PRIVACY AND DATA POLICY – Interstellar Luxury Spa Palace

ISSUED BY XLSP GAMES LTD
Last Updated: 12 October 2022

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by XLSP GAMES LTD. Our registered office is at Dolphin House, 3 North Street, Guildford, Surrey, England, GU1 4AA. We are a company registered in England, with company number 06663645.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games including our websites (xlsp.us.kg) (the “Website”), our online forums and promotional websites, which may be operated by us or on our behalf (https://xlsp.us.kg/) (the “Forums”) and user Help Centre (https://xlsp.us.kg/) (the “Help Centre“). Together the Game(s), the Website, the Forums and the Help Centre are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at [email protected]

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

What types of 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.

This Privacy Policy forms a part of and should be read in conjunction with any of our terms of use for the Website and end user licence agreements for each of the Games. Where we particular personal data, those lists should not be considered complete, but an indication of the categories of personal data we process.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.

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 Games
(“Basic Information”)

We may collect the following information from you when you play our Games:

Your username (or gamertag);
the names of planets, alien bases, flora and fauna you discover in Found Girls Sky;
player ID;
your mobile device’s unique device ID;
your console’s unique device ID;
your platform player ID, as may be allocated to you by third party platforms such as PlayStation, Steam or Xbox;
any third party platform profile display names;
your user preferences, including your language and country; and
core milestones related to your gameplay, such as your overall progression to a particular level or stage, or the completion of certain activities during your gameplay (for example, completing a tutorial or passing a level).

Information provided by you when you contact us or use the Help Centre
(“Support Information”)

We may ask you for, or you may submit, certain information to us whenever you contact us through the Help Centre.
This may include:

your name;
your email;
location data specifying the city in which you are located;
the type of device you’re using to play a Game;
your platform player ID, as may be allocated to you by third party platforms such as PlayStation or Steam; and
debug logs, which are records of technical information relating to software operation and errors that may have occurred during that operation.

Information provided by you when using the Forums
(“Forum Information”)

In order to set up an account to use the Forums, we will collect the following information from you:

username;
email address;
password; and
a unique Forum User ID which identifies your account.

If you wish to do so, you may also provide the following information when using the Forums:

date of birth;
location;
interests;
occupation;
a link to your website;
details relating to your accounts for the following: Yahoo Messenger; AOL; Facebook; Google+; Skype; Twitter; YouTube and ICQ.

Information collected for the purposes of providing analytics
(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

how many times you visit the Website;
which pages you go to;
traffic data;
your IP and MAC address;
your internet service provider;
your Device ID;
your Console ID;
your user ID (which is generated by us and allocated to you when you first play our Games);
your device operating system & version;your device make and model;
game play attempts, progression and results;
session game time start, end and duration;
the country of your device; and
identification of crashes and defects.

We use the third party analytics provider Google Analytics, as well as data provided by third party platforms such as PlayStation and Steam.

Google and Steam may collect analytics data on our behalf and in accordance with our instructions, and their applicable privacy notice. If you would like to find out more about the way Google and Steam collect and process this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://policies.google.com/privacy and https://store.steampowered.com/privacy_agreement/.

We also obtain data in respect of software crashes from Microsoft and Sony. This includes technical information about your device, the software and applications running on your device and your user ID.

Content created by our users which we host and display on the Forums and in the Help Centre, or which is submitted to us through the Website
(“User Content”)

When users submit their own User Content to the Forums or Help Centre, this content may contain personal and non-personal information.

You may also submit information to us through our Website, for example by emailing us at our general contact email address [email protected].

This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Online Services to you

We will use information about you (including Basic Information, Registration Information, Analytics and User Content) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games and using the Online Services.

To record discoveries in Found Girls Sky

On of the key elements of our Game Found Girls Sky is exploration. When exploring the Found Girls Sky environment, you may discover planets, alien bases, flora and fauna. If you are the first to do so, your discovery will be named after you, based on your Found Girls Sky username. Those names are viewable by other players.

As this is a feature of Found Girls Sky, we process this information in order to deliver Found Girls Sky to you under the terms of use agreed between us.

If you decide to stop playing Found Girls Sky, we will continue to use your username as the basis of the name of your discoveries. We do this in the pursuit of our legitimate interests.

To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, User Content, Registration Information, and Analytics) so that we can analyse and improve our Games and Online Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Games and Online Services.

To respond to your enquiries and requests for support and to enable you to use the Forums and Help Centre

We may process Support Information and User Content so that we are able to properly respond to your enquiries and support requests either via the Help Centre and we may process Forum Information and User Content so you are able to use the Forums, in accordance with the terms of use agreed between us.

Zendesk helps us to operate our Help Centre and process Support Information for us. Studios Alice & Smith and Moov2 help us offer our Forums and process Forum Information and User Content for us.

For recruitment

We may use User Content, which may include CV data or other information you submit to us in application for a job, and references obtained from third parties, for recruitment. We do this in the pursuit of our legitimate interests.

4. COOKIES

A cookie is a text file placed onto your device when you access our Games or Website. We use cookies and other online tracking devices such as web beacons, and flash object storage to deliver, improve and monitor our Website and Games, including in the following ways:

Authentication – To log you into our Website and Games and keep you logged in.
Preferences – To remember information about you such as your preferred language and configuration.
Analytics – To help us understand how you use our Games and Website, and how often, so we can improve them to deliver a better experience for our users. To carry out research and statistical analysis to help improve our content, products and services.

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

Our Website should display a notice alerting you to our use of cookies and and requesting your acceptance. If you accept, you will be accepting our use of cookies or similar technologies for the purposes described in this privacy policy.

If you use our Website after this notice has been displayed to you we will assume that you consent to our use of cookies or similar technologies for the purposes described in this privacy policy.

Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Games and Website.

We work with third parties who may also set cookies on our Website, for example Google Analytics, Facebook, Twitter and YouTube, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Games and Website.

If you want to learn about how to opt out of Google’s use of cookies, please visit https://tools.google.com/dlpage/gaoptout/. The Google Analytics terms of service can be accessed here: www.google.co.uk/analytics/terms/us.html. For further information please visit the website of the relevant third party.

5. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, 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.

Required by law: 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).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of XLSP, our customers, or others.

Digital Content Stores: Where the Games are downloaded through Steam, Xbox Live and/or PSN, we may disclose your personal information to Valve Corporation, Microsoft, Sony, Google and/or Apple respectively for the purposes of facilitating any payments made through these platforms.

Help Centre: We use a third party platform provider called Zendesk to manage any support requests, queries and issues raised by users through the Support. Further details about the way in which Zendesk may collect and process your information can be found in their terms at https://www.zendesk.co.uk/company/customers-partners/privacy-policy/.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you would like to exercise any of your rights in respect of your personal data, please contact us at [email protected].

7. YOUR RIGHTS 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 by sending an email to [email protected]

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 XLSP or a third party, 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 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, or 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 a commonly used, machine-readable and interoperable 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 are 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

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

If you would like us to delete your Forum account or any User Content that you have posted, please let us know by sending an email to [email protected]

9. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at [email protected].

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

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. INTERNATIONAL DATA TRANSFERS

It is possible that your personal information may be transferred outside of the EEA by third parties that process personal data on our instructions, such as Microsoft Azure, Zendesk, Google, Valve Corporation, Microsoft, Sony and Apple. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.

Our servers are hosted by Microsoft Azure located in Virginia, USA.

Where we transfer your information outside of the EEA, we implement appropriate safeguards to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to [email protected].

CONTACT INFORMATION

All questions, comments or enquiries should be directed to [email protected]. We will endeavour to respond to any query or questions within three business days.