Effective date: August 23, 2019
Marble It Up LLC (“us,” “we,” or “our”) operates the Marble It Up! cross-platform game application (“Marble It Up!” or “the game”).
This policy tells you about our policies regarding the collection, use and disclosure of your personal data when you play the game, along with the choices you have associated with that data. We don’t think it’s rocket science, but we need to make sure you understand how your privacy rights apply in Marble It Up!
We use certain data to provide the game. By using the game, you agree to the collection and use of information in accordance with this policy.
You are the User (“you,” “your,” or “data subject”), the living individual using the game and who has certain data associated with you as a User.
Our Commitment to Privacy
If you decline to share your data, you will be unable to play in multiplayer, post scores in weekly challenges, or submit scores on the global or local leaderboards. You can still unlock singleplayer cosmetics, play through the entire singleplayer game, and create and play your own custom levels (though you can’t share them), and enjoy user-generated content (UGC) from other users.
PII or Non-PII?
Personally identifiable information, or PII, would include any information that can be used to specifically identify you as an individual, such as your name, email address, address, phone number, or similar information.
Non-personally identifiable information, or Non-PII, consists of information that does not specifically identify you.
Marble It Up! collects only Non-PII to support user-generated content (UGC), stat tracking, and multiplayer. That’s it. We do not collect PII. And the way our data is architected…we can’t even if we wanted to.
The following sections describe what non-PII we collect and how we collect and use it.
How We Collect Your Information
Your information comes to Marble It Up! from the Apple Game Center via a non-human-readable identifier we call “Opaque ID.” This identifier is unique among all players of the game and consistently assigned to a specific user. This lets us track particular bits of data necessary to help you enjoy the game, while keeping you completely anonymous behind your Apple Game Center nickname.
Basically, Opaque ID is like a big alias shield we hang your nickname and game data on, but we can’t use it to access your Apple Game Center PII.
What We Collect and How We Use It
When you are using the application, we collect data to support the following game features:
User Generated Content (UGC): Your scores are uploaded with replay data about your run for other players to watch, associated with your opaque ID and username. Custom levels are uploaded for other players to download and play, associated with opaque ID and username.
Stat Tracking: Stats and player-unlocks are associated with opaque ID and stored on server to securely award rare cosmetics and prevent accidental deletion of local save game data.
Multiplayer: Opaque ID and username are used to associate your account with your online profile. Usernames are used in-game over the network for player identification while opaque ID is used to keep sensitive multiplayer info like your Skill-Rating for matchmaking.
To get a little more technical, we collect these specific data points:
objectID – random unique ID for user entry
playerID – Opaque ID
statblock – zipped JSON game stat data (times jumped, meters rolled, etc), none of this is PII
unlocks – string array of in-game unlocks earned
banned – boolean value blocking score uploads and online play
createdAt – Date object for user entry creation
updatedAt – Date object for last update time
We use two third-party services to power Marble It Up! Both are contractually obligated to use your game data only to support the game, not for any other purpose. We don’t share data with them, but since they provide our server backbone for multiplayer gaming, your Opaque ID-shielded data goes through each service.
Amazon Web Services (AWS), to provide multiplayer server hosting. AWS tracks the same limited data we track. That’s where your Opaque ID lives. Amazon can’t see anything we can’t see.
Photon, to provide multiplayer matchmaking and multiplayer packet tracking. Photon tracks only your IP address and your Opaque ID, but none of the other stats. Note that neither Marble It Up LLC nor Photon store or save your IP address, and we don’t have any correlating data about you that would allow us to use it to obtain any PII. Finally, Photon’s service doesn’t include analytics.
Our Backend, to track multiplayer progress and other persistent game state.
The difference between data we collect/use on our Photon backend arrangement versus data the game collects and then stores with Apple is as follows:
Photon data includes an opaque Game Center identifier and your Game Center nickname. We use it to enable multiplayer gaming and letting players find games with others of their approximate skill level.
Our backend’s data includes an opaque Game Center identifier.
Apple data includes game progress and leaderboards, collected via Apple Game Center. This data is managed and stored by Apple, and is removed when you uninstall the game/wipe your iCloud data.
Transfer of Your Data
Your Marble It Up! data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of the jurisdiction where you live.
If you are located outside the United States, please note that we may transfer your data to the United States and process it there.
How Long We Keep Your Data
The only information we collect and keep is secure data about your game state (multiplayer ranking, rare unlocks, global scores, etc). As you saw above, it’s really limited. But once you revoke your permission (see below), we scrub it from our systems. In that case, if you later give permission for us to use your data again, you’ll start multiplayer over with a blank slate.
This assumes you’ve retracted your permission. We won’t scrub the data of active multiplayer players.
At the end of the day it’s your data, and you don’t have to agree to let us use it. Further, even if you gave us permission, you can deny it any time you like by going into Settings or Preferences and making the change.
If you choose not to give us permission to track the data, you won’t be able to access Marble It Up! multiplayer gaming, as described under The Basics, above. You’ll still have full access to singleplayer and your own custom levels, though.
As a game application, some of our users are under the age of 18 (“Children”). We don’t collect personally identifiable information from anyone, including anyone under the age of 18. If you are a parent or guardian and you think your Child has provided us with Personal Data, please contact us.
Because we don’t track PII and only collect a very limited set of data anonymized by Opaque ID, we don’t even know which of our players are Children. Not only that, we don’t have any way of finding out. So there’s no difference in how we treat minors in Marble It Up!
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Marble It Up LLC aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your data. The GDPR is concerned about protection and privacy of personal data like PII.
The game doesn’t track personal data that can be used to identify you, so this section doesn’t practically apply to us. But we think it’s important for you to know your rights, so we’re including this section.
If you want to be informed about what Personal Data we hold about you (none) and if you would like it to be removed from our systems, please contact us. The contact information can be found at the end of this policy.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Marble It Up LLC relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. This only applies if you visit our website.
Security of Data
You are responsible for maintaining the secrecy of your Apple Game Center ID and Apple account information at all times.
The security of your data is definitely important to us, but remember, no method of transmission over the Internet or method of electronic storage is 100% secure. While we and our third-party partners do our best to use commercially acceptable means to protect your data, we can’t guarantee its absolute security.
By email: firstname.lastname@example.org
Via our website: https://marbleitup.com/privacy/
If you do go to our site, you’ll be asked to consent to us tracking cookies. Another button to press.
Company Name: Marble It Up, LLC
Our contact for data privacy: Ben Garney