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Hatch Privacy Policy

HATCH PRIVACY POLICY

Effective Date: 24 of May 2019

Thank you for using HATCH! This privacy policy is to let you know what data we collect in our application, website, and related services (together “Service”) of you, why we do so, and how you can affect such data collection. We might update this Privacy Policy once in a while, but we will inform you in advance of any material changes thereto. Please note that any use of the Service after such changes is subject to the new Privacy Policy.

CONTACT US.

If you have any questions concerning this Privacy Policy or our collection or processing of your personal data, please contact us at privacy@hatch.live.

Controller name: Hatch Entertainment Ltd.

Address: Keilaranta 19, 02150 Espoo, Finland

WHAT PERSONAL DATA WE COLLECT.

 Personal data that you provide us:

  • Contact Data including phone number and email address.
  • Identity Data including name and a profile picture.

Personal data which is collected automatically:

  • Information about your visit including data about your use of the Service (such as interactions with the Service and other users in the Service) and your game progress.
  • Technical information including your IP address and device identifiers (e.g. device ID, advertising ID, IMEI), general location data (country and city level), device type and network connection type and device related data (such as resettable device ID, device name, operating system, language).

Personal data we get from our partners:

  • Demographic data.
  • Data for advertising and analytics purposes, so we can provide you a better Service.

WHY WE COLLECT YOUR PERSONAL DATA.

We will only use your personal data when the applicable law allows us to. Most commonly, we will use your personal data in the following circumstances:

Contract.

In order for us to fulfil our contractual obligation of providing you the Service – create an account for you, enable you to play the games in the Service, operate the Service, and to notify you of issues and news concerning the Service – we need personal data from you.

Legitimate Interest.

In order to provide you with the best possible user experience and enjoyment of the Service, we have a legitimate interest to collect and/or process personal data for the following purposes:

  • Update and develop the Service.
  • Communicate with you through the Service, by email, and by SMS – including support, Service and news notifications, and relationship management.
  • Give you the opportunity to be social (e.g. chat, comments, social media, game sharing) in our Service. 
  • Provide you with the best user experience based on your personal preferences.
  • To give you personalised game recommendations based on your actions within the Service as well as the data you have provided us.
  • To send you personalised advertisements based on the personal data you provide us or our partners.
  • To analyse, profile and segment the collected data.
  • To keep the Service safe and fair by monitoring and moderating (manually or automatically) its use and the social features therein, and should the need be take actions against misbehaving players.

Consent.

Should we wish to process your personal data for any other purpose where we are not able to rely on another legal basis for processing under applicable laws, we will ask you for consent.

Please note that we may process your personal data using more than one lawful ground depending on the specific purpose for which we are using your personal data.  Please contact us using the details set out in the “Contact Us” section set out at the beginning of this Privacy Policy, if you need details about the specific legal ground we are relying on to process your personal data on any given occasion.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by applicable legal requirements including the General Data Protection Regulation (the “GDPR”).

COOKIE TIME!

As just about all online services, we as well together with our partners, use cookies and similar technologies (such as Software Development Kits) as a way to either collect the aforementioned personal data to provide you the Service, to do the processing actions listed above, or to combat fraud and abuse, frequency capping, and aggregated advertisement reporting. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Service.

We may employ cookies and related technologies described below for a variety of purposes, including:

  • To learn more about how our products and Service are used and similar analytical purposes;
  • To understand how users interact with our ads;
  • To understand how to improve performance;
  • To prevent fraud;
  • To customize our products and Service with more relevant content; and
  • To provide you with more relevant advertising.

As described below, we employ a number of technologies to provide and improve the Service. When you use the Service, you consent to our use of these technologies, but you are welcome to exercise the choices described below.

  • Browser cookies: we use browser cookies on our website. Most major browser companies offer tools or settings for users who do not want cookies set or read on their devices. Please visit your browser’s settings or privacy settings pages.
  • Local shared objects: we may use local shared objects (also known as Flash cookies) on its sites. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the Adobe Flash Player website and make changes at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
  • Beacons, pixel tags, clear GIFs: we and our service providers or third parties advertising within the Service may use these technologies to learn the online behavior and interests of users and to personalize ads that users see. To learn more about behavioral advertising, please visit the Network Advertising Initiative’s (NAI) website.
  • Device IDs and digital fingerprinting: The Service may use one or more of a variety of unique identifiers to recognize users and their devices, including MAC address, IDFA, Android Ad ID, and digital fingerprint, which may be comprised of several types of data, including device name, the app list or applications installed on the device, and browser characteristics.

NOTE: we may also generate and assign a user ID when you access or use our Service.

VISIBILITY OF YOUR PERSONAL DATA TO OTHERS.

Socialising.

If you decide to be social in the Service and send messages to others (text or video) or share your gaming success, other players will be able to see the aforementioned, as well as your profile data. Other players can also find you in the Service, if they have your phone number.

We will only share your personal data with third parties when the applicable law allows us to. Most commonly, we will share your personal data in the following circumstances:

Hatch Processor Partners.

In order to get you the best possible Service, we need some help from others. We have partners providing their expertise to us, and for that purpose they collect and/or process your personal data (e.g. hosting, advertising, and analytics) according to our specific instructions and control.

“Big brother”. 

We may disclose your personal data to a competent law enforcement body, regulatory, government agency, court or other third party, if we find it is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Hatch Controller Partners.

In addition to our Hatch Processor Partners, we also have Hatch Controller Partners, who provide features through our Service. Such partners may be, for example, social media tool or advertisement providers, and they collect and process your personal data separately from us under their own privacy policies. Please go check their privacy policies, as listed below:

Google Double Click and AdX/DFP               https://policies.google.com/privacy

Facebook Ads                                                 https://www.facebook.com/about/privacy

 

DATA TRAVELS.

As we hope everyone around the world can have access to our Service, it is created global. Therefore your personal data can be transferred to any location in the world. That being said, we truly respect your privacy, and hence have all required safeguards in place to protect your data accordingly with this Privacy Policy. Where required by applicable law, we will only transfer your personal data to countries outside of the European Economic Area where we have put in place adequate safeguards to protect your personal data. Standard contractual clauses approved by the EU Commission and the US Privacy Shield certification are generally considered as adequate safeguards to protect personal data in international transfers.

Please contact us using the details set out in the “Contact Us” section at the beginning of the Privacy Policy if you want further information about the specific mechanisms we use when transferring your personal data outside of the European Economic Area in a given circumstance, and to request a copy of them.

YOU HAVE RIGHTS!

Opt-out or withdraw consent.

In the Hatch application you are able to modify your preferences concerning in-app push notifications (including marketing messages) by going to Settings and Notifications. 

For our Hatch Controller Partners, please see their respective privacy policies to opt-out or withdraw your consent to the processing of your personal data.

You can opt-out of interest-based advertising on mobile applications by checking under your phone Settings and the Google settings of your Android device and selecting the opt-out option for interest based or personalized, or similar, ads. Please note that the opt-out does not mean you will no longer receive ads, it only means the ads you do see will be less relevant to your interests.

In addition, where you have provided (and we have relied upon) your consent to process your personal data, you may withdraw your consent, at any time by contacting us using the details set out in the “Contact Us” section set out at the beginning of this Privacy Policy and where no other legal basis exist upon which we can process your data we will apply your preferences going forward. However this will not affect the lawfulness of any processing carried out before you withdrew your consent.  If you withdraw your consent, we may not be able to provide certain Services to you.  We will advise you if this is the case at the time you withdraw your consent. 

See your information.

By sending us an email request at privacy@hatch.live we will send you a copy of the personal data we hold about you.

Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data.

Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms or where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restrict your information.

By selecting to use the Service anonymously, you can restrict the personal data we process of you. You can use the Service anonymously by not registering or signing in. Please, however, note that by playing anonymously you do not get all the features and benefits of the Service.

Right to modify.

By law you have the right to correct and delete your personal data, as well as to object to our use of your data. Any consent that you might have provided can be withdrawn at any moment. You can delete all the personal data that we have collected of you through the Hatch application by opening the application menu, and by going to Settings and Delete profile. This will erase all your personal data collected through the application, thereby also anonymising all analytics data based on such personal data.

Right to request the transfer of your personal data to you or to a third party.

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to complain.

If you feel that your privacy or a personal data concern has not been satisfactorily addressed by us, you may contact your local data protection authority within the European Economic Area to complain.

To exercise certain rights we may ask you to confirm your identity and where applicable, to help us to search for your personal data.  Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

If you wish to exercise any of the rights set out above, please contact us using the details set out in the “Contact Us” section set out at the beginning of this Privacy Policy.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Additional Choices for California Residents.

If you are a California resident, you may be entitled to request certain information regarding our disclosure, if any, of personal information (such as your name and contact information) to third parties who wish to contact you or send you promotional information about their products and services directly (as compared to when the third party is acting on our behalf or you have provided your personal information as part of a co-promotion by Hatch and the third party).

If you are a California resident and would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, please send us a letter at Attention: Privacy/Legal

If you are a California resident under the age of 18 and a registered user of the Hatch Service, you may request and obtain removal of content or information you have publicly posted on the Hatch Service. To make this request, please email us at privacy@playhatch.comand include a detailed description of the specific content or information you would like to remove. Please note that this removal does not ensure complete or comprehensive removal of the content or information posted on the Hatch Service by you as there may be circumstances in which the law does not require or allow removal.

YOUR DATA IS SAFE WITH US.

Security.

We use appropriate technical and organisational measures designed to protect the personal data that we collect and process of you. The measures we use are designed and continuously developed to provide a level of security appropriate to the risk of processing your personal information.

Data retention.  

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We retain your personal data as long as the provision of the Service to you so requires or we have a legitimate interest including due to legal, tax, or accounting requirements. We will, for example, periodically review accounts that have been inactive for a relatively long period to remove any unnecessary data.

When we have no ongoing legitimate business need to process your personal data, we will either erase or de-identify it. If we de-identify your personal data, we may use such personal data indefinitely without further notice to you.

AGE MATTERS.

When we collect personal data we do not know your age, and we do not knowingly collect or solicit personal data of anyone under the age of 13. We do not knowingly direct or target interest-based advertising to such persons. If you are under 13, please make sure not to send us any personal information. If we learn that we have inadvertently gathered personal data from a person under 13, we will delete such data without undue delay. Should you be aware of us having personal data of a person under the age of 13, please let us know!

Thank you for using HATCH! This privacy policy is to let you know what data we collect in our application, website, and related services (together “Service”) of you, why we do so, and how you can affect such data collection. We might update this Privacy Policy once in a while, but we will inform you in advance of any material changes thereto. Please note that any use of the Service after such changes is subject to the new Privacy Policy.

CONTACT US.

If you have any questions concerning this Privacy Policy or our collection or processing of your personal data, please contact us at privacy@hatch.live.

Controller name: Hatch Entertainment Ltd.

Address: Keilaranta 19, 02150 Espoo, Finland

WHAT DATA WE COLLECT.

Firstly, this is what you provide us:

  • Phone number
  • Name
  • Profile picture
  • Email

Secondly, this data is collected automatically:

  • Data about your use of the service (such as interactions with the Service and other users in the Service)
  • Your game progress
  • Your IP address and device identifiers (e.g. device ID, advertising ID, MAC address, IMEI)
  • General location data (country and city level)
  • Device type and network connection type
  • Device related data (such as resettable device ID, device name, operating system, language)

Third, this is what we get from our partners:

  • Demographic data
  • Data for advertising and analytics purposes, so we can provide you a better Service

WHY DO WE COLLECT DATA.

Contract.

In order for us to fulfil our contractual obligation of providing you the Service – create an account for you, enable you to play the games in the Service, operate the Service, and to notify you of issues and news concerning the Service – we need data from you.

Legitimate Interest.

In order to provide you with the best possible user experience and enjoyment of the Service, we have a legitimate interest to collect and/or process data for the following purposes:

  • Update and develop the Service.
  • Communicate with you through the Service, by email, and by SMS – including support, Service and news notifications, and relationship management.
  • Give you the opportunity to be social (e.g. chat, comments, social media, game sharing) in our Service.
  • Provide you with the best user experience based on your personal preferences.
  • To give you personalized game recommendations based on your actions within the Service as well as the data you have provided us.
  • To send you personalized advertisements based on the data you provide us or our partners.
  • To analyze, profile and segment the collected data.
  • To keep the Service safe and fair by monitoring and moderating (manually or automatically) its use and the social features therein, and should the need be take actions against misbehaving players.

Consent.

Should we wish to process your data for some other purposes, we will ask you for consent.

COOKIE TIME!

As just about all online services, we as well together with our partners, use cookies and similar technologies (such as SDKs) as a way to either collect the aforementioned data to provide you the Service, to do the processing actions listed above, or to combat fraud and abuse, frequency capping, and aggregated ad reporting. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Service.

VISIBILITY OF YOUR DATA TO OTHERS.

Socializing.

If you decide to be social in the Service and send messages to others or share your gaming success, other players will be able to see the aforementioned, as well as your profile data. Other players can also find you in the Service, if they have your phone number.

Hatch Processor Partners.

In order to get you the best possible Service, we need some help from others. We have partners providing their expertise to us, and for that purpose they collect and/or process your data (e.g. hosting, advertising, and analytics) according to our specific instructions and control.

“Big brother”.

We may disclose your personal data to a competent law enforcement body, regulatory, government agency, court or other third party, if we find it is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Hatch Controller Partners.

In addition to our Hatch Processor Partners, we also have Hatch Controller Partners, who provide features through our Service. Such partners may be for example social media tool or advertisement providers, and they collect and process your data separately from us under their own privacy policies. Please go check their privacy policies, as listed below!

Google Double Click and AdX/DFP https://policies.google.com/privacy

Facebook Ads https://www.facebook.com/about/privacy

This site is protected by reCAPTCHA and the Google Privacy Policy andTerms of Service apply.

DATA TRAVELS.

As we hope everyone around the world can have access to our Service, it is created global. Therefore your personal data can be transferred to any location in the world. That being said, we truly respect your privacy, and hence have all required safeguards in place to protect your data accordingly with this Privacy Policy. Standard contractual clauses approved by the EU Commission and the US Privacy Shield certification are generally considered as adequate safeguards to protect personal data in international transfers.

YOU HAVE RIGHTS!

Opt-out.

In the Hatch application you are able to modify your preferences concerning in-app push notifications (including marketing messages) by going to Settings and Notifications.

For our Hatch Controller Partners, please see their respective privacy policies to opt-out therefrom.

You can opt-out of interest-based advertising on mobile applications by checking under your phone Settings and the Google settings of your Android device and selecting the opt-out option for interest based or personalized, or similar, ads. Please note that the opt-out does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests.

See your information.

By sending us an email request at privacy@hatch.live we will send you your personal data in electronic format.

Restrict your information.

By selecting to use the Service anonymously, you can restrict the data we process of you. You can use the Service anonymously by not registering or signing in. Please, however, note that by playing anonymously you do not get all the features and benefits of the Service.

Right to modify.

By law you have the right to correct and delete your data, as well as to object to our use of your data. Any consent that you might have provided can be withdrawn at any moment. You can delete all the personal data that we have collected of you through the Hatch application by opening the application menu, and by going to Settings and Delete profile. This will erase all your personal data collected through the application, thereby also anonymizing all analytics data based on such personal data. To exercise any other right, please contact us at privacy@hatch.live, and we will respond to you without undue delay. If you feel that your privacy or personal data concern has not been satisfactorily addressed by us, you may contact your local data protection authority within the European Economic Area for unresolved complaints.

YOUR DATA IS SAFE WITH US.

Security.

We use appropriate technical and organisational measures designed to protect the personal data that we collect and process of you. The measures we use are designed and continuously developed to provide a level of security appropriate to the risk of processing your personal information.

Data retention.

We retain your personal data as long as the provision of the Service to you so requires or we have a legitimate interest due to legal, tax, or accounting requirements. We will for example periodically review accounts that have been inactive for a relatively long period to remove any unnecessary data. We will however confirm from you by SMS that such personal data is indeed unnecessary before any deletion.

When we have no ongoing legitimate business need to process your personal information, we will either erase or de-identify it.

AGE MATTERS.

When we collect personal data we do not know your age, and we do not knowingly collect or solicit personal data of anyone under the age of 13. Nor do we knowingly direct or target interest-based advertising to such persons. If you are under 13, please make sure not to send us any personal information. If we learn that we have inadvertently gathered personal data from a person under 13, we will delete such data without undue delay. Should you be aware of us having personal data of a person under the age of 13, please let us know!