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Sean O'Dowd's Privacy Policy
Last updated: January 31st, 2019
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A quick summary: this document explains:
This Privacy Policy explains to you how your personal information is collected and stored and what happens to it regarding the Sean O'Dowd Services. Because we know legal wording is not much fun, we have included a short and informal summary of each section (but the full version is the legally binding one). If you have any queries you can contact us at hello@odowd.co.
This Privacy Policy explains the different kinds of information Sean O'Dowd can collect from you when you're using the Sean O'Dowd Services. Legally, we cannot and will not collect personal information about children below 13 without parental/guardian involvement. We will comply with applicable privacy laws, including the EU’s GDPR.
About Us. I'm a sole trader working out of Melbourne, Australia. ABN: 63 103 144 082
Which services does this Privacy Policy apply to? All of our video games (e.g. Calamari Kid), our websites, user accounts, customer and technical support, official forums, wikis, blogs, social media services and other products and services - “Sean O'Dowd Services” for short.
What information does this Privacy Policy apply to? Specifically, this Privacy Policy governs personal data (or, in the USA, personally identifiable information) and applicable non-personal information (or, in the USA, non-personally identifiable information), which we collect from you when you are using the Sean O'Dowd Services ("personal data" means information which, on its own or in combination with other information, can be used to identify you).
What about children? We recognise we have a special obligation to protect personal information obtained from children. Legally you must be at least 13 years old to use the Sean O'Dowd Services (but this might be older depending on whether or not a particular Sean O'Dowd Service has a required minimum age rating) as per our User Agreement. We do not knowingly collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact hello@odowd.co.
What about GDPR? We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal information contained in this Privacy Policy which is used by Sean O'Dowd in connection with the Sean O'Dowd Services, Sean O'Dowd is the data controller under EU data protection legislation.
We may collect certain information when you use the Sean O'Dowd Services such as your name and email address (more information below). We do not receive or store your payment details.
What information might we collect from you? When you sign up for, download, use or play the Sean O'Dowd Services then we will collect certain information from you. The information that we collect varies depending on the particular Sean O'Dowd Services used, but this may include:
Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.
What about the storage of payment details? The processing and storage of payment details is a matter for the relevant platform and the applicable payment methods/processors. Sean O'Dowd will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g. Steam, Apple’s App Store or Google Play) via the user account you have associated with that platform account. If you make in-game purchases within a Sean O'Dowd game or product, we are notified by the payment processor once a transaction takes place but we will not receive any of your actual payment details.
We will store your information in Europe where possible. We will do our best to keep this information secure. No information security system is perfect so please remember to be careful.
Where will your information be stored? The information we hold will primarily be stored and processed in the EU, but there may be circumstances where we need to work with trusted third parties outside of the EU in order to provide the Sean O'Dowd Services to you. By submitting your personal information, you explicitly agree to such transfer, storing or processing of data outside the EU. We will take all steps reasonably necessary to ensure that this information is treated securely and in accordance with this Privacy Policy.
All information we hold is stored on our secure servers which we own or license from appropriate third parties. We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.
We will use your information to run, maintain and improve the Sean O'Dowd Services as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may share information with partners in order to run our services.
How might your information be used? We may use the information above in order to (for example):
Will we ever share any of your information with other parties?
We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
We may engage third party service providers in the course of providing the Sean O'Dowd Services to you (e.g. data storage, server hosting, customer and technical support, game analytics, advertising, etc.) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers, etc.) subject to their own privacy policies.
We may work with third party service providers (e.g. ad network and measurement services) to display advertising on the Sean O'Dowd Services and to manage our ads on third party sites. You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device and you may be able to opt-out from the collection of information by some of our advertising partners.
We may share your information within the Sean O'Dowd company group for the purpose of providing the Sean O'Dowd Services.
In the unlikely event of a reorganisation or merger of Sean O'Dowd Services we may transfer personal information to an involved third party who will protect this to at least the same level as we do in this Privacy Policy.
You have the option to share your own personal information with other parties, in which case it will be governed by those parties’ own privacy policies – make sure to take a look at them.
Please remember that any communications you have via the Sean O'Dowd Services may reveal details about you. Also, any information you post publicly will be publicly available to other people. We are not responsible for your use of any otherwise private personal information which you make available, or the activities of other users or other third parties to whom you give or make available your information or content. The Sean O'Dowd Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.
We retain your information for as long as needed to provide the Sean O'Dowd Services to you or longer where permitted by law.
How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all Sean O'Dowd Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.
You have rights about how your personal information is used, which can vary depending on where you live. If you have any questions, please contact us at hello@odowd.co.
Can you ask us to stop processing your personal information? You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications.
What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the new GDPR) you have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain Sean O'Dowd Services may no longer function properly or be completely unavailable to you.
Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact: hello@odowd.co.
We can change this Privacy Policy, but if we do we will put the changed version online and normally it will take effect 30 days afterwards. Please feel free to contact us if you have any questions with regards to the changes at hello@odowd.co.
Will we ever change this Privacy Policy? Possibly, but if we do we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on you as of the date of publication (i.e. the new “Last Updated” date). You are welcome to contact us if you have specific questions about the changes at hello@odowd.co.
If you do not agree to those changes, regardless of whether you email us then unfortunately you must cease using all Sean O'Dowd Services.