PRIVACY AND DATA POLICY
ISSUED BY JETBLACK SOFTWARE LIMITED
Last Updated: 21 September 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of apps, games and other products
developed by Jetblack Software Limited ('Jetblack' / 'we' / 'us').
Our registered office is at 165 Powis Avenue, Tipton, West Midlands,
DY4 0RW. We are a company registered in England, with company number
has effect in respect of all apps, games, related online services
(including online network play connectivity and interactivity) and
other software and products made available by us (together the "App(s)"),
as well as any other online features relating to the Apps including
our website (https://www.jetblacksoftware.com/) (the "Website"),
and user support Centre (email@example.com) (the "Support
Centre"). Together the App(s), the Website and the Support
Centre are referred to as the "Online Services".
please contact our Data Protection Officer at
We are committed to protecting and respecting your privacy. The
collect from you will be processed by us or on our behalf. Where we
decide the purpose or means for which personal data you supply
through these Online Services is processed, we are the "data
controller." We will comply with all applicable data protection
laws, including the General Data Protection Regulation 2016/679.
information about the following:
▪ What information we may collect about you;
▪ How we will use information we collect about you;
▪ Whether we will disclose your details to anyone else; and
▪ Your choices and rights regarding the personal information you
have provided to us.
The Online Services may contain hyperlinks to services owned and
operated by third parties. These third party services may have their
own privacy policies and we recommend that you review them. They
will govern the use of personal information that you submit or which
is collected by cookies and other tracking technologies whilst using
these services. We do not accept any responsibility or liability for
the privacy practices of such third party services and your use of
these is at your own risk.
posted on this page. You should check this page from time to time to
ensure you are aware of any changes. Where appropriate we may notify
you of changes through the Apps.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include
your personal data.
Information provided by you when using the
We will collect the following information from you when you use our
▪ your mobile device's unique device ID (Device ID) (if applicable);
▪ your Google Play ID (if applicable); and
▪ your user preferences.
Information collected when you purchase any
of the Apps online
When you purchase any of the Apps online we may collect the
following information from you:
▪ your name;
▪ your Order ID;
▪ your email address;
▪ your IP Address;
▪ the date of Purchase;
▪ the EU VAT country (if applicable); and
▪ a log of the download date/time of the purchased App.
Contact information provided by you when you
contact us or use the Support Centre
We may ask you for, or you may submit, certain contact information
to us whenever you contact us through the Support Centre or via
This may include:
▪ your email address; and
▪ your name.
Information collected for the purposes of
We may collect technical information about your use of the Online
Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
▪ how many times you visit the Website;
▪ which pages you go to;
▪ traffic data;
▪ your IP and MAC address;
▪ your internet service provider;
▪ your Device ID;
▪ your user ID;
▪ your device operating system & version;
▪ your device make and model;
▪ app session time start, end and duration;
▪ the country of your device;
▪ A/B testing statistics; and
▪ identification of crashes and defects (including optional personal
description of problem).
We use the following third party analytics providers:
▪ Google Analytics
Google may collect analytics data on our behalf and in accordance
with our instructions, and their applicable privacy notice. If you
would like to find out more about the way Google collect and process
this information this is likely to be set out in their privacy
policies and/or terms and conditions. Please refer to
Information collected for the purposes of
Android Advertising ID
Some of our Apps are provided for free and supported by in-app
advertising. These Apps make use of an Android Advertising ID.
We fully comply with Google's policy on its use:
▪ We use it only for advertising and user analytics.
▪ We do not associate it with any personally-identifiable
information or other identifiers.
▪ If reset, we do not associate it with any previous advertising
identifier or data derived from a previous advertising identifier.
▪ We respect the "Opt out of Interest-based Advertising" and "Opt
out of Ads Personalisation" settings.
▪ Collection and use of the advertising identifier is transparently
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Online Services to you
We will use information about you (including Basic Information and
agreed between us. The processing of information in this way is
necessary for us to record your progress and current status within
an App, and to ensure the Apps deliver the features promised and
function properly, so that you have the best experience when using
any one of our Apps and using the Online Services.
To help us improve the Online Services and
fix any problems
We may process information about you (including Basic Information,
Purchase Information, and Analytics) so that we can analyse and
improve our Apps and Online Services.
This processing is also necessary for us to pursue our legitimate
interests of (i) ensuring that our Online Services function properly
so that you and other users have the best experience when using any
of our App(s) and using the other Online Services; (ii) improving
the quality of our Online Services, and providing a better
experience to our users; and (iii) identifying and correcting any
bugs in the Apps and Online Services.
To respond to your enquiries and requests for
support and to enable you to use the Support Centre
We may process Contact Information so that we are able to properly
respond to your enquiries and support requests via the Support
Centre through firstname.lastname@example.org in accordance with the
To prevent fraud and illegal activity
We process personal data (including Purchase Information) for our
legitimate interests of ensuring that any use of the Online Services
is lawful and non-fraudulent, does not disrupt the operation of our
services, does not harass our staff or other individuals, to enforce
our legal rights and to comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any
information to inform relevant third parties such as your law
enforcement agencies about the content.
A cookie is a text file placed onto your device when you access our
such as web beacons, and flash object storage to deliver, improve
and monitor our Website and Apps, including in the following ways:
Authentication: To log you into our Website and Apps and keep
you logged in.
E-commerce: To keep track of items you have purchased in our
Apps or which you are interested in, and to take you through the
Preferences: To remember information about you such as your
preferred language and configuration.
Analytics: To help us understand how you use our Apps and
Website, and how often, so we can improve them to deliver a better
experience for our users. To carry out research and statistical
analysis to help improve our content, products and services.
Advertising: To deliver ads which are more relevant to your
interests, and to measure their performance.
contain your personal data. Although we may obtain information about
your device such as your IP address, your browser and/or other
internet log information, this will not usually identify you
Our Website should display a notice alerting you to our use of
cookies and other similar technologies and linking to this privacy
policy. If you use our Website after this notice has been displayed
similar technologies for the purposes described in this privacy
Please note that if you choose to disable cookies, or similar
technologies, on your device you may be unable to make full use of
our Apps and Website.
We work with third parties who may also set cookies on our Website,
for example Google Analytics, Google Adsense, Facebook, Twitter and
YouTube, which we use to display video content, enable social
networking functionality and sharing, to deliver ads, and to monitor
how visitors use our Apps and Website. These third party suppliers
are responsible for the cookies they set on your device.
If you want to learn about how to opt out of Google's use of
cookies, please visit https://tools.google.com/dlpage/gaoptout/ or
your Google Ads Settings
(https://www.google.com/settings/u/0/ads/authenticated). The Google
Analytics terms of service can be accessed here:
www.google.co.uk/analytics/terms/us.html. For further information
please visit the website of the relevant third party.
5. DATA SHARING
We will share your information with third
parties only in the ways that are described in this Privacy
Group members, personnel, suppliers or subcontractors: We
keep your information confidential, but may disclose it to any
member of our group (which means our subsidiaries, our ultimate
holding company and its subsidiaries, as defined in section 1159 of
the Companies Act 2006), our personnel, suppliers or subcontractors
insofar as it is reasonably necessary for the purposes set out in
make independent use of the information, and have agreed to
Merger or acquisition: If we are involved in a merger,
acquisition, or sale of all or a portion of its assets, you will be
notified via, account message and/or a prominent notice on our
website of any change in ownership or uses of this information, as
well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your
information to the extent that we are required to do so by law
(which may include to government bodies and law enforcement
agencies); in connection with any legal proceedings or prospective
legal proceedings; and in order to establish, exercise or defend our
legal rights (including providing information to others for the
purposes of fraud prevention).
Enforcement: We may also disclose your personal information
to third parties in order to enforce or apply the terms of
agreements, to investigate potential breaches, or to protect the
rights, property or safety of Jetblack, our customers, or others.
Digital Content Stores: Where the Apps are downloaded through
Google Play, we may disclose your personal information to Google for
the purposes of facilitating any payments made through these
6. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS
RELATING TO YOU
You have the following rights over the way we process personal data
relating to you, as set out in the table below. We aim to comply
without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know by
sending an email to email@example.com.
Ask for a copy of data we are processing
about you and have inaccuracies corrected
You have the right to request a copy of the personal information we
hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to
supply, correct or delete personal information held about you on our
files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your
personal data if:
▪ you consented to our processing the personal data, and have
withdrawn that consent;
▪ we no longer need to process that personal data for the reason it
▪ we are processing that personal data because it is in the public
interest or it is in order to pursue a legitimate interest of
Jetblack or a third party, you don't agree with that processing, and
there is no overriding legitimate interest for us to continue
▪ the personal data was unlawfully processed;
▪ you need the personal data to be deleted in order to comply with
▪ the personal data is processed in relation to the offer of a
service to a child.
Obtain a machine readable copy of your
personal data, which you can use with another service provider
▪ If we are processing data in order to perform our obligations to
you, or because you consented, or if that processing is carried out
by automated means, we will help you to move, copy or transfer your
personal data to other IT systems.
▪ If you request, we will supply you with the relevant personal data
in a commonly used, machine-readable and interoperable format. Where
it is technically feasible, you can ask us to send this information
directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
▪ If you are unhappy with the way we are processing your personal
data, please let us know by contacting us via the support services.
▪ If you do not agree with the way we have processed your data or
responded to your concerns, an alternative is to submit a complaint
to a Data Protection Supervisory Authority.
7. DATA RETENTION
We will hold your personal information on our systems for as long as
is necessary for the relevant service, or as otherwise described in
Purchase Information is retained indefinitely.
We do not use our Online Services to knowingly solicit information
prohibit users aged under 13 years from accessing our Online
Services. In the event that we learn that we have collected personal
information from a child under 13 years of age we will delete that
information as quickly as possible. If you believe that we might
have any information from or about a child under 13 years of age
please contact us at firstname.lastname@example.org.
We will take all reasonable technical and organisational precautions
to prevent the loss misuse or alteration of your personal
Please be aware that, although we endeavour to provide reasonable
security for information we process and maintain, no security system
can prevent all potential security breaches.
10. INTERNATIONAL DATA TRANSFERS
It is possible that your personal information may be transferred
outside of the EEA by Google. We recommend that you refer to the
privacy policies and/or terms and conditions of these third parties
if you are concerned about your data being transferred outside the
Our web server is hosted by Gandi.net located in Paris, France.
Where we transfer your information outside of the EEA, we have
agreements in place with those parties which include standard data
protection clauses adopted by a data protection regulator and
approved by the European Commission to ensure that appropriate
safeguards are in place to protect your personal data. If you would
like to find out more about these safeguards, please let us know by
writing to email@example.com.
All questions, comments or enquiries should be directed to Jetblack
at firstname.lastname@example.org. We will endeavour to respond to any
query or questions within three business days.
©2018 Jetblack Software Limited. All trade marks are the property of
the relevant owners. All rights reserved.