FRENZIES EARLY ACCESS
Privacy Notice

Version 1

Date of Issue: 27 September 2024

Introduction

Who are we?

We are NDREAMS LIMITED, a company incorporated and registered in England and Wales with the registered address at Spectrum Point, 279 Farnborough Road, Farnborough, Hampshire, United Kingdom, GU14 7LS, and registration number 04362105 (“nDreams”, “we” or “us”), and we are a virtual reality games developer and publisher.

Where we decide the means or purpose of processing your personal data, nDreams is the “controller".

What is this Privacy Notice about?

This Privacy Notice explains how nDreams collects and processes personal data, as a controller from users (individually referred to as a “User” and collectively referred to as “Users”) of FRENZIES EARLY ACCESS (“Game”) and any services provided by nDreams in connection with the Game (“Services”). “You” and “your” shall refer to any User.

Please note, the Game, the Services and this Privacy Notice may refer to websites or services not operated by nDreams. You should refer to the privacy notices on those websites and services to understand how they process personal data.

Updates to this Privacy Notice:

nDreams may make updates to this Privacy Notice from time to time (for example because our services have changed or because of changes in the law) so do check back in on a regular basis. In some circumstances, we may also appropriately notify Users of any updates. The date this Privacy Notice was last updated can be found at the beginning of this Privacy Notice.

What data do we collect and for what purpose?

We collect personal data directly from Users, related to the use of the Game and Services, and in some cases, from third parties (such as operators of certain third-party services that we use). The data we collect about Users varies depending on what is required for the Services we provide in connection to the Game. The following are the main purposes for the collection and processing of Users’ personal data by nDreams:

• to assist Users who contact nDreams regarding the Game and/or Services for support;
• reporting player behaviour and violations of the Game’s Code of Conduct;
• to help manage user activity in the Game associated with a User’s ID and Profile such as player customisation choices, purchases of virtual items and virtual currency and other entitlements;
• with consent, we will process certain anonymous and aggregated data from Users to understand:
  • how Users are playing the Game to improve, test and monitor the quality and delivery of the Game; and
  • to identify and correct any problems in the Game (such as bugs or problems preventing progression); and
• to monitor and manage in-Game interactions between Users.

All data collected and processed for the above purposes is done under one of the following legal bases:

• Contract: where it is necessary, nDreams will use personal data in order to perform a contract with the User and ensure we are able to complete any related obligations under the contract with our Users.
• Legitimate interest: personal data may be needed for nDreams’ business purposes, as balanced against the potential impact on a User’s privacy rights. This includes common purposes, such as to communicate with a User and respond to their requests, to ensure the smooth operation of the Game and Services along with working on improvements for the Game.
• Legal: nDreams processes personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement officials or in accordance with the relevant regulatory frame works to comply with applicable youth protection laws such as the Online Safety Act 2023 in the United Kingdom.
• Consent: for the processing of some data, nDreams will be relying on the consent from the User, such as analytics. Consent can be withdrawn at any time, either in-Game on the Preferences screen or by contacting us via one of the contact emails listed in the Contact section of this notice.

Information you provide to nDreams

Where a User contacts nDreams’ support email address for the Game or submits a report regarding another User’s behaviour, a User may provide the following personal data to nDreams:

• their User ID and User Profile;
• their name;
• their email address; and
• any other personal data provided by the User to nDreams (for example, their telephone number to be contacted by).

Please note any missing or incorrect data may not enable nDreams to fully assist with a support request.

Where nDreams runs competitions and prize promotions in connection with the Game, nDreams may collect social media handles/account names as well as any winner’s personal data (such as name, telephone number, email address and residential address (if required for delivery of any physical prize)) as necessary for the performance of any obligations tied to that activity.

Information nDreams collects automatically from Users

The following data is collected automatically from Users either directly through Users playing the Game or by third parties on nDreams’ behalf (for example, from Meta when Meta enables Users to access the Game and Services):

• data such as User ID, User Name, age group category, geographical region, language settings and internet latency;
• in-Game activity and User choices, progression and events (including score, rank and accuracy);
• in-Game purchasing activity and use of virtual currency and virtual items;
• player customisation choices such as use of avatar outfits and weapon skins;
• how long for and when a User plays the Game (including total game time and total session times);
• audio recordings and transcriptions of such audio recordings where a User’s voice chat has been flagged by our voice chat moderation tool VoicePatrol (operated by Optico, Inc.) in violation of the Game’s Code of Conduct; and
• crash reports containing anonymised device and performance information.

Anonymous and aggregated Data

To improve, test and monitor the quality and delivery of the Game and Services and to identify and correct any problems in the Game (such as bugs or problems preventing access to or full performance of the Services), the following anonymous and aggregated data will be collected:

• gameplay settings when playing the Game and how a User plays the Game (examples of information include use and choice of weapons and outfits, how many shots fired and how many times a User has been hit); and
• the country of the device which they are using to play the Game.

We process this data where Users have consented to do so when prompted on first start-up/boot-up of the Game. Consent can be withdrawn at any time on the Preferences menu in the Game.

How long do we keep your personal data for?

nDreams shall only store and retain the data for as long as necessary for the purposes outlined above and until it is no longer required for nDreams. As a general principle, we will retain data necessary to provide the Game until it is discontinued or no longer supported. We may need to keep personal data for longer if required by law, if we are required to keep such data, we will ensure that it is secure and your rights set out below can still be exercised where possible.

Data storage, transfers and disclosures

nDreams may share or disclose your personal data with third parties as set forth below, in accordance with the purposes set out in the notice and the relevant legal basis:

• Affiliates and group members: We may disclose your personal data to other members of our corporate group (such as to the developer of the Game Near Light Limited) in order to carry out the processing set forth in this Privacy Notice. For example, for purposes of assisting us to develop and improve the Game, conduct analytics and market the Game. Our subsidiary or affiliate companies are subject to this Privacy Notice when they use your personal data.
• Service Providers: We may engage vendors, agents, service providers, and others to provide services to us or to You on our behalf, such as support for the internal operations of the Game as well as related offline product support services, data storage and other services such as Amazon Web Services (our cloud web services provider), Datadog, Inc (our observability tool for monitoring workload on infrastructure services) and VoicePatrol operated by Optico, Inc. (the Game’s voice chat moderation tool used to monitor unauthorised content). In providing their services, they may access, receive, maintain or otherwise process personal data or your anonymised data on our behalf. Our contracts with these service providers do not permit use of your personal data for their own marketing and other purposes.
• Law enforcement, tax or government authorities or tribunals: We may disclose personal data to meet requests from regulatory, prosecuting, law enforcement, tax or government authorities or tribunals or disclose to meet obligations or to exercise our legal rights, or to prevent crime and fraud.
• Investments, mergers, acquisitions or disposals: If involved in an investment, merger, acquisition or sale of our organisation or assets, personal data may be shared as required in the pursuit of the legitimate interests of us, our shareholders, customers and other parties to such a transaction, unless such disclosure is not necessary or those interests are outweighed by prejudicial impacts upon you.

For the avoidance of doubt, nDreams does not sell your personal data to third parties.

nDreams is based in the United Kingdom and may from time-to-time use subcontractors based in other countries, as a result, there may be occasions where we transfer personal data to a country that does not provide an adequate level of protection. Where this is the case, we will use the Standard Contractual Clauses as provided by the Information Commissioner’s Office to ensure that personal data is given the same level of protection it has in the United Kingdom. For more information, please contact us using the details provided in the section below.

Your Rights

Users of the Game and Services have several rights regarding how your personal data is processed. Below are the rights a User can exercise:

• ask us to send a copy of your personal data to you or someone else;
• ask us to restrict, stop processing, or delete your personal data;
• object to nDreams processing of your personal data;
• object to use of your personal data for direct marketing purposes; and
• ask us to correct inaccuracies in your personal data.

If a User would like to exercise any of the above rights, they may reach out to nDreams via one of the contact emails listed in the Contact section of this notice.

Please note, we may not be able to action certain requests due to:

• the legal basis we are relying on to process your personal data;
• it would interfere with another User’s own privacy rights;
• it needs to be retained to satisfy certain legal requirements or obligations or for security purposes; or
• otherwise, there are valid grounds under data protection laws to allow us to do so.

Users under the age of 13

nDreams does not knowingly solicit data from or market the Game to children under the age of 13.  If a User under the age of 13 accesses the Game through a parent-managed Meta account, Meta’s and the Game’s default privacy settings ensures that nDreams does not collect any personal data from that User other than the personal data necessary to operate the Game. Please note that the default privacy settings cannot be changed until the User is the age of 13.

If a parent or guardian becomes aware that a User under the age of 13 has provided nDreams with data without their consent, they should notify us at data@ndreams.com. We will delete such data without delay.

How to contact us

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: data@ndreams.com or frenzies.support@ndreams.com. 

When making a request related to your data subject rights (such as when withdrawing consent or a deletion request) please include the nature of the request in the subject line of the email in order to enable us to act promptly on the request.

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 outside of the UK, you can submit a complaint to the supervisory authority in your country).