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Hutch - Privacy and Cookie Policy

Hutch_IanWHutch_IanW Posts: 9 admin
HUTCH GAMES: PRIVACY & COOKIES POLICY

This is the Privacy & Cookies Policy (the ‘Policy’) of Hutch Games Limited (‘Hutch’). This Policy
describes the ways in which Hutch collects and uses information about you when you visit Hutch’s
website at www.hutchgames.com (the ‘Website’) or when you play one of Hutch’s games (each a
‘Game’ and together the ‘Games’) on a browser, through a social networking site or as an app. It also
details how Hutch collects and uses information about you when making a complaint to Hutch by e-
mail, as well as if you choose to make a job application.

Hutch may change this Policy at any time and when this happens we will notify you of any changes to
this Policy by noting this on our Website as well as within the Games. The changes will apply to your
use of the Website and/or our Games after we have notified you. If you do not wish to accept the new
Policy you should stop using the Website and/or playing our Games (as applicable). If you continue to
use the Website and/or play our Games after the changes, your continued use of the Website and/or
your continued playing of any of our Games shows us your agreement to be bound by the new Policy.
For the purposes of data protection legislation, Hutch is the controller for the processing of your
personal data. Hutch has notified the Information Commissioner’s Office (“ICO”) of its processing of
personal data. The notification indicates what data is processed by Hutch and for what purpose, and
to which persons or entities the data will be provided. Hutch’s registration number is ZA369120.
If you have any queries about this Policy, please contact Hutch using the contact details set
out at paragraph 12 below.  

1. Who this Policy applies to: By playing the Games or visiting the Website you are agreeing
to be bound by this Policy in respect of the information collected about you.  Hutch may
change this Policy at any time. Hutch shall deem your continued use of the Games or access
of the Website as indicating your consent to such changes. This Policy applies to the
following people:

A. visitors to the Website (including those submitting a job application);

B. people who use the Games; and

C. people who make complaints to us by email.

2. Visitors to the Website: The Website is essentially a brochure for Hutch’s business, its
Games and opportunities to work with and for Hutch. The Website collects information from
you in the following ways:

A. Hutch uses cookies for the limited purposes set out in TABLE ONE below to collect
certain analytical/technical information. Hutch relies on legitimate interests to collect
this information. It is in Hutch’s legitimate interests to collect these items of personal
data because this is necessary in order to monitor and improve the Website and
provide its features to you. The items of personal data collected are, in being limited
to “technical” type data, not of a nature whereby your rights and freedoms as a data
subject are outweighed by such data collection.

B. Should you choose to contact Hutch via the Website, Hutch will collect your e-mail
address together with any other information that you submit in connection with such
contact request. Hutch relies on consent to collect this information because you
choose whether to contact Hutch or not and can choose how much personal
information to provide to Hutch in doing so.

C. Hutch often advertises jobs on the Website. If you choose to respond to any such
advertisement, any information provided by you to Hutch in connection with such
response will be used to assess you as a candidate and undertake criminal record
and/or checks with references.  Personal information about an unsuccessful
candidate shall generally be held for twelve (12) months after the recruitment
exercise has been completed after which it shall be destroyed or deleted without
further notice unless Hutch reasonably considers that such candidate may be a good
candidate for a future role in which case Hutch shall hold such personal information
for so long as is reasonable in relation to such information. Hutch may retain
anonymised statistical information about applicants to help inform Hutch’s recruitment
activities in the future. Hutch relies on either: (i) compliance with a legal obligation; or
(ii) the legitimate interests processing grounds in order to collect the information set
out in this paragraph. Where legitimate interests are relied upon, it is in Hutch’s
legitimate interests to collect such items of personal data because this is necessary in
order to carry out certain specific employment related duties relating to your
application for employment with Hutch. The items of personal data collected are not
of a nature whereby your rights and freedoms as a data subject are outweighed by
such data collection.

3. People who contact or make complaints to Hutch by email: When Hutch receives
complaints by email it shall file any relevant document and may retain details of the
complainant, and other individuals identified in the complaint.  Hutch will only use this
information to process the complaint and to check on Hutch’s services and staff.  Hutch shall
retain information in relation to a complaint for a maximum of six (6) years after its closure, in
a secure environment and access to it will be restricted on a ‘need to know’ basis. Hutch
relies on the legitimate interests processing ground to collect the information set out in this
paragraph. It is in Hutch’s legitimate interests to collect such items of personal data listed
here because this is necessary in order to analyse and respond to your complaint. The items
of personal data collected are not of a nature whereby your rights and freedoms as a data
subject are outweighed by such data collection.

4. People who use the Games: 

A. Game Data: Hutch will collect the following information from you when you use the
Games:

i. If you don’t log in via a social network, certain information collected by Hutch’s use of
cookies and similar technologies. These collect information such as your device ID
and other technical/analytical information relating to how you interact and play the
Game in question. Hutch will also assign you a User-ID which is a random string of
characters used to identify you as a unique player going forward.  The cookies and
other similar technologies that Hutch places when you use the Games are detailed in
TABLE 2 below (“Analytics Data”);

ii. If you sign into one of the Games through a social network, in addition to the
Analytics Data above, Hutch will also collect such information as that network may
allow Hutch to access. For example, on Facebook, Hutch will access your public
profile (comprising your name, profile picture, age range, gender, Facebook user
name and ID and any other public information determined by Facebook itself and
affected by factors such as what you have shared with the public via your Facebook
profile), as well as, if you don’t de-select the option, your friends list and e-mail
address (“Player Data” which, together with the Analytics Data is the “Game Data”);

iii. if you make any purchases, Hutch will collect certain information in relation to your
purchases (please see paragraph 4(b) below) ("Finance Data");

iv. in F1 Manager, if you opt-in to do so, information including your name, date of birth
and e-mail address which is then used by F1 to provide you with a newsletter and
other marketing information related to F1 (“F1 Data”); and

v. in certain instances Hutch may use certain information relating to your Game
progress and/or Game Spend and/or other Game activity to invite you to complete
surveys in relation to its Games, including, for example, to join its “Player Council”
(“Survey Data”).

B. Financial Information: Your purchase and in-app purchases within the Games are
handled through the platform on which you purchased the Game or through other
payment processors (e.g. the Apple App Store, Google Play, xBox Live, Playstation
Network). Hutch does not retain any card or payment details, although Hutch does keep a
record of your purchases and your aggregate spending.

C. What if Hutch cannot collect this information: You can use your browser settings and
privacy settings on your social networks to prevent us collecting certain of the above
information about you (see, for example, paragraphs 5(f) and 12 below).  If you still have
concerns about the information we collect please contact us at any time by sending an e-
5. How Hutch uses collected information from people who play the Games: Hutch will use
the information it collects as set out in paragraph 4 above to:

A. in relation to the Game Data, offer the Games to the player in question;

B. in relation to the Analytics Data, to facilitate the improvement of the Games and your
experience of the Games;

C. in relation to the Game Data and Finance Data to complete your transactions;

D. in relation to the Game Data to provide technical support in relation to player enquires,
resolving disputes, collecting fees and troubleshooting;

E. in relation to the Game Data to prevent fraud or illegal activities;

F. in relation to the Game Data to serve targeted adverts to you. You may opt-out of your
Game Data being used for this purpose by: (i) for iOS, going to “Settings”, scrolling down
to “Privacy”, scrolling down to “Advertising” and then shifting the “Limit Ad Tracking” slider
to the right; and (ii) for Android, going to “Settings”, scrolling down and clicking on
“Google”, scrolling down and clicking on “Ads” and then shifting the “Opt out of Ads
Personalisation” slider to the right.;

G. in relation to the F1 Data for F1 to then provide such newsletters/marketing information to
you;

H. in relation to the Survey Data for Hutch to provide such survey to you;

I. in accordance with applicable legislation, including direct marketing legislation, to use
your e-mail address to provide information about the Games, applications, services and
other digital goods which Hutch thinks may be of interest to you. You can tell us to stop
this at any time by sending an e-mail to [email protected]; and

J. share with third parties for the purposes as described in paragraph 7 below.

6. Grounds for processing: Hutch relies on the legitimate interests processing ground to
collect the information set out in paragraph 4 and use it for the purposes set out in paragraph

5, other than in relation to targeted advertising and the F1 Data for which Hutch relies on
consent or in relation to the information collected by Hutch once a survey is presented to a
player where Hutch also relies on consent (no survey is compulsory to complete). It is in
Hutch’s legitimate interests to collect such items of personal data listed above because this is
necessary in order to provide and improve the Games that are offered to you. The items of
personal data collected are, in being limited to “business card” and “technical” type data, not
of a nature whereby your rights and freedoms as a data subject are outweighed by such data
collection.

7. Sharing information with third parties: Hutch will not pass your information to third parties
other than as described in this paragraph. Hutch may, subject to its obligations to comply with
applicable data protection legislation, share your information with third parties including:

A. its server providers which host and store the Game Data, such as Apple, Google,
Microsoft Azure and AWS;

B. the third parties who assist Hutch in collecting the Analytics Data (as listed below);

C. where Hutch carries out any e-mail marketing campaigns, your name and e-mail address
will be transferred to Mailchimp which carries out such campaigns on Hutch’s behalf and,
where Hutch carries out certain personalised advertising on TikTok Inc’s platform, your
User ID and other device information may be shared with TikTok, Inc. (or its affiliates) in
relation to allowing TikTok, Inc. to more carefully target our adverts to you;

D. Helpshift in relation to Hutch’s customer support;

E. Get Social and/or KTPlay should you participate in any in-game chat services;

F. F1 in relation to the F1 Data;

G. as part of the Games your information (for example your name, profile picture or user ID)
may be posted on a Leaderboard of top scorers within the Game to be shared with other
players and your social networks.  You may also share elements of your performance or
participation in the Games (e.g. your personal car design) with other players and your
social networks;

H. in relation to the sale of some or all Hutch’s business, or its assets, to any third party, or
as part of any business restructuring or reorganisation, but Hutch will take steps with the
aim of ensuring that your privacy rights continue to be protected;

I. in anonymised form with data aggregators and service providers as part of an analysis of
player metrics or sales performance; or

J. with law enforcement agencies in compliance with law enforcement.

8. Third Party Cookies: Third Party advertisers may place or read cookies on your browser or
device in the Games and on the Website.  This Policy is applicable only to the use of cookies
by Hutch and does not cover the use of cookie by any third parties (including advertisers or
Facebook).  For example, Facebook will place cookies to maintain a secure login to the
Facebook network, amongst other things.  More details of Facebook’s cookies are available
on its website and further links to third party cookies are also set out in the tables below.

9. Links to third party websites and third party adverts: Hutch cannot be responsible for the
privacy policies and practices of other sites even if you access them using links from the
Games/Website, adverts in the Games/Website or from adverts on a webpage when you are
playing the Game/are on the Website. Hutch recommends that you check the policy of each
site you visit and contact its owner or operator if you have any concerns or questions. In
addition, if you link to the Games from a third party site or via a social network (e.g. Twitter,
Facebook), Hutch cannot be responsible for the privacy policies and practices of the owners
or operators of that third party site and recommends that you check the policy of that third
party site and contact its owner or operator if you have any concerns or questions.

10. Security, Storage and Data Retention: Hutch has implemented technology and policies to
safeguard your privacy from unauthorised access and improper use. You may also change
your account settings on Facebook to prevent both us and third parties seeing certain

information in relation to you, such as your e-mail address and friends list. Hutch’s physical
servers are operated by third party cloud service providers and are located worldwide
including in the EEA, USA and Asia. Where such information is transferred outside the EEA,
Hutch has taken steps to ensure that its agreements with such third party providers contain
provisions ensuring the adequacy of such transfer. Hutch has a retention policy in place with
respect to the data it holds, ensuring that it does not retain such data for longer than is
reasonable in line with the purposes for which it was originally collected.

11. Hutch’s policy towards children: Hutch’s Games are intended for anyone who is legally
entitled to own a device that access them and play them and anyone who is legally entitled to
make in-app purchases by the payment functionality the Games provide.  However, Hutch
does not knowingly collect personally identifiable information in relation to children under the
age of 13.  If Hutch discovers it has collected personal data in relation to any children under
13 Hutch shall take reasonable steps to delete such information. You may also be required to
obtain your parents’/guardians’ permission to play the Games if you are under 18, as
indicated in our Terms of Service.

12. Contact details: If at any time you would like to contact Hutch about your views on this Policy
or any enquiry relating to your personal information, you can do so by sending an e-mail to us
at [email protected] or write to us at Data Protection Officer, 44-46 Scrutton Street,
Shoreditch, London EC2A 4HH, UK. This is Hutch’s registered address and we are a
company incorporated in England and Wales with company number 07692393. You also have
the right to make a complaint to the ICO by contacting them at any time.

13. Exercising your rights: You can contact us using the details set out in paragraph 12 above if
you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any
items of personal data that we hold about you; and/or (iii) have any items of personal data that
we hold about you erased or object to our processing of such items of personal data.

14. Cookies and other similar technologies:

A. What are Cookies? Cookies are small text files that are placed on your device when you
play a Game or visit a Website. Hutch’s use of cookies is detailed below. Session cookies
enable you to move from page to page within websites, or our Games and any
information you enter will be remembered but is deleted when you close your browser or
mobile application after a short time. Persistent cookies allow us to remember your
preferences and settings when you browse the Website and/or play the Games in the
future, in different browser sessions.

B. Disabling Cookies: The use of the cookies described above improves the functionality of
the Games and the Website and your experience using them. If you do not want these
cookies to be served on your device, you are able to disable them by changing the
settings on your browser, or on your device.  Please note that if you do decide to disable
cookies you may not be able to access some of the Games or the Website, some of the
features of the Games or the Website, or the Games or Website may not function
properly. By continuing to use the Games, and/or the Website, including using social
networking media functionality, you consent to the relevant cookies being set on your
device.

C. More information: To find out more about how cookies work, how to manage and delete
them and to see which ones have been set please visit www.aboutcookies.org or
www.allaboutcookies.org.


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