact us by email for support in relation to our Game, we only collect the personal information that you provide to us (e.g. your name, contact details and device details). This personal information is not combined with any Game Information you provide. 
For the above stated purposes on which we collect and use the information from you, we rely upon the legal basis of: 

        ▲  performance of a contract (being performance of the terms of use agreed between us) 

        ▲  our legitimate interests (being our commercial interests in providing quality services and 
functionality to you including identifying and correcting any bugs or problems with our Game). 


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


Customer Support: If you contact us directly outside of our Game, we will only disclose your information: 

        ▲  in order to comply with legal requirements such as regulatory bodies, law enforcement agencies and in connection with legal proceedings 

        ▲  in order to protect our rights, property or safety and of our customers or others 

        ▲  as specifically authorised by you. 


YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Our Game is hosted, stored and accessed through Apple Services. We do not access personal information in your Apple Services account, and we do not collect personal information from you, unless you contact us directly. 
You can decline to send your Game Information to Apple for the purposes of recording Game Center achievements and syncing save data with your iCloud account, or withdraw your permission at any time, by not logging into those Apple Services. 
If you decline to permit us to send your Game Information to Apple, your Game Center achievements will not be recorded, and you will not be able to sync your save data for our Games with your iCloud account. You will still be able to access our Game and your save data will only be stored locally on your Apple device. 
For any further queries in relation to your Game Information, please contact Apple for support. 
If we hold your personal information outside of Apple Services (e.g. if you contact us directly), you have the following rights over the way we process personal information relating to you: 

        ▲  to ask for a copy of personal information we are processing about you and have inaccuracies corrected or request erasure 

        ▲  to object to us processing personal information about you 

        ▲  to obtain a machine-readable copy of your personal information, which you can use with another service provider (if technically feasible) 

        ▲  to submit a complaint to your local data protection supervisory authority.
Contact us at support@wildboystudios.com. We aim to comply with requests without undue delay and 
within one month at the latest. 


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 necessary following the deletion of your Game profile or another similar form of cessation of your use of our Game. 


CHILDREN

Our Game collects, uses, and discloses information from children in the same way as for other users, as described in this policy. Our Game’s use of this information is limited to support internal operations of our Game. In accordance with our policy above, we do not collect, use, disclose or retain the personal information of children under the age of 13. 
In the unlikely event we have inadvertently collect a child’s personal information, upon notice we will take reasonable measures to promptly delete such information. 


SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the information transmitted, stored or otherwise processed by us. 


INTERNATIONAL DATA TRANSFERS 

The information 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 including Apple. Please contact Apple or refer to Apple’s privacy policy for more information. 
Any personal information you provide to us outside our Game is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and we rely on this decision in transferring personal information to New Zealand. 
For further information, please contact at support@wildboystudios.com. 


CONTACT INFORMATION 
All questions, comments or enquiries should be directed to support@wildboystudios.com. We will endeavour to respond to any query or questions within a reasonable amount of time.