updated: December 11, 2019
of This Policy to Ultimate Rivals on
Studios, Inc. (“we”, “us”, “our” or “Bit Fry”) with respect to information we
collect from and about users (“you”, “your” or “users”) playing our Ultimate
Rivals™ games (“Games”) on the Apple Arcade subscription service
(“Apple Arcade”) operated by Apple Inc. and its affiliates (“Apple”).
Apple Arcade. If you are interested in learning about Bit Fry’s practices
applicable to the Games played on platforms other than Apple Arcade, or to your
interactions with us via other channels, including our website, please consult
our other published privacy policies applicable to those contexts.
By playing our Games on Apple Arcade, you acknowledge that
reflected by the effective date above. Please revisit this page to stay
we will provide you with additional notice of such changes by providing alerts
within our Games on Apple Arcade.
Our Use of Apple Tools to Limit the User Data We Collect
Bit Fry is committed to transparency about its privacy
background regarding how privacy and security considerations inform the Games’
Certain game features – resumption of gameplay over time and
across devices, multiplayer gameplay and matchmaking, game personalization, and
progression tracking – inherently rely on data specific to individual users
other game developers who offer such features, we need a user identifier in
order to match up individual users with their Gameplay Data. Instead of
using persistent identifiers (except to the extent collected as Contact
Information (defined below) for customer support), such as names, email
addresses, phone numbers, IP addresses, and mobile device identifiers, that are
more susceptible to abuse in the hands of bad actors, we use two types of
identifiers that do not have meaning outside the context of the Games:
The first is a “teamPlayerID” available through Apple’s Game
Center. Each teamPlayerID is specific both to the user and to our
Games. In other words, each user’s teamPlayerID for our Games is
different not only from other users’ teamPlayerID for our Games but also from
the user’s teamPlayerIDs for other developers’ games. The second is a
universally unique identifier (a “URID”) that we randomly generate for each
Our use of these identifiers is designed intentionally in
order to help reduce any privacy impact or security risk associated with
describe certain aspects of our data practices in additional detail.
Collection and Use of User Data.
We collect the following types of information from or about
Data: In order to enable resumption of gameplay over time and across
devices, multiplayer gameplay and matchmaking, game personalization, and
progression tracking, we collect, and associate with Limited Identifiers
(defined below), data concerning your game progression and preferences,
including data concerning achievements, inventory, matchmaking, saved game
states, and customized settings (“Gameplay Data”). Whether and to
what extent we collect and use Gameplay Data for you may depend on what Permissions
we have received from you. Gameplay Data is also stored on your
Apple device and in iCloud.
Identifiers: As described in detail above under “Our Use of Apple Tools to
Limit the User Data We Collect and Store,” we use teamPlayerIDs available
through Apple’s Game Center and URIDs that we generate (“Limited
Identifiers”) in order to enable certain features that rely on Gameplay
Data. Whether and to what extent we collect and use Limited
Identifiers for you may depend on what Permissions we have received from
Center Data: We also use teamPlayerIDs available through Apple’s Game
Center to access information publicly available through a user’s Game
Center profile, such as a user’s avatar and alias (“Game Center Data”).
As described below under “Your Choices,” we obtain user permissions before
collecting and using certain types of user data (“Permissions”).
Permissions are stored in iCloud.
Information: If you request customer support, we may collect information
you provide to us or Apple in connection with such request, such as your
name and email address (“Contact Information”), so that we can reply to
Sharing of User Data with Third Parties.
We may share the above-identified types of user data with third
parties as follows:
Data: with Apple and with our Service Providers (defined below);
Identifiers: with Apple and with our Service Providers;
Center Data: with Apple and with our Service Providers;
with Apple; and
Information: with our Service Providers.
In addition, we may share any other aggregated or
de-identified user data that cannot reasonably be used to identify any user
with our Service Providers and with our licensors, such as the professional
sports leagues and players’ associations with whom we partner in order to offer
certain content included in the Games.
In addition, we may share user data: (i) with our affiliates
or any successor to all or part of our business; (ii) in order to comply with a
subpoena, court order, or applicable law; and (iii) in order to protect the
rights, property, or personal safety of users, us, or the public.
As used above, “Service Providers” means third parties who
perform services (such as data storage and data analytics) on our behalf.
Security of User Data.
We take reasonable measures designed to protect user data
from unauthorized access and against unlawful processing, accidental loss,
destruction, and damage.
Retention and Deletion of User Data.
aggregated or de-identified user data that cannot reasonably be used to
We will retain your user data for the duration of your use
of or access to our Games. We may retain your user data for longer as
necessary and relevant to our legitimate operations in accordance with
applicable laws, such as to resolve any legal proceedings.
After 180 days of inactivity, and if there are no other
reasons why retaining your user data is necessary and relevant to our
legitimate operations, we will delete your user data; however, we may create
(using a one-way hash function) a fingerprint of that data that allows us,
should you choose to reengage with our Games and enable this option, to recover
your user data using data stored locally on your Apple device and in iCloud.
We will delete this fingerprint upon request.
Your Choices and Rights.
You have choices with respect to how we collect and use your
In-Game Permissions: We obtain Permissions before: (i)
generating Limited Identifiers that enable us to track your game progress; (ii)
collecting and using Gameplay Data that specifically pertains to and enables
online gameplay; and (iii) collecting and using Gameplay Data that specifically
pertains to and enables multiplayer gameplay. You may decline to grant
such Permissions, but doing so may result in the corresponding features (e.g.,
resumption of gameplay over time and across devices, online gameplay,
multiplayer gameplay) not being available to you. You have the ability to
review and adjust previously granted Permissions in the Games’ settings menus.
Apple Settings: In addition to the user data stored by Bit
Fry and our Service Providers, data relating to your gameplay will be stored on
your Apple device and in iCloud. To turn off such storage or to delete
such stored data, you must adjust settings on your Apple device and in
iCloud. As a result, however, you may only be able to play in single-player
offline mode, and without the ability to resume saved games. In addition,
if you do not want your achievements to be sent to or displayed in Game Center,
you must sign out of Game Center in your Apple settings.
Rights and Requests: You can contact us at any time using
request we do any of the following: (i) erase or delete all or some of
your user data; (ii) change, update, or correct your user data; (iii) restrict
how we use all or some of your user data; (iv) access your user data and, where
applicable and feasible, request to receive that information in a commonly used
electronic format (or ask for this information to be provided in that format to
a third party); or (v) disclose what user data we collect, use, disclose, or
sell. We will consider and respond to any such requests promptly and
otherwise in accordance with applicable laws. Although we use good faith
efforts to respond to your request, we may not be able to provide and/or
correct the requested user data in all situations. For example, we may
not be able to provide the user data requested if it imposes an undue burden or
expense, requires us to release confidential commercial information, requires
the disclosure of information relating to another person, or requires
authentication of the request that is not feasible in light of our design of
the Games around Limited Identifiers (defined above).
Note for California Residents: With respect to our
compliance with California law, we do not sell personal information, and we
disclose personal information only to the categories of third parties described
above under “Sharing of User Data with Third Parties.” Under California
law, you may have a legal right to make, and we may have a legal obligation to
honor, some or all of the types of requests described under the “Rights and
Requests” section above. You may submit such requests at the contact
you for additional information in order to verify your identify before
responding to such requests, but we will use such additional information only
for purposes of such verification. Under California law, you have a right
not to receive discriminatory treatment by a business for the exercise of your
consumer privacy rights conferred by California law.
Note for European Economic Area Residents: While our focus
is generally on the United States, insofar as we may from time to time process
personal data of individuals in the European Union, Iceland, Liechtenstein,
Norway, or the United Kingdom, which processing may be subject to the European
Union’s General Data Protection Regulation (“GDPR”), please note the following:
Fry is headquartered in Portsmouth, New Hampshire, in the United
States. Our full contact information is provided in the last section
will only process your personal data to the extent applicable law allows
us to do so.
United States has not sought nor received a finding of “adequacy” from the
European Union under Article 45 of the GDPR. We rely on derogations for
specific situations as set forth in Article 49 of the GDPR. In particular,
we collect and transfer personal data to the U.S. to fulfill a compelling
legitimate interest in a manner that does not outweigh your rights and
- If you
have any complaints regarding our privacy practices or how we handle any
requests you make in accordance with the “Rights and Requests” section
above (which requests you may have a legal right to make and we may have a
legal obligation to honor, as dictated by applicable law), you may also
lodge a complaint with your national data protection authority (contact
information available here).
We collect and process information from children in the same
ways as for our user base as a whole, and the design of the Games allows us to
do so in compliance with laws applicable to children’s privacy. The Games
comply with Apple’s Game Center Content Restriction settings described here.
Any comments, concerns, questions, or specific requests
Inc. at email@example.com.