What is this Privacy Policy for?
This privacy policy is for the video game ACTing Minds (iOS & Android) served by Mikoshi Ltd. and governs the privacy of its users who choose to use it. The policy sets out the different areas where user privacy is concerned, and furthermore the way the ACTing Minds video game processes, stores and protects user data and information will also be detailed within this policy.
Are there any other privacy policies I need to be aware of?
Yes. ACTing Minds is built using Unity3D and utilises Unity Analytics to collect information about gameplay progress and device information to identify problems or app improvements. Unity Analytics privacy policy can be found at https://unity3d.com/legal/privacy-policy and further GDPR related policies can be found here https://unity3d.com/legal/gdpr
Acting Minds
- ACTing Minds and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their gaming experience. The app complies to all UK national laws and requirements for user privacy
- We may collect anonymised data that includes:
- Your gameplay progress
- Game perfomance data
- Your achievements unlocked
- Your device operating system in use
- Your play sessions
- Your country location
- We do not collect personal data that include:
- Your name
- Your age
- Your address
- Your gender
- Your email addresses
- Your phone numbers
Data Use
2.0 Your personal data will not be used for purposes such as Clinical Research.
2.1 We do not share any data with any other app or service except Unity Analytics.
2.2 The video game doesn’t contain features that allow the video game to share data with other users.
2.3 The data will be stored in Unity’s secure servers in the cloud.
Data Security
3.0 The data that is transferred to Unity and is stored using recognised secure data technologies that is used by tens of thousands of games globally.
3.1 Unity Analytics does not use encryption.
3.2 The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject. We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
3.3 The video game ACTing Minds complies with GDPR rules which supersede the ‘Data protection act’.
Data Retention
4.0 Data retention is the GDPR ruling that data should not be kept longer than necessary. There is a degree of flexibility with regards to “longer than necessary”, but this cannot be
an undetermined amount of time or;
forever.
4.1 The ACTing Minds video game does not collect personal data, however it does collect analytic data. As analytic data could also potentially be regarded as sensitive data (despite being anonymised), we will still implement a data retention policy guidelines for this data.
4.2 The guidelines are intended to ensure that ACTing Minds processes Analytic data in accordance with the Analytic data protection principles, in particular that:
- Analytic data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.
- Analytic data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. When Analytic data is no longer needed for specified purposes, it is deleted or anonymised as provided by these guidelines.
- Analytic data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.
- Analytic Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
- Analytic Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
4.3 ACTing Minds approach to retaining Analytic data is to ensure that it complies with the data protection principles referred to in these guidelines and, in particular, to ensure that:
- Analytic data records are regularly reviewed to ensure that they remain adequate.
- Analytic data records are kept secure and are protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. ACTing Minds uses anonymization to prevent identification of individuals.
- When records are destroyed, whether held as paper records or in electronic format, we will ensure that they are safely and permanently erased.
4.4 Data retention periods for ACTing Minds Analytical data is governed by the retention periods outlined in the Data Retention policies for Unity