Privacy and Cookies Policy
TreesPlease Games Privacy and Cookies Policy
Last updated: 9th February 2023
Summary
We are Treesplease Games Ltd, a company incorporated under the laws of England and Wales with company number 12223638 and registered office at Preston Park House, South Road, Brighton, East Sussex, United Kingdom, BN1 6SB ( ‘TreesPlease’, ‘we’ or ‘us’).
This policy describes the ways in which we collect and use personal data about you when you use our website at https://www.treespleasegames.com, when you play our games and you otherwise interact with us, for example, when you contact us with a query or when you engage with us in the course of your employment with one of our service providers or business partners.
Personal data is information from which you can be directly or indirectly identified (for example, name and email address, username and password).
We may change this policy from time to time so please check our website regularly to keep up-to-date with any updates.
This policy was last changed in May 2022.
For the purposes of data protection legislation, we are the controller of personal data we process about you. This means that we are responsible for the security of the personal data and the decisions we make regarding the personal data.
We have registered with the Information Commissioner’s Office (“ICO”) as a controller and our registration number is ZB265376.
1. What personal data do we collect about you?
Playing the game
When you log in to play our game we collect basic account log in information such as your username or information related to your account with Facebook, Apple or Google (such as names and email addresses) received by us when you log-in to our game via Facebook, Apple or Google.
We may attach a unique reference ID to you as a player.
Advertising and marketing strategy
We and third party advertising service providers may collect the following information about you and your device, some of which amounts to personal data about you:
gameplay information: your use of the game, for example, your actions within the game, your progress within the game, your preferences, your in-app purchases and your session time and metrics
third party platform information: your use of third party social media and other online platforms
device identifiers: IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, any user IDs issued by us about you and other similar unique identifiers
device information: this refers to technical information about your mobile device such as: device type and model, CPU, system language, memory, OS version, Wi-Fi status and time stamp zone.
We may also collect personal data used to promote our offerings on third party websites and platforms, for example, information regarding demographics, interests and behaviours.
Social media
We may receive personal data about you such as opinions and comments you make via social media, when you interact with our accounts on social media and other online platforms, for example, when you post something on our LinkedIn page or when you tag us on one of your Facebook posts.
Website and correspondence
We may also collect personal data about your use of the website, your preferences on the website and information about your device when you use our website (please see the section titled Cookies below). We may also receive any data that is included in any correspondence you have with our team or when an individual mentions you in any correspondence they send to us.
2. How do we collect your personal data?
Playing our game
We mostly collect personal data directly from you. We may also receive your personal data via Apple, Google or Facebook when you log-in to our game via Apple, Google or Facebook.
Advertising and marketing strategy
We may also receive information relating to your engagement with our game and your preferences or activities on third party platforms or websites, which might be used as part of our performance marketing strategy from third party marketing partners, such as Facebook.
We engage a number of advertising partners that collect and provide us with a number of device and advertising identifiers and information in the form of aggregated data reports to help us understand how our marketing strategy is performing and to promote our game to you and potential new players. These partners also help us provide tailored marketing to you whilst you are playing the game.
Social media
We may also collect your personal data through social media platforms such as LinkedIn and Facebook when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, and when you provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Facebook.
Correspondence
We may also collect your personal data when you email us or otherwise contact us. We may also receive your personal data through other individuals who may, for example, mention you in any communications they send to us.
Other third parties
We may collect your personal data from any other types of organisations listed in the section titled Sharing your information with third parties below.
3. How do we use your personal data?
In accordance with data protection laws, we will only process your personal data if we have a lawful basis for doing so.
In respect of your personal data, these bases are:
if it is necessary to provide services to you under the performance of a contract we have with you
if we are required to do so in accordance with legal obligations
if you have given your consent
if it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests.
The following is a list of the purposes for which we process your personal data, and the lawful bases on which we carry out such processing.
| Purpose | Lawful Basis |
|---|---|
| To facilitate you logging in and playing our game | Necessary for the performance of a contract |
| Administering a connection between your Apple, Google and Facebook accounts and the game | Necessary for the performance of a contract |
| Displaying in-game profiles or display names | Necessary for the performance of a contract |
| To make event/content related information available to you | Necessary for the performance of a contract |
| To deliver marketing materials to you, including on third party websites and platforms, including personalised advertising to you, when you play our game. This refers to advertising done based on the use of Cookies (please see the Cookies section below). | Consent |
| To engage with players and potential players including providing advertising on third party websites and platforms. This refers to activities that do not involve the use of Cookies implemented by us or Cookies implemented on our behalf. | Legitimate interests of promoting our offerings, including commercial interests in expanding our business |
| To respond to communications, including player support queries | Legitimate interests of handling player communications |
| To record and analyse customer communications for training purposes | Legitimate interests of improving our customer service |
| To send you service messages and updates about our game | Necessary for the performance of a contract |
| To prepare and analyse statistics relating to the use of the game by you and other users, testing, to investigate complaints, to seek and analyse feedback and to further develop the game | Legitimate interests of ensuring the game is as enjoyable as possible |
| To analyse statistics that provide us with an understanding of the level of the success of our marketing campaigns | Legitimate interests of better understanding our marketing campaigns |
| To share anonymised gameplay data with third-party services to analyse and/or publish | Legitimate interests of promoting, expanding and improving our business |
| To run our everyday operations, for example, communications between employees in connection with the provision of our services | Legitimate interests of running our business |
| To administer and protect our business and the website including troubleshooting, data analysis and system testing | Legitimate interests of running our business, provision of administration and IT services, including network security |
| To administer a sale or possible sale of the whole of or part of our business or the restructuring of our business | Necessary for the performance of a contract |
| To consider job applications that we receive | Legitimate interests in choosing appropriate staff for our business |
We may also process your personal data (a) to comply with a legal obligation we are under; and (b) for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.
In certain circumstances, you may be obliged to provide us with your personal data under a statutory or contractual requirement. This might include, but is not limited to, personal data we require to enter into an agreement with you; for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation. Failure to provide us with personal data required under a statutory or contractual requirement may prevent us from entering into or performing our obligations under a contract with you.
4. Sharing your information with third parties
Some of the information TreesPlease collects from you is passed to third parties. These third parties are:
website hosting providers, including Squarespace
technology service providers, including storage providers such as Cockroach Labs, Inc, (CockroachDB) and Google Cloud and log in service providers (Apple, Google and Facebook)
providers of advertising related services, that collect or receive information (including personal data) from your use of our game and other apps and use that information for the following purposes
to provide measurement services to help us understand how well our advertising campaigns are doing
to provide you and individuals like you with targeted ads within our game and on third party apps and online platforms and websites (for example, on Facebook and TikTok)
Some of these providers might be collecting your personal data as controllers (i.e. they decide how it’s collected and how it is handled and therefore they are responsible for their activities involving your personal data – these activities will be covered in their privacy policies, so please read their privacy policies for further information on how your personal data is handled by them in these circumstances). We use the providers listed below – these are the links to their privacy policies: IronSource, AppsFlyer, Facebook, TikTok, Unity Ads, Vungle, Google Ads, Delta DNA
potential purchasers of our business or investors in it (including in the event of insolvency)
in relation to the sale of some or all of TreesPlease’s business, or its assets, or as part of any business restructuring or reorganisation
regulators and law enforcement agencies which may have any reasonable requirement to access your personal data, for example, when we are assisting with any investigations or when we bring a claim or defend ourselves against a claim that requires the disclosure of personal data
external professional advisors who need to access information for the purpose of advising us.
5. Links to third party websites and third party adverts
TreesPlease is not responsible for the privacy policies and practices of other sites even if you access them via our website and/or as part of playing the game. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
6. International Transfers
Some of the parties we share your personal data with might be based abroad. When we transfer personal data outside the UK and EEA we are required to ensure you are afforded equivalent protection in respect of your personal data to that provided in the UK and the EU.
Generally, we will put in place appropriate safeguards when making international transfers, for example, by using specific contractual clauses which have been approved by the European Commission and/or the UK government together with supplementary measures if we deem it necessary in the circumstances, for example, further contractual commitments, enhanced security and assessments of transfer risk.
7. Retention
We retain your data for no longer than is reasonable in line with the purposes for which it was originally collected, including for the purposes of satisfying any contractual requirements or other legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the purposes for which we process the personal data, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.
7. Cookies
What are Cookies? For simplicity, in this policy we use the term Cookies to refer to cookies and other tracking technologies. Cookies are small text files that are placed on your device or browser and read information on your device or browser when you use the website and/or play the game.
Cookies set by us are called ‘first party cookies’. Cookies set by third parties (i.e. domains we do not operate) are called ‘third party cookies’.
Session cookies enable you to move from page to page within our website and/or play our game and any information you enter will be remembered but is deleted when you close the page or session or after a short time. Persistent cookies allow us to remember your preferences and settings when you use our website and/or play the game in the future.
We will obtain your consent for the implementation of any Cookies that are not Necessary Cookies (as described below).
Disabling Cookies:
Website: The use of the Cookies improves the functionality of our website and our game. If you do not want these Cookies to be served on your device, you are able to disable them by changing the settings on the website or on your device. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. You may be able to block cookies from by activating the setting on your browser that allows you to refuse the setting of cookies. Please note that if you do decide to disable cookies you may not be able to access some of the website, and some of the features of the website may not function properly.
Types of Cookies we use:
We currently use the following types of Cookies on our website and game:
Necessary
Those that are necessary for the operation of the website and the game, including allowing you to interact with our website and the game and to recall selections as you move between pages and different parts of the game and which enable core functionality such as security, credentials authentication, network management and accessibility and to determine changes in information you provide to the website and the game.
Website: We only use a crumb cookie on the website which is used to prevent attacks.
Performance (analytics)
Those that analyse the use of and game, for example, to help analyse how players use our game. We use this information to identify trends and improve our game.
Functional
Those that are used to provide certain functionalities within our game and to remember choices you make so we can personalise the content of the game for you.
Advertising (targeting)
Those that are used to deliver advertisements about our game within third party websites and apps [and advertisements about other products and services within our game].
We use Cookies from different advertising service providers, which allow us to track how our advertising campaigns are doing and deliver advertising to you.
More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.
8. Your rights
Exercising your rights: You can contact us using the details set out below if you wish to exercise your data protection rights. We may require you to provide forms of identity should you wish to exercise one of your rights below.
Access: You are entitled to confirmation that we process your personal data and a copy of such personal data.
Rectification: If the personal data we hold about you is incorrect, you have the right for this to be rectified. You may also update your personal data through your account settings.
Erasure: You can request us to erase your personal data if there is no compelling reason to continue processing.
Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below).
Objection: You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.
You may object to receiving direct marketing at any time.
Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.
Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email privacy@treespleasegames.com to withdraw consent for the processing of your personal data.
Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the Information Commissioner’s Office (https://ico.org.uk/). If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.
Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data.
9. Treesplease Details
If at any time you would like to contact TreesPlease about your views on this Policy or any enquiry relating to your personal data, you can do so by sending an e-mail to us at privacy@treespleasegames.com or write to us at Treesplease Games Ltd, Preston Park House, South Road, Brighton, East Sussex, United Kingdom, BN1 6SB. You also have the right to make a complaint to the ICO by contacting them at any time.