Protecting your privacy is a high priority to us. We hope that the following statement helps you understand how Proeminent Code SRL (“we, us, our”) processes, uses and safeguards your personal information in context of CLASHBOWL (“The Game”).
This privacy policy may be updated from time to time. You should consult this privacy policy regularly for any changes.
1. Information Processing for CLASHBOWL
At the heart of personal data protection in regards of The Game is the principle of data minimization. We only collect data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. The following subsections explain what data is processed in relation to CLASHBOWL.
Game Data
Game Data consists of Player Account Data and High Scores Data. Game Data is exchanged between The Game client that is running in player’s device, and our servers. Game data is transmitted via internet using encrypted HTTPS requests from client to server. We process and persist Game Data to be able to create a continuous gaming experience across multiple gaming sessions and devices for our players. In order to be able to create this type of continuous experience, we require every player of The Game to give consent for processing their Game Data before we allow access to The Game.
Player Account Data contains Player’s credentials, Player’s Game State and list of Player’s Friends from the platform from which The Game installation was obtained from. Player’s Credentials identify the player’s account in the store platform from which The Game installation was obtained from and allow our server to identify a player account as an existing player of The Game when a player initiates a game session from a new device or after reinstalling The Game. This allows playing The Game with one Player Account from many devices. Game State allows the player to continue game on another device or after reinstallation, instead of starting anew. List of friends makes it possible for The Game to identify player’s friends who are playing The Game and to make it easy for the player to set up games with friends.
High Scores Data allows players to compete on high score lists in The Game. Most High Scores Data is sent directly from The Game client to the server after finishing a game while some High Scores Data is generated on the server. Example of generated High Scores Data is weekly player rankings, which takes last week’s ranking score and best scores from the client as input and calculates a new aggregated ranking score based on them.
Online Game Data
Online Game is a feature that allows players to interact and play together using internet and our server as the means of connecting players. Online Game Data is exchanged between game clients and our server to be able to make this possible and playing online requires a steady stream of Online Game Data to flow between The Game client and our server. Online Game Data contains Player Data of players who have Online Game feature enabled, as well as real time data such as current activity of the player, position and pose of the player’s avatar, position and rotation of player’s ball and all player’s pins and events such as collisions and scores. Online Game Data is not saved to long term storage at all.
Voice Chat Data
Voice Chat is a feature that allows players to speak naturally with each other while they’re using Online Game. Voice data consists of voice over ip data packets that are sent from The Game client to our server and then relayed by our server to clients that are receiving that communication. Voice chat data is not saved to long term storage at all.
Meta Avatar Data
The Game client uses Meta Avatars for representing players in the virtual environment. All players can choose their representation from a selection of Meta Avatar presets while players from Meta Platform can create a customized Meta Avatar to represent theirselves accross multiple applications. Custom Meta Avatar is configured using Avatar Editor in Meta’s Platform and the related configuration data is stored and managed in the Meta Platform by Meta Platforms, Inc. The Game client retrieves Meta Avatar Data regarding custom avatars from Meta’s Content Delivery Network by using internet as the medium, to be able to show custom Meta Avatars.
The Game client identifies its owner to Meta’s Content Delivery Network while retrieving Custom Meta Avatar data. Player’s Meta User Account is used for players from Meta Platform and a Federated Meta User Account is created for players from other platforms. The Federated Meta User is created only for the purpose of retrieving Meta Avatar Data and it doesn’t contain any personal information about the owner.
Privacy Policy of Meta is available at:
https://www.oculus.com/legal/privacy-policy
Analytics Information Collection Regarding Usage of The Game
We use a game analytics services to collect and analyze usage information from The Game. Game analytics services are provided by Unity Technologies Ltd. Analytics information is collected, maintained and utilized following game analytics service providers’ privacy policies. Privacy policies are available at:
https://unity3d.com/legal/privacy-policy
Game Server Logs
Our servers log the following information related to actions of game clients:
- Requests related to Game Data (HTTPS)
- Usage of Online Game features
Logged information contains player account id and information regarding what kind of operations were performed.
Web Site Logs
We log information related to HTTP and HTTPS requests to proeminentcode.com domain. Logged information contains client IP-address, the page that client has requested and any request parameters given.
2. Information Usage
We use information for the following purposes:
- To create a high quality gaming experience across many sessions and devices
- To identify and fix issues with our services
- To monitor the usage of our services
- To derive useful information concerning the interests of our users
- To improve our services
3. Information Sharing
Personally Identifiable Information
We do not share any personally identifiable information with third parties with the exception of when we are required to do so to comply with the law.
Aggregated Reports
We may share aggregated reports of use of its services with third parties or public. Aggregated usage reports cannot be used to identify information about our individual users.
Compliance with Laws
We co-operate with government, law enforcement officials and private parties as required to comply with the law. We will disclose information to the law enforcement officials as we are required to.
Business Transfers
We may sell some or all of our assets, including among others any information we have related to our players, in connection with a business transfer, merger, acquisition, sale of assets or in the event of bankruptcy.
4. Data Protection
Safeguarding personal information of our players is a top priority for us. We employ a large variety of measures designed to protect information from unauthorized access and are committed to the following principles, set out in the General Data Protection Regime (GDPR).
Information of our players shall be:
- Processed lawfully, fairly and in a transparent manner in relation to individuals.
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accurate and kept up to date.
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
5. Information Processing
The information may be located at -, transferred to -, and processed in the United States of America or European Union.
6. Data Removal Request
The game has built-in support for removal of Player Account and all related data. This functionality can be accessed by launching the game, choosing Edit Player Account and pressing Delete button. Players can also request removal of information related to them by contacting our support email address contact@proeminentcode.com
7. Data Retention
Player data is removed automatically after 2 years of inactivity.
8. Contact Information
If you need to ask anything related to our privacy policy, contact us by email contact@proeminentcode.com.