Last updated: 13/09/2024

TThis policy applies to personal information held about players and users of our games (including “Whodunit?”), our website(s) and any other related services (the Services).

In this policy, "we," "us," and "our" means MVP Games Ltd, a company registered in England with registered address at 93 St Helens Rd, Prescot, Merseyside, United Kingdom, L34 6HP. 

1. About this Policy

This policy deals with where we are acting as a 'data controller' under the data protection legislation: which essentially means where we are responsible for deciding what personal information we collect and how we use it. When we refer to "personal information" we mean information relating to you personally or from which you can be identified. Some of the information mentioned in this policy is not 'personal information' as is meant under data protection legislation, but we may refer to it to help you understand what we do.

We are committed to protecting and respecting the personal information of everyone we deal with - that is important to us and we know it is important to you.

In this policy you will find information about what types of personal information we hold about you, how and why we collect it, how we use it, and how we keep it secure. You'll also find information about your rights and how you can exercise them.

Please read this policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal information, you can reach us by email at support@mvpgames.co or by post at the address above.

2. What information do we collect about you?

We may collect some information about you to enable you to use our Services, to improve or optimise your gaming experience, to provide player services, to improve the services we provide and for marketing (see below for more details). This may include:

  • Your public user name and any information you expressly provide through any online form or survey we may administer from time to time.

  • Your game profile - including information needed for our games to function, such as in-game progress, achievements and an inventory of any in-game items.

  • Usage and analytics data including information about how you use Services and technical information about the device you are using.

  • Performance and diagnostic data: Includes information such as software errors and load time details, detailed information about crashes or information if the software runs slower than expected

  • Device and location data: Information about your device and network, your general location (i.e., nearest city), type of device; operating system, time zone settings and platform;

  • Marketing and communications data including your preferences in receiving marketing from us and our third parties.

  • Marketing attribution: If you permit marketing tracking on your device, we will be able to better monitor the effectiveness of our marketing campaigns by potentially attributing your installation of the mobile app to any interaction you made with an advertisement outside our Services.

3. How we collect information about you

We will collect this information in a variety of ways depending on how we interact with you.

Direct interactions

You may give us your identity, contact or other information by filling in online forms or by corresponding with us by post, phone, email, social media sites or otherwise. This includes personal data you provide when you:

  • use our products or services;

  • interact with customer services;

  • subscribe to any mailing lists;

  • enter a competition, promotion or survey;

  • register for alpha, beta or other early access to our games;

  • interact with us on social media websites

  • give us feedback; or

  • provide services to us.

Automated technologies or interactions

As you interact with our Services we may automatically collect technical data about your device, and your activity when using the Services.

Platforms

We may receive personal data about you from a third party platform or distributor for example from your account with Steam or other platforms that we release our games on and which you use to play our games.

4. How we use your information

We use different information in different ways:

  • providing and managing our games, any website and its related services;

  • to answer your enquiries or deal with your complaints;

  • account verification and clearance;

  • to help us develop improve the Services;

  • detecting and reporting fraud and other unlawful activity;

  • direct marketing to let you know about products and services that may be of particular interest to you;

  • administering surveys and opinion polls;

  • managing competitions and/or promotions and your registration for the same;

  • managing alpha, beta or early access tests including collecting your feedback; and

  • complying with legal or regulatory requirements.

We do not make any legally significant decisions about individuals based solely on automated decision-making.

5. Legal basis for processing

There are a number of different legal grounds for processing personal information. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that:

  • you have provided your consent to us using your personal information in that way;

  • our use of your personal information is in our legitimate interest as a commercial organisation. However, we will only use personal data relating to players users for the purposes of legitimate interests where players’ interests, and rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with. Our legitimate interests include for the purpose of providing, developing, improving and promoting the Services and our wider business;

  • our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or

  • our use of your personal information is necessary to comply with a relevant legal or regulatory obligation.

6. Sharing your information

The personal information you provide to us may be shared with other players, our staff and the following types of third parties:

  • platforms and distributors of our games such as Apple and Google;

  • service providers such as back-end providers (Firebase and Playfab), crash analytics providers, data analytics providers (Firebase), data storage providers, marketing partners (Facebook), and customer service support partners;

  • our auditors, insurers, lawyers and other professional advisers;

  • law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;

  • any other wholly-owned subsidiary, sister or holding companies in our corporate group; or

  • other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

7. Marketing

If we create a mailing list and you agree to be contacted for marketing purposes, we may use your personal information to send you information about us and our services. You can unsubscribe from receiving them at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of "unsubscribing" from our mailing list at any time thereby disabling any further such e-mail or other marketing communications from being sent to you by emailing support@mvpgames.co.

We will action any opt out request from you as soon as we can.

8. Children

Our Services are not targeted at users under the age of 13.  We do not knowingly collect or use any personal data relating to children under the age of 13.

9. International transfers

We routinely transfer personal data outside the UK. Where we transfer personal data outside the UK to a country that has not been recognised as providing an adequate level of data protection we use the standard contractual clauses unless we have identified another appropriate safeguard or relevant exemption.

10. How long will we keep your information?

We keep personal data relating to players for such reasonable period as necessary to provide the relevant Services and in compliance with applicable law and regulation.

In some circumstances you can ask us to delete your data: see "Your Rights" below for further information.

Sometimes we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.

11. Your Rights

Everyone has the right to:

  • Information about how we use personal data (which is what this notice is for)

  • Access to personal data

  • Object to the use or disclosure of personal data for certain purposes

  • Erasure of personal data

  • Portability of personal data

  • Withdraw consent where our use of personal data is based on consent

  • Rectification of personal data

  • Restriction of personal data

  • Complain to your supervisory authority

Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant.

You will not be treated differently or discriminated against for exercising any of your rights.

12. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.

13. Terms of Use

You should read the Terms of Use in conjunction with this Privacy Policy.  The Terms of Use set out certain important clauses relating to disputes, limitations of liability and forum of resolution.

14. Changes to this Policy

We may need to amend this policy from time to time, for example, in order to ensure that we remain compliant with applicable law or to reflect any changes we make to the Services.

Your continued use of the Services after any changes to the policy have been made by us will mean that you accept those changes. If you do not agree to any changes to the policy, you may not continue to use the Services.

Any changes to this policy will not affect your accrued rights and will not have any retrospective effect.

15. Contact

If you wish to contact us, please email support@mvpgames.co.