Privacy policy

Last updated: 1 September 2020

Please read this privacy policy and our terms of use before using our games and services.

1. Who we are

1.1 We are Kisetsu Studio Limited, a company registered in Spain with company number B01628106. Our registered office is at Ronda de Segovia 50 Office C, 28005, Madrid, Spain.

1.2 Kisetsu Studio is a small independent studio in Spain, working with multiple people worldwide. Whether making top-grossing mobile apps, barn-stormingly original multiplayer games, or deliciously crafted narrative adventures, every title we design shares our ambition to entertain millions of people around the world, in games that run for years.

1.3 We love games and the way they bring people together, and that passion is what holds us together as a studio, connects us with the partners we collaborate with, and is what links us to our sister studios across the world.

1.4 You can contact us by email at info@kisetsustudio.com for general queries.

2. About this policy

2.1 This privacy policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing our games and services.

2.2 This policy also provides contact details and important information about your data protection rights.

3. What personal data do we collect?

3.1 Players

We collect personal data directly from players via registration and gameplay. If you link your account to or access it via a third-party service (for example, Facebook, Xbox, Steam, PlayStation and Switch) we collect personal data from that service.

The personal data we collect and generate relating to players includes:

• Username and account details

• Game profile (including basic details, game progress and usage)

• Game profile ID (a randomly generated identifier)

• Analytics ID (used to track game usage)

• Third-party ID (if you link your account to or access it via a service such as Facebook, Xbox, Steam, PlayStation to your account)

• Device information (including ID, type, time zone setting and location, IP address)

• Marketing and communications data (including preferences)

3.2 Website users

We operate the following websites (our websites):

• www.kisetsustudio.com

The information we collect from individuals that visit our websites includes:

• IP address

• Device information (including ID, type, browser type and version, plugins, operating system and platform, time zone setting and location, IP address)

• Website usage

• Personal data entered into webforms

• Purchases and order history

• Marketing and communications data (including preferences)

• Cookie date (please see cookies section below)

3.3 People we work with

We collect personal data directly from individuals we work with. We collect personal data from their employers or the organisations they represent. We also collect personal data relating to people we work with from other organisations we work with (for example, industry conferences, gaming media, social media, platforms and stores).

The personal data we collect relating to people we work with includes:

• Name

• Address

• Contact details (including telephone and email)

• Social media

• Professional and employment details

• Personal data in correspondence

4. How we use personal data

4.1 Players

We mainly use personal data relating to players to provide, develop and promote our games and wider business. More specifically, we use personal data relating to players to:

• Improve our games (including by providing personalised content, language, help and instructions)

• Allow players to participate in certain website features

• Account verification and clearance

• Direct marketing to let players know about relevant products and services

• Provide customer service assistance

• Administer surveys and opinion polls

• Manage alpha, beta or early access tests (including collecting feedback)

• Administer promotions for products, services, news and events

• Better understand how our games are used (including checking traffic patterns and what types of content are most popular)

• Receive and respond to correspondence

• Detect and address hacking, cheating and other activities that harm the experience of our games

• Display in-game profiles

• Engage with players on third-party social networks (please check the privacy notices of social networks)

• Display leader boards, nicknames and any clan/guild information

• Detect and address security risks

• Detect fraud and other unlawful activity

• Exercise legal rights and comply with legal obligations

4.2 Website users

We use personal data relating to users of our websites mainly to provide, develop and promote our websites, games and wider business. More specifically, we use personal data relating to website users to:

• Provide customer service assistance

• Better understand how our websites are used (including checking traffic patterns and what types of content are most popular)

• Website analytics and improvements

• Detect and address security risks

• Detect fraud and other unlawful activity

• Exercise legal rights and comply with legal obligations

4.3 People we work with

We use personal data relating to people we work with mainly to provide, develop and promote our games and wider business. More specifically, we use personal data relating to people we work with to:

• Manage services provided by our suppliers

• Arrange meetings, calls and events

• Manage business and professional relationships

• Exercise legal rights and comply with legal obligations

5. Our legal grounds to use personal data

5.1 Players

Contract

Our main legal ground for the use of personal data relating to a player is for the performance of our contract with them under a game’s terms of use.

Legitimate interests

We will also use personal data relating to players where necessary for the purposes of legitimate interests pursued by us and organisations we work with.

However, we will only use personal data relating to players for the purposes of legitimate interests where players’ interests, 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 and promoting our games and our wider business.

Consent

Our legal ground for sending players users direct marketing is consent. Consent for direct marketing may be withdrawn at any time.

5.2 Website users

Legitimate interests

We use personal data relating to website users where necessary for the purposes of legitimate interests pursued by us. Our legitimate interests include for the purpose of providing, developing and promoting our games and wider business.

We will only use personal data relating to website users for the purposes of legitimate interests where website users’ interests, rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with.

Consent

Our legal ground for sending website users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.

5.3 People we work with

Contract

Where we have a contract in place with the people we work with, our legal ground for the use of personal data relating to such a person is for the performance of such contract.

Legitimate interests

We use personal data relating to people we work with where necessary for the purposes of legitimate interests pursued by us. Our legitimate interests include for the purpose of providing, developing and promoting our games and wider business.

We will only use personal data relating to the people we work with for the purposes of legitimate interests where their interests, rights and freedoms do not override our legitimate interests.

6. Automated decision-making

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

7. Sharing personal data

7.1 Players

We share personal data relating to players with other players, our staff and the following types of service providers:

• Platforms

• Distributors of our games

• Payment processors

• Marketing partners

• Analytics service providers (see cookies section below)

• IT providers

• Group companies

• Business partners

• Professional service providers (for example, accountants and lawyers)

7.2 Website users

We share personal data relating to website users with our staff and the following types of service providers:

• Analytics service providers (see cookies section below)

• Payment processors

• IT providers

• Marketing partners

• Group companies

• Professional service providers (for example, accountants and lawyers)

7.3 People we work with

We share personal data with our staff and the following types of service providers:

• Online stores

• Payment processors

• IT providers

• Marketing partners

• Group companies

• Sister studios

• Business partners

• Professional service providers (for example, accountants and lawyers)

We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Kisetsu Studio or our games.

We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.

8. Cookies and similar technologies

8.1 Essential cookies

Our websites will not work properly without essential cookies. For example, we use cookies for security purposes.

8.2 Analytics cookies

We use Google Analytics to learn about how people use our website. For example, which pages users visit most often and where users encounter error messages.

9. Children

We do not knowingly collect or use any personal data relating to children under the age of 14.

10. International transfers

We routinely transfer personal data outside Spain. Where we transfer personal data outside Spain 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.

11. Data retention

11.1 Players

We keep personal data relating to players for the period that the game is available to play. Once we make a game unavailable, we will delete all personal data relating to players of that game. We will also delete personal data relating to a player when we receive a specific request for erasure (see rights section below).

11.2 Website users

We keep personal data relating to website for as long as necessary for our games or wider business purposes.

11.3 People we work with

We keep personal data relating to website for as long as necessary for our games or wider business purposes.

12. Rights

12.1 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 of personal data (including the sale of personal data to other companies)

• 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

12.2 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.

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

13. If you do not provide personal data

Where we need personal data for an agreement with you and you do not provide that personal data, we may not be able to perform out agreement. In this case, we may have to cancel your access to our games.