PRIVACY POLICY

At Studio Folly Pty Ltd (Australian Business Number: 44 646 712 085) (defined here as ‘We’, ‘Us’ or ‘Our’), We recognise the importance of your privacy and understand the concerns surrounding security of personal information.

This Privacy Policy sets out how We collect, use and disclose “personal information” and other “non-personal information” We have gathered about you about you in relation to Our game “Gubbins”, (“Game” which term includes the associated website: https://folly.studio).

By using our Game, you acknowledge and consent to the terms of this privacy policy.

This policy will let you know:

What information (often referred to as ‘data’) is collected from you;
How your information is used;
With whom your information may be shared;
How you can access, update, or delete your information.

We will comply with all relevant and applicable legislative requirements, and, in the event of any inconsistency, the legislative requirements will override the provisions of this document.

USER AGE LIMITS

Our games and Our website are not aimed at children under 13 years of age. Nevertheless, We acknowledge that our Game may unintentionally appeal to children.

An age gate is in place at the launch of the Game, which shall direct each user to the part of the Game that is applicable to that user’s age bracket.

We do not collect any personally identifiable information within the age gated part of Our Game for children, nor do We intentionally direct interest-based advertising to anyone under the age of 13 years.

If you believe that We have inadvertently collected information from a person under the age of 13, please contact Us at the email address below and the information will be permanently deleted. We do not permit behaviourally targeted advertising to children under the age of 13 years.

WHAT DATA DO WE COLLECT?

We collect data in three ways:

A. Data collected automatically;
B. Data you provide us; and
C. Data collected by our partners.

The basis for collecting data is “legitimate interest” under GDPR (Global Data Protection Regulation) and “to support internal operations of the game” under COPPA (Children's Online Privacy Protection Act). Any data collected is done solely for internal uses that are reasonably and directly related to your relationship with US, in accordance with the California Consumer Privacy Act (CCPA).

A. Data collected automatically

Certain data is collected automatically. This includes:

• Data about your game progress;
• Data about your device, such as device name and operating system, browser type and language;
• Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service; and
• Your IP addresses, and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI). Please note, there are ways to prevent this, which are outlined at ‘Third Party Service Providers’ below.

B. Data you provide us

We collect and store your email when you sign up for Our newsletter, or where you nominate to specifically allow Our games to collect your player name and your email. We will also keep your contact details if you contact Us for a particular purpose.

Newsletters Mail-Outs and Promotional Materials

When you opt in to join Our mailing list for the purpose of receiving Our newsletter, We will use that to provide you with direct marketing communications about upcoming games, features of Our websites and other events and promotions related to Our products.

You may unsubscribe from Our newsletter at any time. All you need to do is unsubscribe from the link in the letter, or let Us know in writing, via emailing Us at hello@follys.studio that you want to be removed.

If you wish to receive promotional information from Us, you will be asked to provide your email address to Us. This information is gathered by a third-party partner that collects and compiles that information for us so that we may undertake mail outs to large numbers of people. The third-party partner that We use to create and send promotional information is Pencilbooth. The Pencilbooth policy can be found here: https://pencilbooth.com/s/privacy

C. Data we collect from our third-party partners

To operate and manage Our services We need to use third party service providers from time to time. A list of those parties can be found in this privacy policy. The type of information We might collect from them includes:

• Data we receive if you link a third-party tool with the Service (such as logging in via Facebook, or Google);
• Demographic data (to determine the coarse location of your IP address)
• Data from platforms that the games run on; and
• Data for analytics purposes.

How do we use the data we collect?

Data collected can be personal to you or non-personal, and sometimes data that doesn’t appear to be personal can become personal if certain other facts are learned. No matter how We come to collect your data, We will always treat it in accordance with this document, and any applicable legislation.

What is Personal Information?

‘Personal Information’ is information that identifies you as an individual. This is only collected by Us if you submit it to Us directly. We note that this does not mean that the Game itself does not collect data, rather We do not collect personal information from you.

Player Feedback

If you contact Us with a comment or query, We keep a copy of any personal information you provide. This is so that We can respond to your comments and questions as a part of Our commitment to providing you with player support. If you contact Us directly for any reason, We also keep a copy of that correspondence.

What about Sensitive Information?

Sensitive information includes information about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a professional body, criminal records or health information.

We will not attempt to obtain nor record any sensitive information.

THIRD PARTY SERVICE PROVIDERS

Apart from Us, your data is accessible by Our third-party providers in the following circumstances. Our Game includes services from third-party providers such as functionalities through application programming interfaces (APIs) and Software Development Kits (SDKs). These third-party providers may access your data and operate under their own privacy policies. We encourage you to review their privacy policies (listed below) before interacting with our Game.

APIs

FIGMA: https://www.figma.com/summary-of-policy/
Unity: https://unity3d.com/legal/privacy-policy

SDKs

Apple: https://www.apple.com/legal/privacy/pdfs/apple-privacy-policy-en-ww.pdf

Google: https://policies.google.com/privacy

COLLECTION OF OTHER ‘NON-PERSONAL’ INFORMATION

Some non-personal information may be gathered while you use Our games. Non-personal information is general, non-identifiable and anonymous information that is gathered for statistical, analytical and research purposes such as the improvement of our games (for example, bug fixes).

Though We do not use cookies in order to track your movement around the web, Our website (https://folly.studio) uses Google Analytics to help analyse how users use these sites. The tool uses cookies to collect internet log information and general visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website, including your IP address, is transmitted to Google. This information is then used to evaluate use of our website and to compile statistical reports on website activity.

The Google Analytics privacy policy can be found here:
Google Analytics: https://policies.google.com/privacy