1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products and services developed and/or published by Soccer Manager Ltd. (“Soccer Manager” / “we” / “us”) and as further detailed below. Our registered office is at 4th Floor 33 Park Place, Leeds, West Yorkshire, England, LS1 2RY. We are a company registered in England and Wales, with company number 05271374.
We do not use our Online Services to knowingly solicit information from, or market to, those under the age of 13.
- 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 data we hold about you.
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 data 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.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following personal data from you when you use our Online Services (together, the “Submitted Information”):
Information provided by you when using a Game or Community
- Your mobile device’s unique device ID (e.g. for our mobile Games);
- Your age bracket (e.g. above or below 18);
- Your Facebook User ID;
- Your user/account avatar;
- Your user/account profile picture;
- Your user/account username;
- Your name;
- IP address;
- MAC address;
- System, browser and device settings and information (including make, model and operating system of your device, device properties such as orientation, mobile network operator, Games played, country and locale settings, network connection speed and type and browser type).
- Advertiser and platform (e.g. Apple or Google) IDs, which are unique to you but which do not reveal your name.
- Your email address;
- Your user/account ID; and
- ‘Events’ related to your gameplay in our Games, such as your achievement of a milestone, the occurrence of other particular events during your gameplay (such as completing a tutorial, game level, making a purchase or viewing an advertisement).
Information provided by you when using the Communities or that may be provided by you when you contact us for support
- Your name;
- Your Steam ID / Steam profile identifier / display name or your username/identifier on another platform or account;
- Your email address;
User-generated content and score information hosted and displayed in our Online Services
In some Online Services, the provision of User Content (e.g. leaderboard / ‘scoring’ information between users and/or in a public manner within the Online Service or similar) (“Leaderboards”) is a significant or essential part of the functionality and/or gameplay or user experience and may be posted automatically. We may, but we are not required to, provide you with a means to still play / use the Online Service without taking part in this functionality (e.g. without having your information on the leaderboard) within the Online Service. You can also contact us to enquire further about User Content at [email protected] Please be aware that it may not be possible for us to turn off this type of User Content functionality for you within the Online Service without affecting your user experience.
We cannot control the wider dissemination via the public internet of personal data that you may choose to post, or make available, in User Content.
Information about your activities and cookies
We may collect technical information about your use of our Online Services through the use of tracking technologies and analytics.
- Your IP address and MAC address;
- User ID;
- Device country;
- Advertisements viewed and clicked;
- Time, date and install source of your first download (e.g. from a clicked advertisement);
- Purchase transaction types and spend made in an Online Service;
- Session start, duration and end timings;
- Identifying information about crashes and defects;
- Device information (e.g. device identifier and browser);
- Game results, progress and timings; and
- Page usage (e.g. buttons clicked, screens viewed).
This also includes the use of ‘cookies’ and similar technologies such as SDKs and APIs in our mobile games.
Cookies and similar technologies
Third party vendors and partners are used by Soccer Manager when conducting our Analytics and for our other data processing activities set out in this policy, including in relation to our advertising purposes. The following cookies and similar technologies are used on the Online Services (but differ between each Online Service) and you can find out more information about their processing activities through the links provided:
Cookie or SDK Name / Title
Google Analytics is a service offered by Google that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sales.
We may use a Google AdMob SDK to enable us to serve advertising to you. Google’s use of the SDK enables Google to serve you with more relevant advertising based on your experiences on our services and others.
The Bidstack service enables advertising to be served to you within certain of our Games. Bidstack’s use of the SDK may enable Bidstack to serve more relevant advertising to you.
Unity Ads SDK
This SDK enables advertising to be served to you within certain of our Games. Unity’s use of the SDK may enable Unity to serve more relevant advertising to you.
This SDK enables advertising to be served to you within certain of our Games. AdColony’s use of the SDK may enable AdColony to serve more relevant advertising to you.
This SDK enables advertising to be served to you within certain of our Games. AppLovin’s use of the SDK may enable AppLovin to serve more relevant advertising to you.
This SDK enables advertising to be served to you within certain of our Games. IronSource’s use of the SDK may enable IronSource to serve more relevant advertising to you.
This SDK enables advertising to be served to you within certain of our Games. Tapjoys’s use of the SDK may enable Tapjoy to serve more relevant advertising to you.
This SDK enables advertising to be served to you within certain of our Games. Vungle’s use of the SDK may enable Vunlge to serve more relevant advertising to you.
We may use Facebook SDKs and cookies to allow us to: (i) serve more relevant advertising to you; (ii) understand how users are using and interacting with our Online Services; and (iii) to enable you to log into or connect the Online Service with your Facebook user account.
We may use this SDK to help us understand how you use our Online Service so that we can deliver better experiences and improve our Online Services. We may also use this SDK to help us to understand which advertising publisher referred you to us.
Google Play Services API
We may use this API to able you to log into / connect your profile in our Online Service with your Google account.
We may use a Twitter SDK in order to connect your Online Service profile with your Twitter profile (for example, so that you can more easily ‘tweet’).
We may use this SDK to help us understand how you use our Online Service so that we can develop and improve our Online Services.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/. To opt out of being tracked by Google / Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
To opt out of being tracked by advertising providers you can access a general opt out at http://www.networkadvertising.org/managing/opt_out.asp.
Information about you collected from third parties
(“Third Party Account Information”)
If you choose to access or log into our Online Services via a third party social media platform such as (without limitation) Facebook, we may collect and store personal data and other information made available by that third party platform, such as your profile username, profile picture, user ID and public information about your friends, provided that you have expressly agreed to the use of such information within the relevant Online Service.
We may also collect technical information in order to ensure that our Online Service connects correctly with your social media user account. This information may be obtained via a Facebook cookie or other similar device in our Online Service. The third party platform is responsible for obtaining your consent before sharing such data with us.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Online Services to you
Where we process your personal data for Leaderboards, or other User Content, in our Online Services, we also rely upon our legitimate interests as a legal basis for undertaking that processing, being our commercial interests in providing an enhanced experience in our Online Services (though, depending on the nature of our particular Online Service, the Leaderboard or User Content may be a part of the core functionality of the Online Service).
To enable purchases
If you make purchases through the Online Services, your order and Game Information and Contact Information may be processed so that you can access these features within the Online Service.
Moderation and preventing spam
Certain Game Information and User Content which you supply through our Online Service may be shared with other users of the Online Service. In some cases you may be able to select specific recipients (for example, if you are sending a forum post, or a private message, to a particular forum or individual) and then only those recipients will receive it, however in all other cases, your information may be made publicly available.
Spam is a problem for many forums and websites. In order to minimise this we may use IPS Spam Defense Service to check that any new registration is not spam. In order to do this certain information may be provided to IPS Spam Defense Service for the sole purpose of checking that it is not spam. You can find out more about how the IPS Spam Defense Service uses this information on their website available here: https://invisioncommunity.com/legal/privacy.
To respond to your enquiries and requests for support
As part of this we may also share this Submitted Information with the developers of the Games that we publish and with our vendors who may assist us with managing support queries.
For advertising purposes
We may process your Submitted Information so that we can serve untargeted advertisements to you in the relevant Online Service. For this purpose, your personal data is processed on the basis of our legitimate interests, being our commercial interests for advertisement-supported services.
For some of our Online Services, we may process Submitted Information to show you more relevant advertisements (on our Online Services or on third party services), based on your perceived preferences, for our products and services or for other third party products and services. Where we process your Submitted Information for this type of advertising, we rely upon your consent for our data processing. You have the right to withdraw this consent at any time by letting us know by email to: [email protected].
For the purposes of serving you with more relevant advertising in our Online Services and on other third party services and platforms, we work with advertising networks including the following:
- Facebook (https://www.facebook.com/privacy/explanation)
- Unity (https://unity3d.com/legal/privacy-policy)
- Bidstack Ltd (http://www.bidstack.com/)
- Google (https://policies.google.com/privacy)
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
We will not process your information for the purposes of targeted 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. After you have given your consent, you may withdraw it at any time.
For some of our Online Services, Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data (this might be, for example, aggregated visitor numbers).
Please note that we use third party providers of adverts and the advert content is provided by these third parties and not Soccer Manager. Soccer Manager does not control and is not responsible for third party advert content. If you have concerns about specific advert content, you can contact us at: [email protected].
To understand which publisher of our advertisements referred you to us
We process personal data, including without limitation the Game Information and Analytics, so that we can understand which publisher of our advertisements referred you to us and, for example, to which advertisement and/or advertising or marketing campaign that referral related. This information is helpful for our purposes of understanding which marketing and advertisement activity is successful. We process this personal data on the basis of our legitimate interests, being our commercial interests in promoting and improving our Games and their commercial success (including by improving our advertising and marketing).
To acquire new users and engage current users
We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.
- We may also process this information to pursue our legitimate interests of acquiring new users for our Games.
- Your Steam ID / Steam profile identifier / display name or your username/identifier on another platform or account;
To prevent fraudulent or illegal activity
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).
To help us to improve the Online Services and help us fix any problems
We may process information about you (being the Submitted Information or any part thereof) so that we can analyse and improve our Online Services and also for us to develop new Online Services or new parts thereof.
This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Games 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 or problems with the Online Services.
To help us to understand your usage of the Online Services
We may process information (being the Submitted Information or any part thereof) to understand how users use our Online Services, and to compile statistical reports regarding that activity, as well as understanding how users progress within a particular Online Service such as a Game. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems (such as when users may frequently be ‘stuck’ in a particular Game level) and to improve our future products and services.
To keep you up to date
Where you have consented, or where it is otherwise lawful for us to do so, we use your Submitted Information to send you emails in order to keep you informed about our news and products. You can withdraw your consent at any time by letting us know by email to: [email protected].
Push notifications about our Game and similar notifications
Where you have consented or where it is otherwise lawful to do so, we may use your Submitted Information to send you ‘push notifications’ or in-service notifications (for example, on your device and in relation to the Game). The third party platform (i.e. your device provider such as Apple) is responsible for obtaining your consent to activities such as push notifications.