Privacy Policy
PRIVACY POLICY
Thank you for playing our game! In order to do so, we need to know a few things about you
and your device. In this Privacy Notice, Flowstate Games Ltd (“Flowstate” or “we”) describes:
the personal data we process about,
the purposes we use your personal data, and
the rights you have concerning your personal data.
This Privacy Notice applies to Flowstate’s games, websites and related services or properties
we control (“Services”). It is important that you read this Privacy Notice before accessing or
using our Services to understand why and how we may process data from which you can be
identified (“your data”).
We may update this Privacy Notice every now and then by posting a new version on
flowstate.games/privacy. If we make any material changes, we will notify you by posting a
notice in the service prior to the change becoming effective. Your continued use of the service
after that effective date will be subject to the new Privacy Notice.
CONTACT US
Flowstate Games Ltd.
Kalevankatu 13 A 2, 00100 Helsinki, Finland
If you have questions about data protection or your data, you can reach us by e-mail at:
contact @flowstate.games
1 DATA CONTROLLER
“Data Controller” means an entity determining how and why personal data is processed. With
regard to the activities described in this Privacy Notice, we are the Data Controller of your
data.
While operating the Services, we may share your data with partners we work with, and some
of these partners are data controllers independently of us and determine how and why they
process your data. Please see section 6 of this Privacy Notice for more information.
2 WHAT DATA WE COLLECT AND WHERE
DATA YOU PROVIDE US
• Your contact information (such as name and email address and other provided
information when registering an account to our Services (“Account”)).
• Your messages or other communications you send us or through the Services (such as
chat logs and user support tickets).
• Your content preferences or other information you submit to us (if you subscribe to
our communications).
• Any other information you choose to give us.
DATA WE COLLECT AUTOMATICALLY (WHEN YOU ARE PLAYING OR USING OUR OTHER
SERVICES)
• Information about your use of the Services (such as information about your progress
in our game, your visits to our website, or your interactions with ads in our game).
• Your IP address and mobile device identifiers (such as your device ID, advertising ID,
MAC address, and IMEI).
• Data about your device, such as device name and operating system, browser type and
language.
• With your consent, other information explained to you when asking for your consent
(for example, your GPS location for location-based experiences).
• Crash logs or other information related to bugs, errors, or other issues in our Services.
DATA WE COLLECT FROM OUR PARTNERS (SOME OF THESE FEATURES ARE PLANNED BUT
NOT YET IN USE)
• Data we receive if you link a third-party tool with the Services (such as Facebook or
Google).
• Demographic data (such as determining the coarse location of your IP address).
• Data to fight fraud (such as refund abuse in services or click fraud in advertising).
• If you make purchases in our Services, information we receive from third-party
payment service providers to validate those purchases.
• Data from platforms that the Services run on (such as to verify payment).
• Data for advertising and analytics purposes so that we can provide you with better
Services.
3 WHY DO WE COLLECT YOUR DATA?
Providing data to us is not mandatory. However, we are unable to provide the Services, or
some parts or features of the Services, without processing your data. If you use our Services, we will collect your data for some or all of the purposes described below, depending on the Services you decide to use and your choices when using them.
To perform the contract, we may collect and process your data necessary to
• enable you to use our Services, for example, play our game,
• provide and deliver products and Services you request,
• respond to your comments and questions and provide user support,
• send you messages and information related to the Services,
• enable you to communicate with other users of the Services, and
• verify your purchases or other transactions in the Services.
To provide and maintain good Services to our users, we have a legitimate interest in collecting
and processing your data necessary to
• operate and maintain our Services,
• update and develop user profiles,
• develop and improve the Services and user experience,
• handle your support requests or otherwise manage our relationship with you,
• customize your service-experience (like language version), and
• provide you offers in the Services.
Based on our legitimate interest in promoting and funding our Services and providing you with
relevant ads in our Services, we may process your data to
• send you communications related to our Services,
• track your activity in our Services to learn about your interests and improve the
advertising in our Services,
• show ads in our Services, and
• request our advertising partners to advertise our Services to audiences that they
believe have similar interests to yours
To keep the Services safe and fair, to fight fraud and ensure the acceptable use of our Services,
we have a legitimate interest in processing necessary data to
• analyze and monitor the use of our Services and ensure that our Terms of Service are
followed, and
• moderate and monitor the use of our Services (including any messages sent through
the Services), either automatically or manually.
With your consent, we may process your data to
• send you newsletters or other similar communications if you have subscribed to them,
and
• other purposes explained to you when we ask for your consent (for example, using
your location).
Finally, we may process your data as necessary to:
• comply with legal obligations that we believe apply to us, and
• protect your vital interests or the vital interests of another person.
In addition, we may process your data for additional purposes that are compatible with any
of the purposes listed above.
We do not use your data to make automated decisions that significantly affect you.
4 COOKIES
Like most online services today, we and our partners may use cookies or similar technologies
to provide and personalize the Services, analyze the use of the Services, target advertisements
and prevent fraud. Cookies and similar technologies allow us and our partners to store their
preferences and track your activities within the Services. Note that our partners may operate
under their own privacy policies.
If you wish to limit behaviourally targeted advertising, you can control the use of cookies, for
example, by disabling some or all cookies or configuring your browser or device to notify you
when cookies are being set. However, please consider that disabling cookies may affect your
ability to use the Services.
5 AGE LIMIT
In accordance with our Terms of Service, you must represent that you are at least 13 years
old. However, we are not able to verify the specific age of individual users of our Services. If
you are under 13 years of age, you should not provide your personal data to us or use the
Services.
If we discover we’re processing the personal data of a person under 13 years, we will take
appropriate measures to promptly delete the data from our records. If you have reason to
believe we hold personal data relating to a user under 13, please contact us.
6 WHO CAN SEE YOUR DATA
To achieve the purposes described herein, we may share your data with the following types
of recipients:
PARTNERS WORKING FOR FLOWSTATE
We have partners performing services for us. These partners process your data only at and
according to Flowstate’s instructions in order to provide the Services. These external services
can be, e.g., hosting, user support, advertising, analytics, and fraud prevention.
OTHER COMPANIES AND PUBLIC AUTHORITIES
In order to combat fraud and illegal activity, we may exchange data with other companies and
organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your explicit consent to comply with the law or to
protect the rights, property or safety of us, our users or others.
7 INTERNATIONAL DATA TRANSFERS
In connection with the processing activities described in this notice, your data may be
transferred to and/or processed in countries outside the European Union (“EU”) and the
European Economic Area. Because different countries may have different data protection laws
than your own country, we take steps to ensure adequate safeguards are in place to protect
your data, as explained in this Privacy Notice. Adequate safeguards that our partners may use
include standard contractual clauses approved by EU Commission and other lawful
safeguards.
8 YOUR RIGHTS AND OPTIONS
• You have the following rights concerning your data:
• access the personal data we hold about you,
• correct or request deletion of your data,
• request us to restrict the processing of your data,
• object processing of your data to the extent our processing is based on our legitimate
interests or the legitimate interests of a third party, or
• where technically feasible, request a copy of the personal data you have provided to
us in a machine-readable format.
9 YOUR OTHER RIGHTS
If the processing of your data is based on your consent, you have the right to withdraw your
consent at any time. We may, however, continue processing your data despite your
withdrawal of consent if we have another lawful basis to process that data.
To unsubscribe from our marketing communications, please use the unsubscribe link provided
in the messages we send. The unsubscribe link is typically found at the end of the message.
We will respond to all requests within a reasonable timeframe. If you have an unresolved
privacy or data use concern that we have not addressed satisfactorily, please contact us. You
may also contact your local data protection authority within the European Economic Area for
unresolved complaints.
10 HOW DO WE PROTECT YOUR DATA
In order to help ensure a secure and safe user experience, we are continuously developing
and implementing administrative, technical and physical security measures to protect your
data from unauthorized access or against loss, misuse or alteration. These security measures
vary but may include, for example, encryption, pseudonymization and limiting access to
systems containing personal data.
11 HOW LONG DO WE KEEP YOUR DATA
We retain your data for as long as your Account is active or as long as necessary to achieve
the purpose(s) for which your data was collected. We may periodically delete or de-identify
inactive Accounts or other data in our Services.
After the applicable retention period, we will either delete or de-identify your data. We may
continue to use data that is not identifiable to you (for example, aggregate data).
Note that if you ask us to remove your personal data, we will retain your data as necessary for
our legitimate business interests, such as to comply with our legal obligations, resolve
disputes, and enforce our agreements.