PRIVACY AND DATA POLICY ISSUED BY MILESTONE S.r.L.
Last Updated: 4 April 2022
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by Milestone S.r.L. (‘Milestone’ / ‘we’ / ‘us’). Our office is at Via Olona 2, 20123 Milan, Italy. We are a company registered in Italy, with company number IT10851750967.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal information you have provided to us.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data:
Information provided by you when using the Game or the Online Service (“Submitted Information”)
We may ask you for, or you may submit (including without limitation through voice or text features) personal and non-personal information and data to us through the Online Service and/or the Game whenever you contact us, submit User Content in the Game or on the Online Service.
This may include:
- your email address (in the case of subscription to the newsletter service and access to the customer support service);
- your username and account in respect of the platform on which you are using the Game (for instance your Online ID for PlayStation®4 and your Apple Game Centre username and account details for iOS).
We may also obtain other personal data about you if you voluntarily supply it through the Game and/or the Online Service.
This could include a photograph that you have taken and uploaded to the Game (for example, when you create your User Content).
If you volunteer such information, you will be consenting to our processing it for the purpose explained to you when you supply it.
How you use our Services (“Analytics”)
We may collect technical information about your use of the Game /or the Online Service through the use of tracking technologies and analytics.
By way of example, data we may collect includes the following Analytics:
- how many times you access the Game;
- traffic data;
- the devices that you use to access the Game;
- your internet service provider; and
- the actions you take when playing the Game.
When you install, uninstall or update the Game, a unique application number and information about your installation, for example, the type of operating system, may be sent to us.
We use the following third party analytics providers (“Third Party Providers”):
- Google Analytics – https://policies.google.com/privacy
- Game Analytics – https://gameanalytics.com/privacy
- Facebook – https://www.facebook.com/about/privacy
- Playfab – https://playfab.com/privacy/
The third party analytics providers listed above will collect Analytics on our behalf and in accordance with our instructions, and their applicable privacy notice.
You can find out more about the way the Third Party Providers collect and process this information by following the above links to the privacy notice and/or terms and conditions for each applicable third party analytics provider.
Milestone DOES NOT USE data regarding the use of tracking technologies and analytics for marketing, advertising or profiling the data subject for commercial purposes.
Information about you collected from your device or Third Parties (“Content Information”)
We may collect information about you which you make available to us and which is stored on your console, device, or your Facebook or other social media profiles. This might include images (photographs/screenshots), video or other digital content such as records of your gameplay, the results of challenges within the games themselves, and the resulting leaderboards. Only the results of challenges which take place within the games and the resulting leaderboards may be shared with some of Milestone’s content partners and game brands (e.g. motorbike manufacturers, etc.).
In accessing the Amazon LUNA cloud game service, Milestone does not engage in account linking with user information, online ID or other such data. For any details regarding how Amazon manages this information, please consult the following links:
https://www.amazon.com/luna/landing-page – https://www.amazon.com/gp/help/customer/display.html?ie=UTF8&nodeId=468496&ref_=footer_privacy
3. HOW WE USE INFORMATION WE COLLECT ABOUT YOU
We will use any information that we collect about you, including any personal data, for the purposes described to you at the time that we collect such information, and for the following purposes:
- to help us identify you and to open, run and monitor any accounts you hold with us;
- to process your orders of Virtual Items and enquiries;
- to analyze technical information about the use of the Game /or the Online Service by the Users through tracking technologies and analytics for the improvement of our games, only using aggregated and non-personalized information.; and
- in the case of subscription to newsletter services or acceptance of our cookies, to send you information about, and updates concerning, the Online Service and/or the Game;
- in the case of subscription to newsletter services or acceptance of our cookies, to provide you with information about other games and services we offer that are similar to those that you have already purchased;
- to make suggestions and recommendations to you and other users of the Game about goods and services that may interest you or them;
- to allow you to participate in interactive features of the Game when you choose to do so; and
- for managing users’ reports of incorrect behavior (see point 5.11 of Milestone’s EULA) by other gamers and
- to notify you about changes to the Game or the services we provide.
- to remember you and your player profile, including your avatar and saved data;
- to understand how, and how often, users play the Game and use the Online Service;
- to administer the Game and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
- to help us improve the Game and the Online Service to ensure that content is presented in the most effective manner for you and for your device; and
- as part of our efforts to keep any multiplayer elements for the Game safe and secure.
- to allow you to share your gameplay with other users of the Game and your friends;
- to allow you to participate in interactive features of the Game when you choose to do so;
- to make suggestions and recommendations to you and other users of the Game about goods and services that may interest you or them; and
- in the case of subscription to newsletter services or acceptance of our cookies, to provide you with information about other games and services we offer that are similar to those that you have already purchased.
4. WHY WE COLLECT INFORMATION ABOUT YOU
To provide our Games and the Online Service to You
- responding to your enquiries; and
- contacting you about matters requiring your attention.
This processing of Submitted Information, Content Information and Analytics is necessary for us to pursue our legitimate interests of making our Games and the Online Service available to you, and ensuring that our Games function properly so that you have the best experience when playing any one of our Games and using the Online Service.
To understand how users play our Games and use our Online Service
We process information (including Submitted Information, Content Information and Analytics) to understand how players use our Games or our Online Service, and to compile Analytics and statistical aggregated and non-personalized reports regarding that activity.
This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Games function properly so that you and other users have the best experience when playing any of our Games and using the Online Service, and (ii) improving the quality of our Games and our services, and providing a better experience to our users.
We use various forms of marketing to provide you with promotional materials about our Games and/or the Online Service.
We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already.
Direct Marketing: We might send you marketing emails (Newsletter) about products or services which are similar to or related to our Games or Online Service, but only following your voluntary subscription to the newsletter service.
We work with the following third party providers to provide you with such targeted marketing:
The processing of your information in this way is necessary for us to pursue our legitimate interests of ensuring that our Games remains accessible for all of our users.
5. DATA SHARING
5.3 In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
5.4 If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
5.5 We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements between us, to investigate potential breaches, or to protect the rights, property or safety of Milestone, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by changing your account settings in the Online Service at any time.
In the case of subscription to the newsletter service, you can unsubscribe by clicking on the link in each communication sent.
In the case of cookies, it is possible to activate the options to change the privacy choices by means of the functionalities available by each browser.
Alternatively, you can contact us via the Support Service and let us know that you no longer wish to receive promotional or other marketing material from us or third parties.
7. YOUR RIGTHS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know via the Support Services.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
- you consented to our processing the personal data, and have withdrawn that consent;
- we no longer need to process that personal data for the reason it was collected;
- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Milestone, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed;
- you need the personal data to be deleted in order to comply with a legal obligations;
- the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we is processing your personal data, please let us know by contacting us via the Support Services.
- If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
8. Data Retention
10.1 We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and encrypted using Transport Layer Security (TSL) and Secure Sockets Layer (SSL).
10.2 Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
11. ADVERTISEMENTS AND AD SERVING TECHNOLOGY
11.1 Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not Milestone. Examples of third party providers we may use from time to time are:
11.2 If you are using an iOS device, you can find more information about how to opt out of personalised adverts by visiting https://support.apple.com/it-it/HT202074.
12. INTERNATIONAL DATA TRANSFERS
12.1 Information that we collect from you will be stored outside the European Economic Area (“EEA”) on a secured server in North Carolina, USA in the first instance.
All questions, comments or enquiries should be directed to Milestone using the Support Services link https://milestone.it/contact/. We will endeavour to respond to any query or questions within two business days.
Milestone’s DPO/RPD can be contacted by our Support Service at https://milestone.it/contact/, that will analyze all the inquiries and will provide feedback, also through the Officer, within the provisions in the existing European Community legislation on personal data protection, Regulations UE 679/2016.
© 2022 Milestone S.r.L. All trade marks are the property of the relevant owners. All rights reserved.