BEAR HUG ENTERTAINMENT - PRIVACY POLICY

PRIVACY POLICY

This is the Privacy Policy (the "Policy") of Bear Hug Entertainment Limited a limited company registered in England and Wales with a registered company number of 11779479 and a registered address at Units A-J Austen House, Station View, Guildford, Surrey, GU1 4AR (hereafter "Bear Hug", "we" or "us"). This Policy describes the ways in which Bear Hug collects and uses information about you when you visit our websites, including those at www.bearhugentertainment.com and www.alicelegends.com (the "Websites" and each a "Website") or use any of our mobile applications (each an "App").

Bear Hug may change this Policy at any time in which case we shall notify you of any changes to this Policy. The changes will apply to your use of the Websites and/or App (as applicable) after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Websites and/or App (as applicable). If you continue to use the Websites and/or App (as applicable) after the date on which the change comes into effect, your use of the Websites and/or App (as applicable) indicates your agreement to be bound by the new Policy.

For the purposes of data protection legislation, Bear Hug is the controller for the processing of your personal data. Bear Hug has notified the Information Commissioner's Office ("ICO") of its processing of personal data. Bear Hug's registration number is ZA550205.

This Policy was last changed in September 2024.

SECTION A - Your use of the Websites

  1. Information which is collected when you use the Websites: Bear Hug may collect the following information from you via the Websites if you choose to contact us via either Website, namely your name, e-mail address and details of your particular query together with any other contact details that you may provide to us such as your phone number.

  1. Processing ground: Bear Hug relies on the contractual necessity processing ground to collect the items of information listed in 1 above, as this information is required in order for Bear Hug to answer your particular query or support request.

  1. How the information about you on the Websites is used: The information about you described in paragraph 1 is used by Bear Hug:

  1. to provide technical support in relation to your use of the Websites and its Apps and troubleshooting/answer your particular query; and

  2. to, in certain situations, transfer such data to its storage provider and/or combine it with its third party partner's data as described in paragraph 7 below.

SECTION B - Your use of any Bear Hug App

  1. Information which is collected by any App: Bear Hug may collect the following information when you use one or more of Bear Hug's Apps:

  1. information relating to tracking/analytics behaviour as you use the App in question, some of which is collected in cooperation with various third party partners as described in paragraph 7 below. This includes information such as unique device ID, the length of time you spend playing our Apps and other metric/statistical information. Whilst the majority of this information is not personal data, Bear Hug may combine it with e.g., the information in paragraph 4(d) and/or (e) and hence it will become personal data as a result;

  2. if you consent, information that allows our advertising partners (as listed in paragraph 7 below) to serve targeted adverts to you, such information as set out in such advertising partner's privacy policy referenced in paragraph 7 below;

  3. where applicable, Bear Hug may collect information relating to your ZEBEDEE gamertag. This feature is available, although not compulsory, in order to allow you in the applicable Apps to cash-out your pay-outs (if any). In the future, and if you elect to log into the applicable Apps via your ZEBEDEE account, Bear Hug may also collect information relating to your ZEBEDEE account including your user identification, wallet address and avatar. For certain Apps this feature will be available, although not compulsory, in order to allow you to save your progress, play across multiple devices, use your avatar in the Apps and cash-out your pay-outs (if any) more promptly;

  4. where applicable, Bear Hug may collect your email address in order to allow you in the applicable Apps to cash-out your pay-outs (if any);

  5. where applicable, Bear Hug may also collect information relating to your age to ensure you meet the minimum age requirements to access the Apps or specific features of the Apps. Whilst this information is not personal data, Bear Hug may combine it with e.g., the information in paragraph 4(d) and/or (e) and hence it will become personal data as a result.

  1. Processing ground: Bear Hug relies on the legitimate interests processing ground to collect the items of information noted in paragraph 4(a). The items collected, in being limited to analytics information of a technical nature do not outweigh your rights and freedoms in having such data collected and are used by Bear Hug to help refine, support and further develop the App for your benefit. Bear Hug relies on consent to collect the information noted in 4(b). Bear Hug relies on the contractual necessity ground to collect the information noted in 4(c) because (i) having your user identification is required to provide the features allowing you to save progress and hence play across multiple devices; (ii) having your gamertag or wallet address is required in order to provide the feature to cash-out your pay-outs (if any) as Bear Hug needs some mechanism to authenticate you to allow for any pay-outs to be made; and (iii) having your avatar is required if you wish to use your avatar in the Apps. Bear Hug relies on the contractual necessity ground to collect the information noted in 4(d) because having your email address is required to provide the feature to cash out your pay-outs (if any) in certain Apps. Bear Hug relies on the contractual necessity ground to collect the information noted in 4(e) because your age is required in order to ensure that you meet the minimum age requirement to play any App.

  1. How the information about you on the App is used: The information about you described in paragraph 4 may be used by Bear Hug as follows:

  1. to enable Bear Hug to undertake administration tasks in relation to the management of the App and to provide the services that Bear Hug provides via the App to you, namely to permit you to access, play mobile games and, where applicable, cash-out pay-outs via the App;

  2. to, if you consent, serve you adverts that are more personalised to you;

  3. to tweak, tune and facilitate the improvement of the App;

  4. to provide technical support in relation to your use of the App and troubleshooting;

  5. to prevent fraud or illegal activities;

  6. to use such information in anonymised form for its own research and marketing purposes; and

  7. to share with third parties as described in paragraph 7 below.

SECTION C - General

  1. Sharing information with third parties: Bear Hug shall not pass your information to any third party (other than as described in this paragraph). Your information may, subject to Bear Hug's obligations to comply with applicable data protection legislation, be shared with the following third parties:

  1. if you consent, we may display certain personal information such as your player name or avatar within an App, for instance on a winners' board;

  2. if you consent, we will share certain personal information with our advertising partners, such as Unity, AppLovin, Meta, Vungle and/or DT Exchange in connection with the placing of personalised adds. You can remove your consent to this at any time via the Settings page within the App. You can find more details on how each of these entities handles your information, including how to opt-out of personalised adverts and how to contact it in relation to deleting information, in their privacy policies being: (a) for Unity: Privacy Policy; (b) for AppLovin Privacy Policy; (c) for Meta Privacy Policy; (d) for Vungle Privacy Policy; and/or (e) for DT Exchange Privacy Policy.

  3. various external service providers that we engage to provide services for us, including analytics partners such as Google Firebase and Microsoft Azure Playfab. Again, you can see the information that Microsoft Azure Playfab collects about you and how your information is dealt with in its Privacy Policy, and for Google Firebase in its Privacy Policy and here. The type of information that is collected in co-operation with such service providers depends on the nature of the service that they are providing but generally comprises items such as IP address, device identifiers, interaction with adverts and the game and so forth;

  4. its storage and hosting provider (Microsoft Azure Playfab);

  5. its Bitcoin payment provider (Zebedee);

  6. its online gift card payment provider (GiftPay or Runa);

  7. having taken precautions to maintain the security of such information, Bear Hug may share this information with its regulator;

  8. in anonymised form, Bear Hug may share the information with:

  1. any third party, in relation to the sale of some or all of Bear Hug's business, or its assets, or as part of any business restructuring or reorganisation. Bear Hug will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this paragraph;
    or

  1. law enforcement agencies in compliance with law enforcement.

  1. Links to third party websites and third party adverts: Bear Hug is not responsible for the privacy policies and practices of other sites even if you access them using links from the Websites or App. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Websites or App from a third party site or via a social network (e.g. X), Bear Hug is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

  1. Security: Bear Hug has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.

  1. Storage and Data Retention: You information is stored by us, via our third party storage provider, in the EEA and USA and we have appropriate contracts in place to ensure the adequacy of such transfer. You can ask for your information to be removed at any time by e-mailing us at privacy@bearhugentertainment.com

SECTION D - Contact with Bear Hug

  1. Information Bear Hug collects and uses if you contact us or make complaints: When Bear Hug receives complaints by email it files any relevant document and may retain details of the complainant and other individuals identified in the complaint. Bear Hug will only use this information to process the complaint. Bear Hug shall retain information in relation to a complaint for 6 years after its closure, in a secure environment and access to it will be restricted on a 'need to know' basis.

SECTION E - Contact and Your rights

  1. Bear Hug Details: If at any time you would like to contact Bear Hug you can do so by sending an e-mail to us at privacy@bearhugentertainment.com or write to us at "Data Protection Query, Bear Hug Entertainment Limited, Units A-J Austen House, Station View, Guildford, Surrey, GU1 4AR". This is Bear Hug's registered address and we are a company incorporated in England and Wales with company number 11779479.

  1. Your Rights: You can contact us using the details set out in the paragraph above if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. You may also contact the ICO at any time.