Privacy Policy

(Last updated March 2024)

1. INTRODUCTION
Who are we? We are Downpour Limited, and our offices are at 16 Chartwood Pl Dorking RH4 2JY.

Where we decide the means or purpose of processing your personal data, we are the data “controller”.
What’s this notice about? This notice explains how we process your personal data as a data controller when you:
  • visit, use and/or engage with our website (https://downpour.games/), and any of its respective subdomains, and any other website or app of ours that links to this privacy policy; or
  • play any of the games (each, a “Game”) we make available from time to time,(together, the “Services”).

    We update this notice from time to time so please check back in.

    Other apps and websites provided by third parties but linked to within our services will have a separate notice provided by the relevant third party.
    • How do you contact us?
    (if you have questions about this notice or to exercise your rights)    		 Write to us at: [email protected]

    If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns
    (or if you live in a European country other than the UK, you can submit a complaint to the supervisory authority in your country).
    What are your rights? You have the following rights, although these rights may be limited in some circumstances:
    • Ask us to send a copy of your data to you or someone else
    • Ask us to restrict, stop processing, or delete your data
    • Object to our processing of your data
    • Object to use of your personal data for direct marketing (to the extent it is used for direct marketing)
    • Ask us to correct inaccuracies
    If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address above.

    2. YOUR PERSONAL DATA AND HOW WE USE IT

    Your data How we use it Sources and recipients
    Platform Data
    • Email address
    • Account identifier, including gaming or device platform accounts (such as iOS and Android)
    • Payment information, including receipts and IDs relating to in-game purchases linked to your account with us
    • Gaming or device platform handle
    • Token assigned by gaming or device platform provider
    		We process this information for the purposes of managing the provision and administration of the platform and the Services.

    We may also associate your in-game purchases with your Downpour account to facilitate better access to such purchases across your devices, including where such purchases are made through third party services through our Games are published (for example Apple and Google).

    You can choose to link your gaming and device platform account(s) with your Downpour account and use your gaming and device platform account details in order to access the Services. When you choose to do this, the relevant gaming or device platform provider will provide us with a token which we use to link with the account. Depending on your privacy settings with the relevant gaming or device platform provider, we may also be sent your name, and email address, from your gaming or device platform account.

    Legal basis

    We may process this data in accordance with the terms of our contract with you (“ToS”) (where we need this information to provide Services to you) or to take steps at your request prior to entering into the ToS.

    We may also process this information on the basis of our legitimate interest to improve the users experience with and accessibility to our Services.

    More information

    You are under no obligation to provide this information, however if you do not, we may not be able to register your account and deliver part or all of the Services.    		 Sources

    We collect this data directly from you or through third party services where you use your existing gaming and device platform account to log into our Service (please see below), or where your access to the Services is facilitated by you subscribing to https://www.patreon.com/v21. Your account identifier is generated by Firebase and will be available in-game once you have created your account.

    Recipients

    We use Firebase to store this data for authentication purposes.

    Wasabi and Akamai provide some of our technical infrastructure, including some of our servers, APIs and storage.

    Further, the relevant gaming or device platform provider will have access to this data (such as Apple and Google).
    Enquiry Data
    • Name
    • Email address
    • Account identifier
    • Details of your enquiry
    		We process this information to respond to your support requests and other enquiries.

    Legal basis

    We may process this data in accordance with the terms of the ToS(where we need this information to provide Services to you) or to take steps at your request prior to entering into the ToS.

    We also use this data to pursue our legitimate interests, including: (a) our interest in responding to enquiries to ensure smooth operation of our business and Services; and (b) to understand our customers and improve our Services, by taking on-board your feedback.

    More information

    You are under no obligation to provide us with this information, but if you do not, we may not be able to respond to your enquiry or support request.    		 Sources

    We collect this data directly from you.

    Recipients

    We use Freshdesk in order to receive, log and respond to your enquiries. Google may also gain access to this data if you email us directly at [email protected].
    Review Data
    • Name (or username)
    • Content of your review

    • Location data




      Information relating to model of device
    		We process this information to consider your reviews, respond where appropriate, and/or to make updates or improvements to our Services in response to your reviews.

    Legal basis

    We use this personal data to pursue our legitimate interests to improve the quality of our Services.    		 Sources

    We collect this information when you leave a review on third party services such as Apple App Store, Google Play Store, and other third party gaming and device platforms, or through Wiredash.

    Recipients

    Platform where you share your reviews, such as Wiredash, Google Play Store, and Apple App Store.
    Usage Data
    • IP address
    • Name (or username)
    • Pages of our Service that you visit, time and date of your visit, and the time spent on those pages
    • Unique device identifiers
    • Country level location data


      Where you access the Service using a mobile device, in addition to the above:
    • Type of mobile
    • Mobile device unique ID
    • Mobile operating system
    • Mobile internet browser
    		We may use software to collect usage data to understand how people use and interact with our Services, and to help improve and maintain our Services.

    Legal basis

    We process this data if you have given your consent.    		 Sources

    We collect this data using tracking technologies. For more information on how we use tracking technologies to collect this data, please see section 3 ‘Cookie, Analytics and Similar Technologies’ below.

    Recipients

    We may use Fathom Analytics, Cloudflare, Honeycomb, RevenueCat, and Firebase, to collect usage data and provide us with analytics.

    Wasabi and Akamai provide some of our technical infrastructure, including some of our servers, APIs and storage.
    Technical Data
    • IP address
    • Email address
    • Pages of our Service that you visit, time and date of your visit, and the time spent on those pages
    • Unique device identifiers
    • Error messages and crash reports
    • Spam/Fraud/DDOS reports
    		We process certain information relating to the device on which users are accessing our Services to: (i) identify users accessing our Services; (ii) improve, test and monitor the quality and delivery of our Services; (iii) identify and correct any problems on our Services; and (v) perform essential business operations.

    Legal basis

    We use this personal data to pursue our legitimate interests, including to improve the quality of our Services by addressing issues and bugs, and to ensure that our Services are safe for users by taking steps to prevent fraudulent or illicit activities on our Services.    		 Sources

    We collect this data directly from you / your device as you use the Services, and through the operator of your mobile system or device (including Apple and Google).

    For more information on how we use tracking technologies to collect this data, please see section 3 ‘Cookie, Analytics and Similar Technologies’ below.

    Recipients

    We may use Sentry to collect crash and error data, and Cloudflare to collect spam/fraud/DDOS data. Apple and Google may also have access and provide us with such data.

    Wasabi and Akamai provide some of our technical infrastructure, including some of our servers, APIs and storage.
    Moderation Data
    • IP address
    • Email address
    • Unique device identifiers
    • Uploaded games and other user activity
    		We process this information to moderate the use of the Services by users, and to ensure that users’ use of the Services is compliant to our ToS.

    Legal basis

    We use this personal data to pursue our legitimate interests, to ensure that users engage the Services in accordance with our conditions for use of the Services, as incorporated in the ToS.     		Sources

    We collect this data directly from you as you use the Services. For more information on how we use tracking technologies to collect this data, please see section 3 ‘Cookie, Analytics and Similar Technologies’ below.

    Recipients

    We may use Plasmic to moderate the use of our Services.

    Wasabi and Akamai provide some of our technical infrastructure, including some of our servers, APIs and storage.
    Marketing Data
    • Screenshots of Games instances that may contain user generated content incorporating personal data
    		We process this information to promote our Services on the marketplaces through which we offer our Services and Games.

    Legal basis

    We use this data to pursue our legitimate interests which is to promote our Services and Games.    		 Sources

    We collect this data directly from you as you use the Services.
    Newsletter Data
    • Email address upon signup to Downpour newsletter
    		We process this information to send you updates on our Services and business if you are subscribed to the Downpour newsletter.

    Legal basis

    We process this data if you have given your consent.    		 Sources

    We collect this information when you subscribe to the Downpour newsletter through third party services, such as Buttondown.

    Recipients

    Newsletter platforms, such as Buttondown.
    Competition Data
    • IP address
    • Name
    • Contact Information (including email address)
    • Social media usernames and associated content, including profile pictures
    • Any other information that you submit as part of your competition entries or submissions
    		We process this information when you enter one of our competitions.

    Legal basis

    We use this personal data for the performance of a contract with you (for example, the terms governing any such competition, and arranging the delivery of the prize), and to comply with our legal obligations (for example, to ensure compliance with applicable laws and regulations governing such competitions, if any).    		 Sources

    We collect this information directly from you, when you enter a competition.

    Recipients

    Applications such as Google Sheets.
    Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.

    3. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

    Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for our sites, apps or services.

    Settings to disable certain similar technologies: Windows Advertising ID | iOS and Mac OS Ad Tracking | Google Analytics | Your Ad Choices.
    Cookie/Similar Technology Duration Purpose Access
    Fathom Analytics 48 hours Website analytics For more information, please refer to Privacy policy for Fathom Analytics - Fathom Analytics (usefathom.com) and GDPR Compliance - Fathom Analytics (usefathom.com)
    Honeycomb 60 days Metrics and monitoring tool For more information, please refer to Privacy Policy - Honeycomb for Observability
    Sentry 90 days Monitoring to address bugs and defects in our Services For more information, please refer to Privacy Policy 3.3.0 (December 15, 2023) | Sentry
    Wiredash Indefinitely Collection of bug reports and user feedback For more information, please refer to Privacy Policy | Wiredash Docs
    Aptabase Session Website analytics For more information, please refer to Aptabase Analytics for Mobile, Desktop and Web apps

    4. TRANSFERS AND DISCLOSURE

    Transfers Your personal data is normally securely stored in the UK.

    Where we use data processors outside the UK and European Economic Area, and (or otherwise) transfer personal data to a country which does not provide an adequate level of protection, we use contracts approved by the European Commission or UK authorities which give personal data the same protection it has in Europe / the UK. For more information drop us a line using the contact details at the start of this notice.
    Disclosure Other than as set out above, we may disclose your personal data:
    • Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies). Legal basis: our legal basis for this processing is likely to be: compliance with legal obligation or legitimate interests in: (i) obtaining advice in relation to legal and similar proceedings, (ii) communicating with relevant third parties in relation to legal and similar proceedings; and/or (iii) protecting and defending ourselves from legal and similar proceedings.
    • With members of our corporate group, suppliers and subcontractors, as necessary for the purposes (and on the legal basis) set out in this notice.
    • If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you. Legal basis: our legal basis for this processing is likely to be: our legitimate interests pursued would typically include our interest (and that of our shareholders) in negotiating and concluding the relevant transaction, and our interest (and that of our users) in financing the business and ensuring the development and continuity of the Services.