Privacy Policy

Last Updated: August 14, 2018

We are Cheapshot. We provide a multiplayer real-world location-based mobile game, designed to enable you to interact in a shared world, seamlessly blended with the real world. To do that, we need information about you. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play our game, use our website, buy merchandise from us, or take part in live events and promotions (the "Services").

You should also read our Terms of Service which set out the contract between you and Cheapshot.

1. Who decides how your information is used?

Cheapshot is the data controller responsible for making decisions about how we use your personal information. If you have any questions or comments on this policy, you can: Email us at x@cheapshot.co

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service.

When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you sign up for an account. We collect and use that information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. That information includes the in-game username you choose to use on our Services, and internal account IDs that we assign to your account.

You must have an account with a supported third party single sign-on service to use our Services. As such, the Personal Data we collect also depends on which third party accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Cheapshot.

Depending on the particular Service you sign up for, we may support other third party single sign-on services and collect additional Personal Data from them.Some third-party providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.

We collect and use your device location information as you use our Services, including how you move around and events that occur during gameplay. Our Services include location based games whose core feature is to provide a gameplay experience tied to your real world location, so we need to know where you are to operate these games for you, and to plan the location of in-game resources (for example Stores within Cheapshot). We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through and mobile/cell tower triangulation.

We also collect and use your in-game actions and achievements as well as certain information about your mobile device collected during gameplay (including device identifiers, device OS, model, settings and information about third party applications installed on your device), to operate the Services for you and to ensure that we provide a fair gaming experience to all players in accordance with our Terms of Service (which includes anti-fraud and anti-cheating measures).

We may also use the information above to show in-game sponsored locations that are in your vicinity as part of the gameplay experience.

We further use the information above in order to provide technical and customer support to you.

You also give us Personal Data when you make a purchase through us, subscribe to our publications, enter a competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, date of birth (as needed to verify eligibility), and email address. We use that information to fulfil those Services to you and to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

We will only use your Personal Data to do the following if we have your consent:

Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at any time in your device settings or in-app settings.

While you may disable the usage of cookies through your browser settings, Cheapshot currently does not respond to a "Do Not Track" signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

3. Who we share information with

We will not share any Personal Data that we have collected from or regarding you except as described below:

Information Shared with Other Service Providers

We engage third party service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These third party service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to:

Information Shared with Other Players

Information about you, such as your nickname you provided and the emoji portrait you chose when registering.

Information Shared with Third Parties

We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

Information Shared Publicly

When you play Cheapshot, as part of the gameplay the following information about you will be shared through the game (including with other players directly within the app, in game notifications emailed to other players as part of the gameplay, and online on the Cheapshot Map website), and will therefore become publicly available: your in-game username, messages sent to other players through the microphone, and in-game bots and buildings that you interact with, as well as your device location whenever you take any in-game action.

4. Sharing Information Related to In-App Purchases

Information Shared: In the pursuit of providing our users with a seamless and enriched experience within our application, specific pieces of information related to in-app purchases are shared with third-party platforms such as Apple or Google. The information we share is confined to:

Purpose of Sharing: The rationale behind sharing this information is to facilitate transactions, optimize user interaction, improve app functionalities, and uphold user integrity. It enables us to tailor our services more closely to user preferences and to rectify any discrepancies in the delivery of in-app purchases efficiently.

5. How your Personal Data is transferred

Cheapshot operates its Services across the globe. Your Personal Data will very likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country. If we transfer your Personal Data from the European Economic Area (EEA) to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the EEA by ensuring that at least one of the following safeguards is implemented: The country that your Personal Data is transferred to is a country that the European Commission has deemed to provide an adequate level of protection for Personal Data as the EEA. We use specific contracts approved by the European Commission which give Personal Data the same protection as it has in Europe when we engage with service providers. Where we engage with service providers in the USA, they are part of the EU-US Privacy Shield, which requires them to provide the same protection of your Personal Data as it has in the EEA.

6. How we keep your Personal Data safe

We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. How long we will keep your Personal Data

We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you.

8. Your rights and choices

You have certain rights in relation to your Personal Data. In order to exercise these rights, please contact us at x@cheapshot.co. You can:

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

We aim to provide the information or complete the outcome you request within 30 days.

9. Children

As a general rule, if you are outside the EEA, children under 13 are not allowed to use the Services. If you are based in the EEA you may only use the Services if you are over 16, or the age needed to consent to the processing of personal data in your country of residence.

If we learn that we have collected Personal Data of a child under the age of 13, or in the EEA 16 or the age needed to consent to the processing of personal data, and we do not have parental consent, we will take steps to delete such information from our files as soon as possible.

10. Third Parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a "Third Party Service"). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.