DARK MATTER PRIVACY NOTICE

Last updated: January 31, 2025

This notice explains how Dark Matter Ltd (referred to as “we” in this notice) collects, stores, uses, or otherwise processes the personal data of end users of our Services as defined below (referred to as “you” in this notice), and what rights you have if we are processing your personal data.

In this notice, “Services“ refers to our Games, Websites, and any related services or properties we control; “Games” refers to the games, applications, and other products we publish; and “Websites” refers to websites and other online properties we control, including this website. The expression “your data” is used when referring to personal data that relates to you as an identified or identifiable individual.

This notice applies to all our Services, unless a separate notice is supplied with a particular Game or other Service. Where a separate notice is supplied, that notice applies instead. In addition, our Services may link to or otherwise allow you to navigate to properties controlled by third parties. Please consider that this notice does not apply to properties controlled by third parties and that the operators of those properties may collect and use your data following their own policies.

It is important that you read this notice before accessing or using the Services so that you are aware of how and why we may use data relating to you. In addition to this notice, we encourage you to carefully review our Terms of Service, which govern your use of our Services.

1 Data controller

By “data controller”, we mean an entity that determines how and why personal data is processed. With regard to the activities described in this notice, we are the data controller. Our company name is Dark Matter Ltd. Our address is Keilaranta 7, FI-02150 Espoo, Finland.

While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 6 of this notice.

2 Contact information

In matters related to this notice, you can reach us by email at privacy@darkmatterplay.com.

3 Why is your data processed and on what basis?

To perform our contract with you, your data may be processed as necessary to:

  • create and maintain an account for you in our Games or other Services where applicable,
  • enable you to play our Games or use our other Services,
  • provide the correct version of our Games or other Services to you (for example, selecting an appropriate language version for you),
  • where available, enable you to communicate with other users in our Games or other Services (for example, by providing or managing chat, communities, forums, or other similar features within the Services or on third-party platforms),
  • send you service-related communications (for example, technical notices, security alerts, or administrative messages), or
  • verify and fulfill your purchases or other transactions in our Games or other Services.

Based on our legitimate interest to make our Services the best they can be, your data may be processed to:

  • operate and maintain our Services (for example, by making sure our Services are secure and function as intended),
  • troubleshoot or debug any bugs, errors, or other issues in our Services,
  • measure and analyze the use of our Services or data collected through our Services (for example, to discover trends or other insights or to inform our operations),
  • create data that is not identifiable to you (for example, aggregate data), which may then be used and shared freely,
  • conduct surveys or other research to learn more about our users, or
  • improve our current Services or develop new Services.

Based on our legitimate interest to make sure you have the best possible user experience in our Games, your data may be processed to:

  • personalize your gameplay experience in our Games based on your activity,
  • provide you with offers and rewards in our Games based on your activity,
  • where available, enable your gameplay across multiple devices (for example, by allowing you to connect a third-party account with our Games for that purpose),
  • where available, provide social features (for example, clans, matchmaking, or leaderboards) or competitions, promotions, or events in our Games or other Services,
  • handle your support requests or otherwise manage our relationship with you, or
  • send you service-related communications (for example, technical notices, security alerts, or administrative messages).

Based on our legitimate interest to make sure our Services are a fair and safe environment for all users or, where applicable, based on a related legal obligation, your data may be processed to:

  • ensure that you have access to content and features which are appropriate for you, for example based on your age,
  • moderate and monitor the use of our Games or other Services (including any messages sent through the Services), either automatically or manually, or
  • ensure that our Terms of Service are followed.

Based on our legitimate interest to promote our Services and to make sure we reach interested audiences, your data may processed to:

  • keep track of installations of our Games (including the source of each install),
  • measure, analyze, and improve the effectiveness of our advertising (including our advertising outside of our Services),
  • send you communications about offers, rewards, events, or other news related to our Services or other operations,
  • show or not show our ads to you based on your activity (including by limiting the number of times you see our ads), or
  • advertise our Games or other Services to audiences who our advertising partners believe have interests similar to yours.

Based on our legitimate interest to provide you with relevant ads in our Games and to fund our Services so that we can keep providing them to you, your data may be processed to:

  • show ads to you in our Games, either from us or our advertising partners,
  • keep track of your activity in our Games to learn about your interests and improve the advertising in our Games, or
  • personalize the ads you see in our Games to make them more relevant to you.

Based on our legitimate interest to safeguard our operations, your data may be processed to:

  • detect, investigate, or prevent fraud or fraudulent or otherwise unauthorized behavior,
  • audit our operations or processes (for example, to verify that they function as intended and according to regulatory or contractual requirements), or
  • establish, exercise, or defend our legal rights to the extent permitted by applicable laws and regulations.

With your consent, your data may be processed:

  • to share it with our advertising partners (specified when asking for your consent) for their independent use under their own privacy policies, which may include creating a personalized ads profile about you, selecting personalized ads for you, measuring ad performance, generating audience insights, and other uses or
  • for other purposes explained to you when we ask for your consent (for example, using your GPS location to provide location-based experiences).

Finally, your data may be processed as necessary to:

  • comply with legal obligations which we believe apply to us (including accounting and tax requirements, requirements to limit access to our Services, and requirements to provide information to competent authorities upon due request) or
  • protect your vital interests or the vital interests of another person.

In addition, your data may be processed for additional purposes which are compatible with any of the purposes listed above.

Your data is not used to make automated decisions which significantly affect you. By an “automated decision”, we mean a decision made by an information system without any human intervention.

3.1 Advertising

Advertising funds our Services and enables us to make our Games available free of charge. In our Games, we show our own ads and also ads from third parties. We also advertise outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes.

Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses and other identifiers. An “Advertising ID” is an alphanumeric string of digits typically provided by a device or its operating system. It is consistent across applications installed on the device, even if those applications are from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices. Equivalent identifiers may exist on other operating systems and devices.

Advertising IDs are used for interest-based advertising and other advertising related purposes as a means of establishing a pseudonymous identity which remains constant from one application or other property to another. You can control the extent to which your Advertising ID is used in this manner. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can choose to not “allow apps to request to track” on iOS devices or to “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them to your desired state on each of your devices individually. Our Games may offer additional options to opt in to or out of advertising related uses of your data. Where available, these options are found in the game settings, and you may be prompted to select your preferences. It may take some time for your selection or any updated settings to take effect. Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads, but the ads you see may be less relevant to you.

For more information on mobile privacy settings, we encourage you to refer to resources such as the Network Advertising Initiative’s guide on mobile device opt outs (link). However, please consider that we do not maintain those resources and cannot guarantee their accuracy.

When you see ads in our Games, we may share your Advertising ID and IP address, along with information about the game and your device, with our advertising partners. Our advertising partners may also collect information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information on our advertising partners and their privacy policies, please refer to section 6 of this notice.

When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID and data about user engagement with our Services, have determined that you may be interested in our Services. Ad networks may also use your data to:

  • limit the number of times you see our ads,
  • inform users who have previously played our Games about new content, updates, or other news related to those Games, or
  • refrain from showing our ads to users who already play the Game being advertised.

In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services.

For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as views, clicks, or installs generated by an ad. This measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as conversion pixels inserted into ads. It is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.

3.2 Cookies and similar technologies on our Websites

Like most websites today, our Websites may use cookies or similar technologies (for example, local shared objects or web beacons).

A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit (“first-party cookies”) or a third party involved in providing content, functionality, or services such as analytics or advertising for the website you visit (“third-party cookies”). Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or store your preferences.

When you visit our Websites, you may be prompted to make a choice regarding cookies. Some cookies may be strictly necessary for the operation of the Websites. These cookies will be used and stored on your device independent of your choices regarding other types of cookies. You can also control the use of cookies using your browser or device settings, 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.

4 What data is processed?

The following data relating to you may be processed:

  • your name, email address, or other contact information if you have provided them to us (for example, when creating an account),
  • your age or information about when you were born,
  • online identifiers such as your in-game alias, IP address, identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID,
  • technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
  • your coarse location (for example, country, state, or city), inferred from your IP address,
  • information about your use of the Services (for example, information about your progress or purchases in our Games or other Services, your use of an account you have with us, your visits to our Websites, or your interactions with ads in our Games),
  • information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
  • crash logs or other information related to bugs, errors, or other issues you encounter in our Services,
  • inferences made based on your activity in our Services (for example, about the content you might enjoy),
  • messages or other communications you send to us or through the Services or related communities managed by us on third-party platforms (for example, your chat messages in our Games or emails you send to our support team, or messages you post to official community groups for our Games),
  • if you choose to connect a third-party account (for example, a social media account) with our Services, information received from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends information to provide social features),
  • if you make purchases in our Games or other Services, information received from third-party payment service providers to validate those purchases (note that we do not receive your credit card or other payment method information when you make purchases in our Services),
  • if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
  • information about your choices regarding your data (for example, any consents you may have given or withdrawn),
  • any other information you choose to submit to us through our Services or otherwise, and
  • with your consent, other information explained to you when asking for your consent (for example, your GPS location for location-based experiences).

We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

5 Where is your data collected from?

Data relating to you may be collected from the following sources:

  • directly from you when you submit it to us (for example, when registering an account with us, sending support enquiries to us, or responding to our surveys),
  • directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
  • companies that distribute or publish our Games, which may include both our corporate group companies and third parties (for example, platform operators),
  • if you interact with ads in our Games or our ads outside of our Services (for example, on third-party websites or applications), from our advertising partners involved in the delivery and measurement of those ads,
  • if you choose to connect a third-party account (for example, a social media account) with our Services, from the third-party account provider,
  • if you participate in official community groups for our Games on third-party platforms, from those community groups or the platform provider,
  • if you make purchases in our Games or other Services, from the third-party payment service provider involved in those transactions, or
  • with your consent, from other sources explained to you when asking for your consent.

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 data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games (or to utilize the privacy settings of those third-party services to control the extent to which your data is shared to us), to use options provided to you in our Games to manage your preferences regarding the use of your data for advertising purposes, to use your device settings to reset or control the use of your Advertising ID or to toggle features such as push notifications or location tracking, or disable some or all cookies from your browser settings. At the same time, please be aware that our Websites may not respond to “Do Not Track” signals in HTTP headers.

6 Who is your data shared with?

Your data may be shared with third parties to achieve the purposes described in this notice. This may include sharing data with the following types of recipients:

  • other companies in our corporate group, for example where they help us develop or operate our Games or other Services,
  • persons or companies outside of our corporate group that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services),
  • payment service providers that facilitate payments for purchases made in our Games or Services and may process you data (including your payment method information) independently of us,
  • other partners we work with while providing the Services (who may process your data independently of us), including the advertising partners referred to later in this section,
  • prospective or actual buyers (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
  • competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation,
  • any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests, or
  • with any other person or entity with your consent.

Specifically, we share all data collected from or otherwise for the purposes of our Games with our parent company Rovio Entertainment Limited (“Rovio”), who develops and operates the Games we publish. Rovio also operates the advertising services for our Games, which means that data used for advertising purposes may be shared with Rovio’s advertising partners listed here.

Due to the nature of our arrangement with them, Rovio acts as a controller of your data jointly with us and may process your data for the purposes outlined in section 3 of this notice. Where it is stated that we process your data based on our legitimate interest, Rovio has a corresponding legitimate interest of their own to process your data for the same purpose. We have entered into an agreement with Rovio to determine our and their respective obligations with regard to your data. In that agreement, we have agreed to provide you with this information about our arrangement with Rovio, whereas Rovio has agreed to be responsible for securing your data and enabling you to exercise your rights (as explained below in section 9) with regard to the data collected from or in connection with our Games and other Services. More information on how Rovio may process your data, and how to exercise your rights, can be found in their Privacy Notice.

In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and information used to provide social features such as clans or leaderboards. You should expect this kind of information to be publicly available and not submit or make available any information which you wish to remain private.

Your data may be transferred outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, a number of servers used for hosting your data are located in the United States, and some of our group companies or the service providers used to provide the Services may be located outside of the EU and the EEA. These countries may have data protection laws that differ from the laws of your home country. In these cases, appropriate safeguards will be provided to protect your personal data. This may include applying the standard contractual clauses approved by the European Commission for transfers of personal data or other safeguards recognized by applicable laws and regulations. Upon request, we can provide you a copy of the European Commission’s standard contractual clauses and further details on the applicable safeguards.

7 How long is your data kept?

Your data will be kept for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. Inactive accounts or other data in our Games or other Services may be periodically deleted or de-identified.

After the applicable retention period, your data will be either deleted or de-identified or, if neither deletion nor de-identification is possible (for example, due to data being stored on a backup server), isolated from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data). We will not attempt to re-identify you when using such de-identified data.

8 How is your data kept secure?

Your data is secured with measures that provide your data a level of security appropriate for the degree of risk involved with the processing activities described in this notice. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures employed vary, but typically include, for example, encryption in transit, pseudonymization of identifying data where feasible, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents. Please consider that, despite our efforts to secure your data, the internet is an inherently insecure environment and we cannot guarantee absolute security for your data.

9 Your rights

If we are processing your data, you have the right to:

  • access, correct, or request the deletion of your data,
  • request us to restrict our processing of your data,
  • object to our 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 machine-readable format.

Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Where applicable, you may manage your advertising preferences in the game settings under “Terms & Privacy” or a similarly named option. Please be aware that we may continue processing your data despite your withdrawal of consent, if we have a lawful basis for doing so.

To access your data in our Games or to request its deletion, please use the automatic tools provided in our Games. You will find them in the game settings under “Terms & Privacy” or a similarly named option. On the same page, you can also opt out of our personalized offers, where applicable. These tools are specific to each game, which means you should submit your request in each game separately. Please use these tools to submit requests. This helps us validate, process, and fulfill your request more quickly and reliably.

To exercise any of your rights, you may also contact us at privacy@darkmatterplay.com. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide sufficiently detailed information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf. While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations.

Should you be unsatisfied with how we fulfilled your request, you may appeal the decision you have received using the internal appeal process we have established. To do so, please submit a new request after you have received a decision from us on your earlier request. In the new request, you should state that you wish to appeal an earlier decision and that you are asking for the matter to be considered in accordance with our internal appeal process. You may be asked to provide information about the earlier request and decision that reasonably allows us to identify them. Once you have submitted the appeal and provided information to adequately identify the earlier request and decision, we will process youR appeal as soon as practicable.

Finally, you always have the right to lodge a complaint with your local data protection authority (such as the Office of the Data Protection Ombudsman in Finland) regarding our processing of your data. However, we ask that you reach out to us first to allow us to address your concerns.

Note that if your request relates to information about a payment method or other transactional data about a purchase made in our Games or other Services, you should directly contact the payment service provider through which you made the payment, as they will have processed the transaction independently of us.

10 Children

Our Services are generally intended for adults and designed primarily with adults in mind. When you access and use our Services, we may ask you to confirm your age to us or your age may otherwise become known to us. If we discover that you are a minor or do not meet an age threshold we apply, we may take steps to limit, suspend, or terminate your access to the Services where we believe that to be necessary due to applicable regulatory or platform requirements or to provide you with an appropriate experience. If your access to the Services is not suspended or terminated, we will limit the use of your personal data to what is necessary for the internal operation of our Services and other uses permitted by applicable laws, regulations, and platform policies. This may include removing access to certain parts or features of the Services.

11 Changes

We may update this notice from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.