Last updated: July 29, 2019
- Onebutton Games Ltd is the data controller of data processed through your use of its services.
- The type and nature of the data includes profile and contact details, data relating to your use of the services including game stats, posts, log in, traffic data, data relating to the device you use to access the services.
- We use your data to provide and personalise the services, respond to queries and monitor use of our services.
- We may send you marketing materials relating to other services we think may be of interest to you which you can opt out of at any time. We don’t give or sell your data to third parties for them to market to you.
- We may send you push notifications. You will be given an option to allow such notifications or not via your device or the website you are using. You can always use your device or browser settings to control these notifications.
- You have various rights in respect of our use of your personal information as set out in ‘How do I erase or restrict or update my data?’ and ‘How do I get a copy of my data?’. Two of the key rights are that you may:
- ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose; and
- ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.
- Who we are
- Third party sites
- What data does Onebutton Games collect from you?
- What does Onebutton Games do with this data and what is our legal basis for processing this data?
- Does Onebutton Games send marketing communications and how can I opt out?
- What does Onebutton Games do to protect data?
- How long does Onebutton Games keep hold of data?
- What data is shared with or accessed by third parties?
- Third party advertising companies
- Will data be transferred overseas?
- Children’s privacy
- How do I erase or restrict or update my data?
- How do I get a copy of my data?
- How can I contact Onebutton Games?
- What can I do if I have a complaint?
Who we are
- our main website (“websites”);
- any of our mobile applications (“apps”); and
Third party sites
Please note that the Services may contain or incorporate links to websites or other services owned and operated by third parties. We do not endorse any such third-party services. We are not responsible or liable for anything that happens to you when you visit or use these services. Onebutton Games strongly recommends that you review the privacy policies and cookie usage of these third parties.
What data does Onebutton Games collect from you?
We will usually collect and store the following data about you when you access and use our Services:
Data you give us directly:
- if you register an account with us directly on our Services, we will collect the data that you provide to us on registration such as your date of birth, location, username, avatar, password and email address;
- if you enter into any competitions or complete any surveys on our apps or websites, or when using any of our Services, we will collect and store the data you submit to us, including your name and contact details as well as information on your game scores and ranking in any competition;
- when you complete any in-app or in-game purchases, such as buying in-game currency and other items, we will collect data relating to your purchase history;
- when you participate in any Onebutton Games chat or forum services on our Services, we will collect your username, email address and any data that you share within your messages posted to that chat or forum; and
- we will also collect information you provide to us if you raise a complaint, ask for technical support or report a problem with any of our Services, including when you contribute to or post on our Community pages.
Data we may collect when you use our Services (whether or not you register with us):
- data about your location, device type and model, operating system and version and platform, and any apps you are using in conjunction with our Services;
- data about your device’s browser version, page loading time, mobile phone network and operator, generated device identifier information, referral source and IP address;
- data generated when you play our games, such as the game version you are playing, your high score, log-in method, VIP level and rankings;
- attribution data (engagement with advertising on third party websites and in-app event data) and advertising ID, for user acquisition campaigns and monitoring the success of the same;
- data relating to your game play history on our Services, including any purchases made;
- the number of times you visit or use any of our Services and the amount of time you spend using the Services; and
- where you are accessing our Services through a third-party account such as Facebook or Google, we will collect certain information relating to your account with those third parties including your name, user ID, location (country and/or city specific), email address, date of birth, information from your public profile including friends and connections, log in details, avatar and other information based on your use of our Services. You can manage the data which is shared by such third parties with us by amending your preferences using the privacy settings which these third parties provide on their platforms. We will sometimes use third party advertising companies to help us collect this data. Further information is provided below in the section titled ‘Third party advertising companies’ .
What does Onebutton Games do with this data and what is our legal basis for processing this data?
Use of data which is necessary to perform a contract
We collect, store and use certain data as it is necessary in order for us to provide you with access to our Services under the relevant terms and conditions of those Services. This includes:
- providing you with a consistent and personalised Service across different devices and platforms and parts of our Services, for example, ensuring that your progress is saved across devices and displaying your image to your social media contacts (for example, Facebook friends that also use our Services);
- to restrict customers from attempting to use our Services from a restricted territory or who are under-age and attempting to access inappropriate content in breach of our terms and conditions;
- to ensure that you are complying with our terms and conditions when you use our Services and taking any necessary action if you are not complying with our terms and conditions;
- to moderate any chat messages in chat forums, in order to restrict access to harmful, infringing or illegal content; and
- to process any refunds requested by you.
This applies to the following data:
- your username and password in order to allow you to log-in to your account for any of our Services from any device;
- your contact details so that we can contact you with material variations to the legal terms relating to the Services you have asked us to supply (in accordance with our terms and conditions);
- your contact details to communicate with you in relation to any competition that you have entered through our Services (in accordance with the relevant competition terms and conditions); and
- your name and contact details along with details of your device operating system, browser version and IP address, in order to offer you technical support or respond to service questions that you raise.
Use of data which is necessary for our legitimate interests
Sometimes, our use of your data is for purposes which are ancillary to the provision of the Services, which are desirable in order to make them operate more effectively or which are vital to the viability of particular Services. In those circumstances, we believe we have a legitimate interest in handling your data, and do not believe that this storage and use of your data will be of particular concern to you. We use your data for our legitimate interests in the following ways:
- to detect and prevent fraud, hacking and/or cheating;
- to keep our Services secure;
- to customise the Services which are available to you;
- to improve the Services, for analysis and reporting purposes (this also includes using data to log any crashes in our provision of the Services, so we may report such interruptions (in this regard, we may use a third party to assist us));
- to track your use of our Services across our different games and platforms in order to provide you with a seamless experience;
- to connect social media accounts which you have actively linked with our Services (such as Facebook or Google+);
- to understand your preferences and personalise your experience of our Services;
- to send you push notifications with service-related information for certain Services (which you can choose not to accept or turn off by visiting the settings section of your device and selecting the appropriate setting);
- to communicate to you details of our events, promotions or updates that you may be interested in, both within a game and via user acquisition campaigns on third party applications;
- to help us manage and provide you with advertising, as further described in the ‘Third Party Advertising’ section below;
- to serve you with targeted advertising on our websites in certain circumstances so that the advertisements you see are more relevant to you;
- to record your preferences in relation to advertising and marketing communications; and
- to provide you with any customer support you have requested.
Data we use with your consent
We collect, store and use your email address, if you have provided your consent, in order to send to you promotional offers and provide marketing for Services that we believe may be of interest to you (see below for details of our marketing communications). We also use your data to offer you other Services which we think may be of interest to you by email where you have given your consent. You can withdraw your consent for these email communications at any time by clicking the “Unsubscribe” button at the bottom of our emails. On our apps, some of the third party advertising companies that we work with also collect, use and store data about you with your consent when you access and use our Services in order to provide you with targeted advertising. You can withdraw your consent for targeted advertising on our apps at any point using the privacy settings available on our apps. (On our websites, you can choose to disable targeted advertising at any point using your privacy settings on our websites. Note however that we will still serve you advertising when you visit or use our websites but this will no longer be tailored to you or your preferences). For more details on our relationship with third party advertising companies, please see the section below titled ‘Third party advertising companies’.
We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
Does Onebutton Games send marketing communications and how can I opt out?
If you have provided your consent, we may send you marketing communications in relation to our other Services that we think may be of interest to you via email. These messages will only ever be in relation to the named other similar Services of Onebutton Games that you have provided your consent to receive. We do not provide your data to third parties so that they can send you direct marketing communications via email or push notification without first obtaining your consent. Please also see the section below regarding third party advertising for more information about advertising activities on our Services involving third parties.
You can opt-out of receiving any direct marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you by using the unsubscribe mechanism in those marketing emails, or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting.
What does Onebutton Games do to protect data?
We have implemented appropriate physical, electronic and managerial security procedures to safeguard the data we process from loss, misuse, and alteration and to help prevent unauthorised access, maintain data security and to ensure that we correctly use the data we hold in accordance with the purposes for which we collected that data.
We use industry-standard practices such as encryption, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address and password will be encrypted which will make it very difficult for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our Services. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.
Whilst we will do our best to protect your data, the transmission of information by you to us over the internet is not completely secure and we cannot guarantee the security of data during its transfer over the Internet to us. Any such transmission is at your own risk. Once we have received your data, we will use the procedures and security features outlined in this section to try to prevent any unauthorised access.
How long does Onebutton Games keep hold of data?
We will keep data only for as long as it is relevant and useful for the purpose for which it was originally collected and otherwise where required by law. This means that we will only retain your data for the minimum reasonable time period to allow us to provide our Services to you. If you decide to delete an account you have with us, certain data does stay on our Onebutton Games system for administrative purposes and to defend or bring any legal action. Please contact us via our support page for information regarding retention periods.
What data is shared with or accessed by third parties?
Onebutton Games will share your data with various third parties (including our affiliate companies in other countries) as follows:
- We use third parties to help us manage your information and the Services, such as our cloud service provider, customer service and technical support provider, software and game developers, marketing delivery companies and IT maintenance providers. These are companies who are authorised to process data on our behalf only as necessary to provide the relevant services to us and cannot use it for their own independent purposes.
- We share your data with our third party payment providers where you have specifically asked us to complete any in-app or in-game purchases. These third-party payment providers may also ask us to share your data with them to confirm the nature of any payment transaction and to verify your identity and payment details.
- You may create a profile for certain Services which may be visible to other users. Other users can choose to add you as a friend. You can change your settings through the ‘edit profile’ function in our Services at any time.
- We or our third-party partners may disclose your personal data where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party. We may also share your data with third parties to prevent fraud, abusive or unlawful behaviour or to demonstrate our compliance with other terms or laws.
- Onebutton Games may disclose your information to third parties in connection with a purchase, transfer or sale of Onebutton Games.
- Onebutton Games is a member of a group of companies who may process your personal data, which includes Miniclip (UK) Limited (a company registered in England and Wales (registration number 06432709), whose registered office is at Legal Department, Holborn Gate, 326-330 High Holborn, London, United Kingdom, WC1V 7PP), Miniclip Portugal (a company registered in Portugal (registration number 509371388), whose registered office is at Taguspark, Edificio Ciencia II, Av. Prof. Dr. Aníbal Cavaco Silva, Nº 11 - 1C, 2740-120, Oeiras, Portugal) and Miniclip Italia (Testaluna) (a company registered in Italy (registration number MI1754241), whose registered office is at Via Melchiorre Gioia, 8, 20124, Milano (MI), Italy).
We require any third parties processing your data on our behalf to process it in accordance with your rights, our instructions and applicable law.
Third party advertising companies
We want to make sure that the advertising on our Services and marketing is relevant and interesting to you and our other customers. To achieve this, we use third-party advertising and technology companies to serve ads and/or provide aggregated data to assist in serving ads when you visit or use our Services. This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our Services. We also use these companies to automatically collect data from you when you use our Services in order to help us identify the ads that are served to you and what you do after seeing those ads. In addition, we share data with providers of web analytics tools, such as Google Analytics, which we use to analyse your use of the Services.
These third party advertising companies collect, store and use data by integrating cookies, tracking code and other software in our Services. The relevant data collected by these third parties will vary but may include your unique device ID, geo-location details, advertising ID, IP address, information on your interaction with advertising, browsing history and other technical information. Data which you provide to Onebutton Games when using our Services may also be captured by these third parties. On our apps, these third party advertising companies will collect and use your data to provide you with targeted advertising that is relevant to you and your preferences with your consent. You can control and withdraw your consent at any time by visiting the game settings page of our apps. If you do not provide or withdraw your consent to receive targeted advertising on our apps, or if we know you are under the age of 16, then we will still serve you advertising when you visit or use our Services but this will no longer be tailored to you or your preferences.
On our websites, we rely on our legitimate interests to allow third party advertising companies to collect and use your data to provide you with targeted advertising that is relevant to you and your preferences. Nonetheless, you can still control and disable such targeted advertising by visiting the settings page of our websites. If you disable targeted advertising on our websites, or if we know you are under the age of 16, then we will still serve you advertising when you visit or use our Services but this will no longer be tailored to you or your preferences.
In some cases the third parties advertising companies that we work with will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
Advertising our products on third party websites and mobile
We will also share your data with social media or other similar platforms, so that you and other people can see relevant content on that platform. For example, we may use the Facebook Custom Audiences service and share your Facebook ID or advertising ID in a protected format with Facebook so that we can: include you in a custom audience that we will serve relevant advertising content to on Facebook; or create an audience of other Facebook users based on the information in your Facebook profile. You can opt-out from Facebook Custom Audiences in your Facebook privacy settings.
We will also share your data with user acquistion partners, via our third party mobile measurement service provider, for the purpose of telling you via third party applications about our new products, promotions and features that maybe of interest to you. We will also work with these partners to monitor the success of such campaigns. You can object to such use in accordance with the “How do I erase or restrict or update my data?” below.
Will data be transferred overseas?
Most of our Services are not specifically targeted at children. Where the Services are being used by children under the age of 16, we recommend parents and guardians regularly clear their browser cache and/or browsing history to clear cookies. Please see our Cookies Policy for more information.
For some Services however it may be possible for those under the age of 16 to register an account and access games and other content (with parental or guardian consent). Where children under 16 sign up and use our Services, their account is limited to those aspects of the Services which we deem appropriate for children.
If you are under 16 and have signed up to use any of our Services, we will only collect and process the following limited data about you:
- your date of birth and email address. We collect, use and store this data as it is necessary in order to allow you to log-in and use the Services you have registered for. We need to use your date of birth to make sure that users are not attempting to access Services which we deem inappropriate; and
- data which is necessary to respond to a question or one-off request for customer service support from you. We believe we have a legitimate interest in handling your data for this purpose as it allows us to provide you with customer and technical support and a better experience of our Services and the benefits of this outweigh any potential impact on you in storing and using your personal information in this way.
If you are under the age of 16 and in the EEA, your email address is encrypted. This means that your email address will be put into a secret code, so no one can use it, including us.
As your email address is encrypted, we are not able to contact you by email after registration for any purpose, including to send service emails or promotional offers.
If you would like to review or amend your child’s information, ask to have it deleted, and/or refuse to allow any further collection or use of your child’s information, then please contact us via our support page. Please be sure to include your email address and a telephone number where we can reach you. To protect your child’s privacy and security, we will take reasonable steps to help verify your identity before granting you access to the information that we collect and maintain about your child.
How do I erase or restrict or update my data?
If you no longer wish for us to use your data, please get in touch. Please note that this may affect the provision of our Services to you, for example, you may not be able to enter any competitions or make any in game purchases.
You have the right to ask us to amend or update any of your data which is out of date or incorrect or change the way we may use your data.
You also have the right to ask us to delete any personal information which we are holding about you. You can also object to our processing of data about you, and we will consider any valid objections which you raise. In certain circumstances we may not be able to stop using your personal data but, if that is the case, we’ll let you know and tell you why.
If you wish to opt out of receiving any promotional emails or newsletters you can do so by clicking on the “unsubscribe here” link at the bottom of each email. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.
If you have an account with us, in certain games, you can view and edit your profile to change the settings in order to prevent others being able to add you as a friend.
If you wish to exercise any of the above rights, please get in touch with us via our support page.
How do I get a copy of my data?
You have the right to ask us to provide you with copies of personal data that we hold about you at any time. Please contact us via our support page.
How can I contact Onebutton Games?
What can I do if I have a complaint?
If you are not satisfied with the way your query or complaint is handled by Onebutton Games, please let us know via our support page. If you are still unhappy, you may refer your complaint to your local data protection regulator. For example, in the United Kingdom this is the Information Commissioner’s Office.