Disney Spell Struck Privacy Policy

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Effective date: May 1, 2023

Artist Arcade Inc (“Artist Arcade” “we” or “us”) has developed and operates the “Disney SpellStruck” iOS game (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of Personal Data when you use our Service and the choices you have associated with that data.

1. Definitions

Personal Data: Personal Data means data that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household including a player’s persistent identifiers in connection with Apple services such as iCloud and Game Center.

Usage Data: Usage Data is data collected automatically and either generated by the use of the Service or from the Service infrastructure itself (for example, the current level passed in the game to send an achievement to Game Center).

Aggregated Data: Aggregated Data means Personal Data and/or Usage Data that has been aggregated and anonymized.

2. Data Collection and Use.

Personal Data:
We will use Personal Data to operate and provide the Service. We will utilize a player’s persistent identifiers for use with Apple services, such as iCloud, Apple Arcade and Game Center. This includes the scoped teamPlayerID associated with the player's Game Center account when logged in. These are stored by, and/or serviced by Apple, and in which case Apple’s privacy policy and associated agreements shall govern the storage, use and dissemination of such data.

We may also generate a Universally Unique ID (UUID) associated with a player’s device to allow for saving progress across multiple devices on iCloud.

We will temporarily collect your Personal Data in connection with opening and servicing one or more service tickets through our helpdesk platform.

Usage Data:
We may collect Usage Data for the purposes of saving progress within the Service, and any additional Usage Data, including, current level reached, items collected within the game, and any customizations or upgrades applied by the player, will be collected in support of that saving functionality.

We may also collect Personal Data and Usage Date for the purpose of playing against other players online, we may temporarily collect the following information:

A player’s persistent identifiers will only be used in connection with Apple services for saving progress in the game and associating it with specific Game Center accounts, which are then stored on iCloud. A player’s scoped teamPlayerID from Game Center will be used for associating a save game to a specific Game Center account, and a Universally Unique ID (UUID) which the Service generates will be used to help identify save data between different devices connected to your iCloud account. From time to time, achievements will be sent to Game Center if the user is logged in.

Some Player data will be used to facilitate online multiplayer matches but will not be used beyond that.

Anonymous Data:

We will use Aggregated Data for analytical and Service improvement purposes.

3. Data Retention.

Usage Data stored for the purposes of saving progress will not be used for any purpose other than the saved progress. Any Usage Data collected to support online play will be discarded once the matches have ended.

We do not intend to retain any Personal Data beyond the time period necessary to service a helpdesk ticket or provide the in-Service functionality available through Apple services.

For online multiplayer within the service, all data collected will be used only for the time necessary to facilitate an online match. Once the match has ended, data will be discarded.

4. Data Sharing.

Apple. We may share your data, including Personal Data, with Apple as they provide services such as Game Center, Apple Arcade and iCloud. Apple may use that data for accessing player IDs and saving game data between multiple devices, when necessary. Apple’s privacy policy and associated agreements shall govern the storage, use and dissemination of any such data.

Heroku. We may share your data, including Personal Data, with Heroku to support online multiplayer setup and matchmaking. Heroku tracks only your IP address and helps transfer data between players while beginning and ending online matches. Heroku's privacy policy shall govern the storage, use and dissemination of any such data. Note that Heroku does not save your IP address beyond what is needed to maintain an active connection. Heroku also does not share the IP address with the Service, nor do we have any correlating data about you that would allow us to use it to obtain any Personally Identifiable Information.

Service Providers. We use third-party services to help support our Service. We don’t share Personal Data or Usage Data with them beyond what is necessary to allow the Service to function. For instance, we may, from time to time, share Personal Data with our helpdesk vendor to service open support tickets.

Licensors. Licensors which provide rights to use certain intellectual property contained in the Service may, if requested, be provided with Aggregated Data.

Affiliates. We may share Personal Data, Usage Data and Anonymous Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (collectively “Affiliates”). Current Affiliates include Wordplay Games LLC and Fun and Games.

Corporate Restructuring. We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

To Protect Us or Others. We may access, preserve, and disclose information associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

5. Your Rights.

If you wish to exercise any of these rights, please contact us at support@artistarcade.com. In your request, please make clear: (i) what Personal Data is concerned; and (ii) which of the above rights you would like to enforce.

For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will comply with your request as soon as reasonably practicable and in any event within one month. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Please be advised that declining to provide your Personal Data or withdrawing your Personal Data once provided may limit the functionality of the Service such as your ability to obtain support from our helpdesk or utilize online functionality of the Service.

You may also decline to store data in iCloud or to send data to Game Center, which is handled by Apple. To turn off iCloud data storage, you must turn off iCloud in Apple Settings for our game. As a result, you will only be able to play in offline mode. To stop sending data to Game Center, you must sign out of Game Center in Apple Settings. As a result, achievements will not be saved.

When optionally connected to iCloud or Game Center, a player’s persistent identifiers may be used only in connection with Apple services and for no other purpose, and players may decline to use these services for those purposes. See “Declining or withdrawing permission for data” for more information.

6. European Data Protection Rights

If you are an individual in the EEA, we collect and process information about you only where we have legal bases for doing so under applicable laws, including:

Please refer to the Your Rights section (Section 5) of this privacy policy regarding the rights you have with respect to the processing of your Personal Data.

To make such requests contact us at support@artistarcade.com. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We may rely on different lawful bases for collecting and processing Personal Data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

7. International Transfer

Your information, including Personal Data that we collect from you, may be transferred to, stored at and processed by us and our third-party providers, as applicable, outside the country in which you reside, including the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.

Where Personal Data originating in the UK, EEA or Switzerland is transferred to external processors, we make use of a variety of legal mechanisms to safeguard the transfer, as well as additional safeguards where appropriate.

As we operate in the United States and use technical infrastructure in the United States to deliver the Service to you, we need to transfer your personal information to the United States and to other jurisdictions as necessary to provide the Service.  Simply put, we cannot provide you with the Service without moving your Personal Data around the world.

8. California Privacy Rights.

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”) as well as the California Consumer Privacy Rights Act (“CPRA” and collectively with the CCPA, the “California Acts”) you have certain rights with respect to that information. In particular, you have a right to request that we provide you with the following information:

To submit such requests, contact us at support@artistarcade.com or the other contact information set out below. You also have a right to request that we delete personal information under certain circumstances, subject to several exceptions.

You have a right to access information about as well as opt out of the automated processing of your Personal Data.

Finally, you have a right not to be discriminated or retaliated against for exercising rights set out in the California Acts.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us at support@artistarcade.com.

9. Children.

We do not intentionally gather Personal Information from visitors who are under the age of 13.To the extent that we utilize Personal Data of a player under the age of 13 for a purpose set forth in Section 2, such use shall constitute a “legitimate interest” under the General Data Protection Regulation 2016/679 of the European Union and shall be designed “to support internal operations of the game” under the United States Children's Online Privacy Protection Act of 1998 (15 U.S.C. §§ 6501–6506). If you believe that we might have any Personal Data from a child under 13, or a parent or guardian becomes aware that his or her child under the age of 13 has provided us with information without his or her consent, please contact us at support@artistarcade.com, and we will delete such information from our files as soon as reasonably practicable.

10. Security.

We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, transmission of information via the internet is not completely secure, nor can we guarantee the security of any transmission or storage system. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us as set forth below.

11. Contact Information.

Our data protection officer can be reached at support@artistarcade.com. You may email the data protection officer with questions about this privacy policy, our data processing practices, and to exercise data subject rights, if applicable.

12. Policy Updates

This privacy policy may change from time to time. We will always keep this privacy policy up to date so that you know information we will collect from you, how we may use it, and when we may disclose it.