Privacy Policy

Last updated: 3 September 2024

Introduction

This privacy notice (this “notice”) is about how we use personal information about you called “personal data” when you’re playing DEATHSPRINT66 (the “game”) and your use of the game website, together with the game the “service”).

Who are we?

We are Secret Mode Limited (“we” or “us” in the rest of this notice). We are located at Unit 32 Jessops Riverside, Brightside Lane, Sheffield, United Kingdom, S9 2RX and you can find our contact details below.  

We make decisions about how and why we use your personal data when you use the game and our website. The means we’re what’s called a “data controller” of this personal data.

Personal Data We Collect and How We Collect It.

We process personal data about you when you play our game, use our website, and when you interact with us in relation to our services. This includes:

• Information you provide to us and information relating to your communication, such information you submit when filling in your account set up form or contacting our customer support teams.
• Usage and tracking information. We automatically collect certain types of usage and device information when you use our services. This information includes device identifiers (like IP address or mobile device identifiers), event data related to updates to your account information, log details, country of install, language, advertising referral data, browser type, Internet service provider, platform type, device type, operating system, pages or features you use, time and date of access, unique device or account ID, usage information, and other similar information. We collect this information using cookies, pixel tags, and other technologies as described in our Cookie Notice at the end of this document.

In relation to information, you provide us, the provision is optional, but if you choose not to provide it you may not be able to access certain aspects or functionalities of the service where this information is needed. Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory, and we will not be able to provide our services without this information.

We collect the following categories of personal data in connection your use of our services:

• Identity and contact information, such as name, email address, mailing address, and phone number, and communication preferences.
• Account information, such as username and password and country of residence. You may also optionally provide your location, preferences, a photo or avatar, or other profile information (but not providing it will not affect your use of our services).
• Customer support and communications data, such as your feedback and interactions with our customer support teams, support ticket and records, and other communications you have with us, including information about in-game communications.
• Marketing and advertising data, such as participation in survey responses, contests, sweepstakes, your marketing choices, information regarding your preferences or attributes based on your use our services, customer profiles, your email address and inference segments based on your account and other games you use, your activity in online forums and communities and your interactions with advertising and marketing communications.
• Usage, browsing and activity information: such as your game activities and device, including IP address, location information, country of install and language, device ID, manufacturer, and model.
• Gameplay data, such as information about events in the game including progress, achievements, occurrence of particular events, game installation/uninstallation, play session durations, choices/selections for different parts of the game, game-play statistics, in-game purchases, scores, rankings, click paths, game profile, preferences and friends, and interactions with game content.

Third Party Sources

We collect personal information about you from the following third parties:

• Connected services: If you link, connect, or log in using third-party accounts to your account with us, or interact with use and others on game forums with third-party platforms, the third-party service sends us information such as your profile information, account details, device IDs, UIDs, MAC address and IP address from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at the service.
• Third party tools: We also may use third-party tools to help us manage and analyse our social media presence, provide behavioural analytics, report on comments, mentions and other content that is posted about us on social media and other third party sites, platforms, public channels and forums. The information collection and sharing practices of these third parties are subject to their respective terms and conditions and privacy policies.
• Advertising partners and social media service providers: We collect information from advertising partners in connection with our ad campaigns that have surfaced on other platforms, such as the ads you clicked on and other interactions with our ads. When you communicate or interact with us, our pages or brand on social media websites and online forums, we collect information about your communication or interaction from social media companies and other service providers in order to provide us analytics in relation to our social media pages and presence and help us respond to comments, mentions, and other content posted on our pages.
• Market research and sweepstake vendors: When you participate in research, we obtain information that you provide our service providers and partners that are assisting us with market research from those service providers and partners as well as their analysis in relation to research contributions. When you participate in offers, competitions, contests, sweepstakes or similar that we offer, we collect participation data from service providers and partners that we work with in relation to the offer or competition.
• Vendors and business partners: We collect contact, account and payment transaction data from our vendors (such as payment processors, digital storefronts, cloud hosting and service providers) to enable features of our services.

How and Why We Use Your Personal Data

Depending on where you play our game, we are only legally allowed to use your personal data where a “legal basis” allows us to do so. These are the legal bases which could apply:

Legal Basis	When does this Legal Basis apply?
“Contract”   We need to carry out or sign up to a contract	When it’s necessary to use your personal data to perform a contract with you, or because you have asked us to do something before signing a contract with you that requires the processing of your personal data.   In these cases, if you don’t provide your personal data, then we won’t be able to perform the contract or do what you have asked us to do before signing the contract.
“Legitimate Interest”   It’s in our or someone else’s “legitimate interests”	“Legitimate interests” is a legal phrase. It usually means a commercial or business interest that is important to us or another company, and which we’ve balanced against your right to privacy.     We will always let you know what the interest is, and you can object to us using your personal data for these reasons via email at info@secretmode.games.
“Consent”   You have given us your consent	Sometimes we will ask for your (or we might need to ask for your parent’s) consent to use your personal data. This consent will always be clear and separated out from other information.   You can always withdraw your consent by contacting us at info@secretmode.games
“Legal obligation”   We need to do something a legal obligation tells us to do.	When it’s necessary to use your personal data so that we can perform our legal and regulatory obligations – so that we don’t break the law.

 

This table lists the types of personal data we use about you, and our reason for this: 

The types of your personal data we use	Why we use this personal data	Legal basis
Providing our services, including identity and contact data, account data, transaction data, (including third-party account IDs), usage and tracking data, and gameplay data	We use this information to create your account to provide access to the service. Where you can login to our services from a third-party platform, we process account information provided by that third party. We also use this information to host our servers and enable the game.	Performance of Contract   Legitimate interest in maintaining and improving the service
Processing transactions related to our services: identity and contact data, account data, transaction data	We use this information to facilitate your payment for products offered through our service and maintain a record of your transaction history.	Performance of Contract
Providing friends list functionality, account data, gameplay data.	We use this information so that you can connect with your friends and share game activities with your friends.	Performance of Contract
Enabling customer support: identity and contact data (email), account data, customer support and communication data, transaction data, and gameplay data	We use this information to help provide support to you in relation to the issue you’ve contact us about.	Legitimate interest in answering your questions about our service to improve your experience.
Leaderboards, including Steam ID, Steam photo & region (country)	We use this information to provide player level data including show on in-game leaderboards	Legitimate interest in providing the service.
Running technical diagnostics and crash reporting, including account data, gameplay data, and usage and tracking data (e.g., basic hardware information, IP address, operating system information, server logs, log files, and bug/crash reports).	We use this information to conduct run technical diagnostics and crash reporting. We process some of your usage and tracking information to accomplish this including device IDs and other technical information necessary to why something went wrong.	Consent (where consent is needed to access information stored on your device)
Maintaining network security, including account data (Device ID, Steam ID, Player ID, Epic Account ID), and usage and tracking data (IP address, IP lookup information)	We use this information to help provide security and network protection mechanisms,	Legitimate interest in ensuring the security of our services & technologies
Providing community forums: Account information including email, IP address, password and alias, and forum postings. .	We use this information to allow you to use the forum services.	Performance of Contract
Conducting analytics for gameplay features, account information, usage and tracking data, gameplay data	We process data related to your device and your gameplay to learn more about our services.	Consent (where consent is needed to access information stored on your device).
Conducting behavioral analytics, Steam ID, Player ID, IP address, country	We track behavioural analytics based on player activities, technical performance, ads channel.	Legitimate interests in improving our products and services
Improving our products services, account information, usage and tracking data, customer support and communication data gameplay data. Steam ID, Player ID, IP address, country.	We process information provided from your feedback and analytics of our users gameplay to optimize our products and services, fix patches and bugs, offer upgrades, facilitate software updates, and develop new games, features, offerings, and services	Legitimate interests in improving our products and services
Enabling anti-cheat and security related features: Device ID, game related data (platform ID), operating system information	We use this information to detect and observe cheating behaviours and fraud, identify and address bugs caused by cheating in the game, prevent hacking and spamming, and combat users registering for multiple accounts. We use this in conjunction with (Proxima Beta Game Anti Cheat (PGAC))	Legitimate interest in maintaining a fair gaming environment
Sending our newsletter, including identity and contact data (name and email)	We use this information to send you our subscription newsletter.	Consent
Conducting marketing and advertising: identity and contact details, account information, tracking and usage data, marketing and advertising data.	We use this information to display advertising network purchases on an impression basis that optimizes ad placement based on return on spend or in-game and website behavior, including how you interact with our services and your online activity.	Consent
Measuring ad campaigns: identity and contact details, account information, tracking and usage data, marketing and advertising data.	We process this data to measure the effectiveness of ads shown to you. For example, if you click on a link that advertises the service, we store the Advertising ID for that advertisement with your profile. We share this information with our	Consent
Protecting and enforcing our rights:  where relevant, identity and contact data, account data, transaction data, customer support and communication data marketing and advertising data, gameplay data.	We may process personal data to protect and enforce the rights, property, security or safety of us, our business, our customers or others, including investigating and helping to prevent fraud or other unlawful activity. We keep business, accounting and legal records to do this.	Legitimate interests in defending our legal rights and interests.
Meeting regulatory requests – potentially all information categories listed above	We may disclose personal data to meet requests from regulatory, prosecuting, law enforcement, tax or governmental authorities, courts or tribunals	Legitimate interests – defending our legal rights and interests.
Responding to data subject requests: where relevant identity and contact data, account data, transaction data, customer support and communication data marketing and advertising data.	If a data subject request is submitted, we use this information to confirm the requestor’s identity, your rights and to process the request.	Legal obligation – our obligations under data protection laws
Sending legal reports/responding to court orders – potentially all information categories listed above if a law enforcement body requests it	We may be required by law to disclose this information to law enforcement bodies.	Legal obligation – our obligations under tax, anti-money laundering, anti-bribery, security, and intelligence laws
Financial reporting: transaction data, usage and tracking data	We use this information to complete our financial reporting and disclosure obligations to parent company, tax agencies and regulators	Legal obligation – our obligations under tax and corporate law.

 

Disclosures of Your Personal Data

Sometimes we share your personal data with other companies and organizations.

The types of companies and organizations we share your personal data with are as follows:

• Game storefronts, platforms and distributors – Where necessary to provide our Services or to investigate or prevent fraud, we share your identity and contact, account, and gameplay data with other companies (including the Apple App Store and Google Play Store) to provide the services or assist you in setting up your account.
• Companies in our “group” of companies – We have lots of different companies in our “group” who are linked to us. Some of them provide us with services to help us to manage our games. When needed, we share all personal data mentioned above with these other companies so they can assist us with the processing set forth in this policy. We may share your personal information with our parent company Sumo Group Limited and its subsidiaries (the “Sumo Group”).
• Service providers – We need separate companies to provide us with services we use to support the game. We share personal data with the following categories of third parties: payment processors and online store providers (we share your identity and contact and account data); hosting providers (we share your account data, and device usage and tracking data, Steam ID, Steam photo & region/country); customer support companies (we share your identity and contact data, customer support and communications data, and gameplay data); technical support providers (we share technical diagnostics information contained in your usage and tracking data, and gameplay data); newsletter providers (we share your identify and contact data); offline support services such as product support or data storage (we share your account data, and device usage and tracking data, Steam ID, Steam photo & region/country); and anti-cheat software providers (we share your account data and gameplay data).
• Advertising and analytics partners – We engage third parties that provide advertising, campaign measurement, online and mobile analytics and related services to us as described above. We share identity and contact information, marketing and advertising data, and usage and tracking data with these providers.
• Regulators, official authorities, and other third parties in relation to legal compliance – For example, the police or the government might legally require use to give them personal data to help them with an investigation, or we might be required to give these companies personal data to enforce our terms, address security and fraud, and to protect you. We may be required to share all categories of personal data mentioned above with these entities.
• A third party that acquires all or part of our business – we might disclose all categories of your personal data mentioned above to another company which buys or undertakes another type of corporate transaction in respect of our shares or buys all or part of our assets.
• With your consent – we share information about you for any other purposes disclosed to you with your consent.

Where We Share Your Personal Data

Yes, sometimes your personal data goes to other countries as part of using your personal data in the ways we listed above, including in the European Economic Area (“EEA”). If you are in the UK, the EEA, or Switzerland (“European Region”) and your personal data goes outside of these countries, the law requires us to take extra steps to make sure your personal data is protected in the place it is going to.

We transfer your personal data to third parties that host or access personal data outside of the European Region, including the United States, Singapore, and China.

Where the country outside the European Region is a country which is subject to an adequacy decision by the European Commission, UK Government, or the Swiss Federal Council, we rely on that adequacy decision of the transfer – for example the United States (when recipients are certified under the EU-US Data Protection Framework).

If we send your personal data to a company (either in our “group” of companies or a separate company) which is in a jurisdiction not subject to an adequacy decision, we will rely on EU standard contractual clauses, which require that company to protect your personal data. To the extent required or permitted by data protection law, we may rely on a vendor’s processor binding corporate rules and/or other data transfer mechanisms available under EU data protection law.

We might take similar steps where you are in another country with similar legal requirements, as well. If you want to find out more information about international transfers, you can contact us using the details below.

How Long We Retain Your Personal Data?

We only keep your personal data for as long as is necessary to fulfil the purpose for which it was collected. As soon as your data is no longer required for the aforementioned purposes it will be deleted. Generally, we will retain data necessary to provide our game until we sunset it. Any additional data related to providing our services, including troubleshooting and customer service, will be kept as long as necessary to fulfil the request.

We might need to keep your personal data for longer if a law requires us to (for example, laws about record-keeping and tax). Normally this is about six to ten years. If we are keeping your personal data for longer in this way, we will make sure it is secure and you can still change what we do with it (see below). 

Your Data Subject Rights

Because your personal data is about you, you should be able to control what happens to it.

We provide different ways you can do this. The easiest way is to write us an email at info@secretmode.games requesting one or more of the following:

• “Right to Object” – you can object to how we are using your personal data if we are using it based on legitimate interests (see above) in certain situations.

 

• “Right to Portability” – you can request a downloadable copy of your personal data and for us to transfer it to another party. If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible.

 

• “Right to Access” – you can request to access to the personal data we use about you, and information about how we use it and who we share it with.

 

• “Right to Deletion” – you can request that your account or specific personal data we store about you is deleted from the game. Please be aware that once an account has been deleted there is no way to recover it;

 

• “Right to Correct” – you can request that information about you that is wrong or outdated is corrected.

 

• “Right to Restrict” – you can request to restrict the use your personal data, for example to storage purposes only.

 

• “Right to Withdraw Consent” – you can withdraw your consent if our reason for using your personal data is consent (see above). We will then stop using your personal data in this way (though this doesn’t affect the lawfulness of the processing until you withdraw).

You can also submit requests to exercise these rights by contacting us at info@secretmode.games.

Unfortunately, we’re sometimes not able to do the things you tell us to, for example because of the legal basis we have been relying on to process your personal data, or because it would interfere with another person’s own privacy rights. If this happens, we’ll explain to you why we aren’t able to do what you tell us to with that piece of personal data.

We may also be required to keep certain personal data to satisfy legal requirements or for security purposes, or if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case.

You can contact the official organization which regulates personal data in your country (the “regulator”) to lodge a complaint, if you think we are not using your personal data correctly. If you are in the UK or the EEA:

• You can find a list of EEA data protection regulators here.
• In the UK, the regulator is the Information Commissioner’s Office which you can contact here.
• In Switzerland, the regulator is the Federal Data Protection and Information Commissioner (FDPIC), which you can contact here.

Updates to this policy

We may make updates to this policy from time to time (for example because our services have changed or because of changes in laws). We will appropriately notify you of this. The date this notice was last updated can be found at the top.  

Children

We do not use the Services to knowingly solicit data from or market to children under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@secretmode.games. We will delete such information within a reasonable time.

Contact Us

If you have any questions about what we have said in this notice or how your personal data is used, you can contact us about it.

Our contact details are: 32 Jessops Riverside, Brightside Lane, Sheffield, United Kingdom, S9 2RX. Our email address is info@secretmode.games. If you are located in the EEA and have questions about your personal data or would like to request to access, update, or delete it, you may contact our representative at:

32 Jessops Riverside, Brightside Lane, Sheffield, United Kingdom, S9 2RX. Our email address is info@secretmode.games.

Thank you!

We hope you have a great time playing DEATHSPRINT66!

—

If you are in California:

Below, we provide information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA“), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under the CCPA.

Categories of Personal Information We Collect and Disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. We may collect personal information from the following sources:

• Our affiliates and subsidiaries
• Third-party platforms
• Third-party sites and services
• Operating systems and platforms
• Ad networks
• Analytics providers
• Social networks
• Internet service providers
• Our vendors and service providers

 

The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we may collect, sell, and disclose to others for a business purpose. We collect and disclose this personal information for the purposes described in Section 2 and Section 3 of this Policy. We do not sell the personal information of California residents.

Personal Information Collected		Categories of Third Parties to Whom We May Disclose this Information
Categories	Uses
Customer Records	Includes your account and profile information and customer records that contain personal information, such as username, name, demographics and other characteristics or descriptions, email, address, telephone number, and other contact information, account credentials, communications preferences, billing and payment information, customer service and support tickets and records), and other information individuals provide us in order to register for, access or purchase our Services.	As above.
Usage Data	Includes browsing history, clickstream data, search history, access logs, information regarding your interactions with our websites, mobile apps and other Services and our marketing emails and online ads, and other and other usage data related to your use of the Services, such as language and preferences, in-game purchases, game-play statistics, scores, persona,  achievements, rankings, time spent playing, click paths, game profile, preferences and friends, as well as your comments, posts and interactions in forums and communities.	As above
Inferences	Includes inferences drawn from other personal information that we collect to create a profile based on your account and activities, that reflect your preferences, characteristics, behavior, attitude and abilities related to the Services.	As above

 

California Residents’ Rights. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Do-Not-Sell. California residents have the right to opt-out of our sale of their personal information. We do not sell personal information about California residents. ]

Requests to Delete. Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.

Request to Know. California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

• categories of personal information collected;
• categories of sources of personal information;
• business and/or commercial purposes for collecting and selling their personal information;
• categories of third parties/with whom we have disclosed or shared their personal information;
• categories of personal information that we have disclosed or shared with a third party for a business purpose; and
• categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
• California residents may make a Request to Know up to twice every 12 months.

Submitting Requests to Know and Delete. Requests to Know and Requests to Delete may be submitted online or by email at info@secretmode.games. 

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above email address) and verify your access to the registered email address for your account, in order to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us in writing at the contact information set forth above, in Section 13. Contact Details; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. We will respond to verifiable requests received from California residents as required by law.

Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Financial Incentives. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time and may not be included in such incentives without their prior informed opt-in consent. Where we offer any financial incentives under the CCPA, we will notify you in advance of the material terms of such incentives and your related rights, before we obtain your consent to such incentives.

To exercise any of the above rights, please contact us and submit the required verifying information, by emailing us at info@secretmode.games.

If you are in Australia:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at info@secretmode.games .

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at info@secretmode.games.

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the service.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the service, including social media integration and in-Game purchases.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

 

If you are in Brazil:

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us at info@secretmode.games. This may affect our provision of the service to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the service for any purpose without first obtaining parental/guardian agreement to this privacy policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact us at info@secretmode.gamesif you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES AND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

 

If you are in Canada:

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at info@secretmode.games. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this privacy policy.

If you live in Philippines:

Minimum Age

You must be at least 18 years of age to be able to use the service.

Your Rights

You are entitled to the following rights:

• Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
• Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
• Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
• Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
• Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

• collecting and processing your personal information as described in the section “What personal data about you do we use, and why?” above;
• sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
• transferring or storing your personal information in destinations outside the Philippines as described in the sections “Who do we share your personal data with?” and “Does your personal data ever go to other countries?” above.

 

If you are in South Korea

We provide your personal information to third parties as described below:

Name of Recipient (and contact information)	Types of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient
See above	See above	See above	See above

 

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee	Description of Delegated Services
See above	See above

 

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)	Country to which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
See above	See above	See above	See above	See above	See above

 

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information  detailed in section “Data Retention” are required to be retained pursuant to the following laws:

 

Act on the Consumer Protection in Electronic Commerce, Etc.	Article 6 of the Act on the Consumer Protection in Electronic Commerce	In an electronic commerce or a mail-order sale: ·       Records regarding labelling and advertising (6 months) ·       Records regarding execution or withdrawal of a contract (5 years) ·       Records regarding the payment of a price and the supply of goods and services (5 years) ·       Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act	Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act	·       Log records, IP address (3 months) ·       The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc.  We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information.  Specific considerations are as follows:

 

• whether the additional use/provision is related to the initial purpose of the collection;
• whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
• whether the additional use/provision unfairly infringe on the interests of the data subject; and
• whether the necessary security measures such as pseudonymization or encryption were taken.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

• Data Protection Department, responsible for the management and safety of your personal information
• Telephone: +44 114 2426766
• Email: info@secretmode.game

 

If you are in Thailand

By accepting this notice, you acknowledge that you have read, understood, and agree to this notice. If you do not agree with this notice, you must not use the service.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the service.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

• withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;
• request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;
• request us to provide you or a third party with your personal data which is stored by us in a machine-readable format; and/or
• lodge a complaint to a relevant authority.

 

Where you wish to make such requests, please contact us at info@secretmode.games.

 

 

Cookie Notice

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, gaming performance and use of the Services. We may combine this “activity information” with other personal information we collect about you. Generally, we use this activity information to understand how our Services are used, track bugs and errors, provide and improve our Services, establish matchmaking, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes. 

Below is a summary of these activities. For more detailed information about these mechanisms and how we collect activity information, see our Cookie Policy (https://wearesecretmode.com/cookie-policy). In addition to our usual cookies contained within our Cookie Policy, the following are also included on the website for the Game:

Cookie	Purpose/ Third Party Access	Duration
Google Analytics (GA4) access	This cookie is used for data collection related to the device/browser, and on-site/app activities like user-agent, referrer & https cookies to track visits to our website and interactions on the website. We use the information for benchmarking purposes to monitor the performance, analyse the success of the marketing campaigns and products, improve the content, and enhance the customer experience. Privacy Policy – Privacy & Terms – Google	1 year 1 month
_ttp	TikTok set this cookie to track and improve the performance of advertising campaigns, as well as to personalise the user experience. TikTok Platform Cookies Policy | TikTok	1 year 24 days
_fbp	Facebook sets this cookie to store and track interactions. Meta Cookies Policy | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy	3 months
_tt_enable_cookie	Tiktok set this cookie to collect data about behaviour and activities on the website and to measure the effectiveness of the advertising. TikTok Platform Cookies Policy | TikTok	1 year 24 days
_ttp	TikTok set this cookie to track and improve the performance of advertising campaigns, as well as to personalise the user experience. TikTok Platform Cookies Policy | TikTok	1 year 24 days
lastExternalReferrerTime	Detects how the user reached the website by registering their last URL-address. How we protect your privacy | Usercentrics Privacy Policy	Never
lastExternalReferrer	Detects how the user reached the website by registering their last URL-address. How we protect your privacy | Usercentrics Privacy Policy	Never
wpEmojiSettingsSupports	WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly. Cookie Policy | WordPress.org	Session
tt_sessionId	Used by the social networking service, TikTok, for tracking the use of embedded services. Session ID is a randomly generated number that temporarily stores the session cookie. This cookie stores information such as the user’s input and tracks the movements of the user within the website. There is no other information stored in the session cookie. TikTok Platform Cookies Policy | TikTok	Session
tt_pixel_session_index	Used by the social networking service, TikTok, for tracking the use of embedded services. A tracking pixel is an HTML code snippet which is loaded when a user visits a website or opens an email. It is useful for tracking user behavior and conversions. With a tracking pixel, advertisers can acquire data for online marketing, web analysis or email marketing. With log file analysis, long data evaluation or using appropriate analytical tools, this data can be used for different purposes, for example retargeting. TikTok Platform Cookies Policy | TikTok	Session
tt_appInfo	Used by the social networking service, TikTok, for tracking the use of embedded services. TikTok Platform Cookies Policy | TikTok	Session

 

Log Files. We collect certain activity information from log files. Log file information is automatically reported by your browser or mobile application to our servers when you access our Services. We record certain information from these log files, including web requests, IP address, browser type and version, language information, referring and exiting URLs, links clicked, pages viewed and other similar information.

Cookies. Are small files with a unique identifier that are transferred to your browser through our Services. They allow us to remember Users who are logged in, to understand how Users navigate through and use our Services, and to display personalized content and targeted ads (including on third-party sites and applications).

Clear GIFs, pixel tags and web beacons. These are tiny graphics with a unique identifier, similar in function to cookies that we use to track the online movements of Users of our Services and to personalize content. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.

Anti-Cheat and fraud prevention. Providing a fair gameplay environment is important to us. We prohibit cheating, hacking, account stealing, and any other unauthorized or fraudulent activity when using our Services. In order to detect and prevent fraud and cheating, we may use anti-cheat and fraud prevention tools, applications, and other technologies. When you use our Services, such technologies may create a machine “fingerprint” or “hash” of your machine components, and collect information about you, including information about your browser, device, activities, game identifiers, and operating system.  

Analytics Tools. We may use internal and third-party analytics tools to collect and aggregate activity data and other data across multiple channels.

Interests-based advertising. Our Game and other Services may include third party advertising. In some cases the advertising content may be tailored to your perceived interests by our advertising services vendor. This is in order that advertising can be served to you which may be more interesting to you.  You can opt-out of such interest-based advertising , such as by utilising in-Game privacy settings or the cookie preference manager for our websites.