March 30, 2021
You should also read our Terms of Service, which set out the contract between you and Tribered.
Who decides how your information is used?
Tribered Oy, is the data controller responsible for making decisions about how we use your personal information.
The information we collect about you and how we use it
Essential Data Processing
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 start using the App, you give us Personal Data. 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.
- We collect and use your in-game actions and achievements, as well as certain information about your mobile device (device OS, model), to operate the Service for you and to personalize your gameplay and user experience.
- We use your Personal Data to organize and run live events based on featuring our games. When you participate in live events, your in-game actions and achievements, in-game username and your avatar, team, and other components of your in-game profile will be visible to other event participants and to the public (for example on leaderboards displayed at the event).
- We further use the information above in order to provide technical and customer support to you.
- You also give us Personal Data when you register for a live event, enter a competition 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), email address and additional information that you voluntarily provide to us when you communicate with us. We use that information to fulfil those Services to you and to provide related customer support to you.
The processing of the above information is necessary for performing the contract with you or to take steps upon your request prior to entering into a contract with you.
In addition, we have and rely on a legitimate interest in using your Personal Data as follows:
- Using your email address and device information in order to share updates and important information about our Services with you either within the games or by email. Your email is not used for marketing.
- Analyze your in-game actions and achievements to show you rewards, promotions, or other offers about our Services that are tailored to your personal user experience.
- To provide social features within our games so you can interact and play with other players, including storing your communications with those players, find your friends and be found by them, and share your gameplay experience and achievements with your friends.
- To offer new or additional features for our Services.
- Using your in-game actions and achievements, as well as certain information about your mobile device (including device OS, model), to carry out anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of Service, to ensure that we provide a fair gaming experience to all players.
- To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.
You can choose to opt out of the processing of your Personal Data listed under legitimate interest by following the steps described in Section 5 below.
Essential Processing of Your Specific Location Information to Enable Gameplay
With your separate consent We collect and use your specific device location information as you use Moomin Move, including how you move around and events that occur during gameplay. Moomin Move is a location-based game of which a core feature is to provide a gameplay experience tied to your real world location. Therefore, we need to know where you are to operate the game for you, and to plan the location of in-game resources. We identify your location using a variety of technologies, including GPS, the Wi-Fi points you are accessing the Services through and mobile/cell tower triangulation. When you start the game and prior to processing your specific location information, you will be prompted with a screen where you can manage your consent options, including for the collection and processing of your location information. Without your consent to processing your specific location information, we are not able to deliver the Services to you.
You may withdraw your consent with effect for the future at any time by contacting us at firstname.lastname@example.org.
Optional Data Processing
We will only use your Personal Data to do the following if you have provided your consent:
- With your separate consent We may use your device’s health app (Apple HealthKit if you use an Apple device, or Google Fit if you use an Android device) to collect your fitness activity data: we read your fitness activity data from your device’s health app to operate background activity tracking. We use background activity tracking to provide you certain functionalities in the game such as in-game items and rewards tied to your fitness activity. We do not use data collected through Apple Health Kit or through Google Fit for marketing or advertising purposes. Our Services cannot read from or write to your device’s health app without your consent. You can disconnect the fitness app at any time through game settings or disable our access to any type of fitness activity data in your Apple Health or Google Fit app settings on your device.
- With your separate consent We use information about your device’s operating system, in-game actions, in-game user settings and preferences, specific location and in-app purchases to gain insight about player activity and to further develop the game and possibly also other games, including games that we might develop on behalf of third parties.
- With your separate consent We may collect and share pseudonymised location information, demographic information, and information about in-game actions with our partner Astellas Pharma for research purposes. Astellas Pharma may process such data independently from us for its research on how mobile walking games may influence player's wellness by behavior change and how mobile walking games may change player’s behavior, including using the research results for the development of new products and services.
- With your separate explicit consent We may collect information concerning your health, including gender, height, weight, information related to your levels of fitness and nutrition, including your physical activity level and type, food and nutrient intake and other health questionnaire answers, and also share this data in a pseudonymised form with our partner Astellas Pharma for research purposes. Astellas Pharma may process such data independently from us for its research on how mobile walking games may influence player's wellness by behavior change and how mobile walking games may change player’s behavior, including using the research results for the development of new products and services. Astellas Pharma may connect these pseudonymised data for the above purpose with your pseudonymised location information, demographic information, and information about in-game actions if you have provided your separate consent to the processing of these data categories.
- With your separate explicit consent We may collect information concerning your health, including gender, height, weight, information related to your levels of fitness and nutrition, including your physical activity level and type, food and nutrient intake to operate, evaluate, and improve our business (including developing new products (including applications (such as games) that we might develop on behalf of third parties); analyzing and improving our products, customer base, and Moomin Move app; conducting market research; and other internal functions).
When you start the game or make use of the wellness task menu and prior to processing the above data, you will be prompted with a screen where you can manage your consent options for the above purposes. Without your consent, you will not be able to use the wellness function of the App and participate in Astellas Pharma’s research project. The denial of your consent does not affect any other parts of the Services. You may withdraw your consent with effect for the future at any time by contacting us at email@example.com.
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 Our Service Providers
We use Amazon Web Services, Amazon Data Services Ireland Ltd, 1 Burlington Plaza Burlington Road Dublin 4, D04RH96 Ireland (“AWS”) as our data storage and cloud service provider. The data center used is located in Ireland. We do not share your data with the service provider. Your Personal Data is encrypted during transition and at rest and AWS is therefore not able to access any of your Personal Data.
Information Shared with Other Players and Publicly
When you use Moomin Move, use social features within Moomin Move, or take part in live events, we will share certain Personal Data with other players. This Personal Data includes your in-game profile (such as your profile name, your avatar, your online status, and your team), your in-game actions and achievements, the real-world location of gameplay resources you interacted with when playing the games, and your public in-game messages. When you take certain actions in Moomin Move and interact with a gameplay resource on the map, your profile name will be shared publicly through the game, including with other players, in connection with that gameplay resource location. As mentioned above, this processing is necessary to provide the Services to you and fulfil the promises we make to you in the Terms of Service.
While Moomin Move itself does not contain features that facilitate sharing through social media or on web pages, please be aware that other users might engage in out-of-game actions, such as taking screenshots of the game and posting them on social media or on web pages – thereby possibly making your Personal Data (e.g. your profile name, in-game profile, achievements and public messages) publicly available.
Information Shared with Third Parties
Research Cooperation with Astellas Pharma
As mentioned, with our partner Astellas Pharma we are conducting a research project about possibilities of mobile walking games to influence player's wellness by behavior change and how mobile walking games may change player’s behavior. We share, based on your consent, pseudonymised demographic and health data, including fitness and nutrition data, with Astellas Pharma for such research purposes when you participate in the separated Wellness part of Moomin Move. The transfer of your pseudonymised information to Astellas Pharma in Japan takes place on the basis of the EU Commission’s adequacy decision for Japan (available here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) according to which Japanese data protection law provides for an adequate level of protection for your information. In cases in which your pseudonymised information is transferred from Astellas Pharma Inc. in Japan to Astellas Pharma US LLC in the United States of America, Astellas Pharma Inc. complies with Japanese data protection laws applicable to such onward transfer.
We may share your data with public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties.
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 subject to applicable data protection laws.
How long we will keep your Personal Data
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. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.
Your rights and choices
You may be entitled
- to obtain access to information on the processing of your personal data,
- to object to certain processing of your personal data,
- to request data portability, and
- to have your personal data rectified, deleted, or otherwise restricted in terms of processing,
in each case as permitted under applicable law and subject to certain exemptions under applicable law.
You may also be entitled to withdraw any consent given with effect for the future with respect to the processing of your personal data.
You can exercise these rights by sending a request via email to our customer service team at firstname.lastname@example.org. Any request is subject to identity verification, which includes that your email will be verified through the Moomin Move app.
If you are not satisfied with our response or believe that your personal data is not being processed in accordance with the law, you also may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law. However, we highly encourage you to work with us in good faith and contact us first.
Special Note about Children’s Privacy
Tribered does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Service. If you are under 13, please do not send any information about yourself to us, including but not limited to your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 13, we will delete that information as quickly as possible. If you believe that, we might have any information from or about a child under the age of 13, please contact us at email@example.com.
Links to Third Party Services