privacy notice

Folk Law, Part I

Last updated: November 25, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Free Privacy Policy Generator.

1. Introduction

Who are we?

We are Chock Hoss Ltd, a company with registration number 14307814, and with registered address at Preston Park House, South Road, Brighton, East Sussex, United Kingdom, BN1 6SB (“we”, “us” or “our”), and we are a games development studio.

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


What's this notice about?

This notice explains how we process personal data, as a controller, in relation to individuals (“Users”, “you” or “your”) who play our game “Threkka” (“Game”), which is available to play on the Apple App Store.

We update this notice from time to time, so you should check back in on a regular basis.

Please note that the Apple App Store, and other websites or services mentioned in the Game, are not operated by Chock Hoss Ltd. You should refer to the privacy notices on those websites to understand how they process personal data.


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 personal data to you or someone else
  • Ask us to restrict, stop processing, or delete your personal data
  • Object to our processing of your personal data
  • Object to use of your personal data for direct marketing purposes
  • Ask us to correct inaccuracies in your personal data


How to Exercise Your Rights

You can exercise any of the rights listed above by contacting us using the details in the “How do you contact us?” section. We will respond to your request within one month (or any extended period permitted by law). We may ask you to verify your identity before responding.


Additional Regional Rights

If you are located in Canada, Australia, or New Zealand, you may also request access to, or correction of, personal information we hold about you. We will take reasonable steps to verify your identity before responding and will handle all such requests in accordance with the legal requirements of your region.


How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: chockHossLegals.

If we can’t resolve your issue, you can contact the relevant regulator or supervisory authority in your country. For example, if you are based in the UK, you can get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns.

If you are located in the EU/EEA, you may contact the data-protection authority in your country of residence. A list of supervisory authorities is available on the European Data Protection Board website.

2. How We Use It

To deliver our services to you

What:

We use:

  • Information relating to your workouts (i.e. any exercise or movement) and heartrate by using Apple Inc.’s HealthKit, which provides a central repository for health and fitness data, using information collected from your wearable technology (including Apple Watches and Garmin wearables) or third-party applications (such as “My Fitness Pal”, “Strava”, and “Nike Run Club”).
  • Information relating to your in-Game purchases, including transaction information (such as transaction date, transaction currency and nature of transaction) and your Muxels balance (which is the Game’s premium currency).
  • Information relating to any crashes you may encounter. We use Unity's built-in Cloud Diagnostics system to send information – which may include data such as device type, operating system, and a randomly generated installation ID – in the event of an application crash. The installation ID does not personally identify you and is used only for anonymous diagnostic purposes. No names, emails, or personal information are collected or stored. Crash reports are used solely to improve app stability and performance, and are not shared with third parties.

You can find out more information about how HealthKit collects this information here.


Why:

We collect and use this information to enable you to play the Game, and use the Game’s functionalities.


How (our "legal basis"):

We may process this personal data:

  • Where it is necessary for the performance of the terms which we have in place between us and you.
  • To pursue our legitimate interests in ensuring that we are able to deliver a high-quality and enjoyable game.
  • To pursue your legitimate interests in ensuring that you get the best out of your experience when playing the Game.

Regarding information concerning your workouts and heart rate, we will only collect this information if you provide your explicit consent to do so, by opting-in to allow us to access this information on the “Health Access” page. You can withdraw or reapply your consent for granting us with access to this information at any time by changing the Game’s permissions within the “Health” options of your iPhone’s Settings app.


Additional Health Data Protection

We do not use information obtained through Apple HealthKit or any other health source for marketing, advertising, or profiling. Health-related information is used solely to support gameplay, is kept local apart from during rare customer support cases, and is never shared with third parties except as strictly required to operate the Game.


Recipients:

We may share your information with Apple Inc. to enable us to deliver the Game to you, and certain related functionalities and features (such as payment processing functionalities).


Use of Third-Party Processors

We use trusted third-party service providers to support analytics, diagnostics, and game performance. These providers process data only on our behalf and in accordance with our instructions, and we ensure that they offer appropriate data-protection safeguards. They do not use your personal data for their own independent purposes.


How long we keep this information for:

We keep your personal data only for as long as necessary for the purposes described in this Privacy Notice. Gameplay data is stored locally on your device until you delete or reset the Game. Analytics and crash-diagnostic data collected through third-party services are retained only for the period required to analyse performance and stability (typically between 30 days and 24 months, depending on the provider). We will delete or anonymise any identifiable analytics or diagnostic information linked to you upon request, unless we are required to retain it for legal or regulatory reasons.



To understand how you play the Game

What:

We collect the following information using Unity Analytics:

  • Certain “identifiers” (including Session ID and User ID), and any unique password which we may generate to enable you to share your “save file” with us.
  • Information which identifies which country Users are located in.
  • Information relating to Users’ in-game achievements and events, progress and scores (including the number of your Champs, their overall Fitness Levels, your average upgrade levels of in-game Equipment, and – for customer service requirements and only with your agreement – your save file).
  • Information relating to the device and technology which Users use to play the Game (including device battery level).
  • Information relating to Users’ Game settings (such as the language settings and device volume level).
  • Information about errors which Users encounter when playing the Game.

Why:

We process certain information relating to the device on which you are accessing the Game to: (i) identify you; (ii) understand how you play our Game (including when and for how long); (iii) improve, test and monitor the quality and delivery of the Game; (iv) identify and correct any problems on the Game; and (v) perform essential business operations.


How (our "legal basis"):

We only collect this information where you have opted-in to disclose this information, via the Game’s “Options” page.

You can opt-out of disclosing this information to us (i.e. withdraw your consent) by updating your preferences via the Game’s “Options” page.


Recipients:

We collect this information using Unity Technologies’ analytics services. Where you have opted-in to disclose this information, via the Game’s “Options” page, Unity Analytics functionality is activated which collects this information. For further information about how Unity Technologies collects this information, you can find out more information here. We may also use Unity’s or a third-party's cloud services to enable you to share your save file with us so that we can identify any problems that may affect your gameplay.


How long we keep this information for:

We keep your personal data only for as long as necessary for the purposes described in this Privacy Notice. Gameplay data is stored locally on your device until you delete or reset the Game. Analytics and crash-diagnostic data collected through third-party services are retained only for the period required to analyse performance and stability (typically between 30 days and 24 months, depending on the provider). We will delete or anonymise any identifiable analytics or diagnostic information linked to you upon request, unless we are required to retain it for legal or regulatory reasons.

3. Storage, Transfers and Disclosure

Storage & Transfers


International Transfer Safeguards

Where personal data is transferred outside the UK or EU/EEA, we use legally recognised safeguards to ensure that your information remains protected. These safeguards may include the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or equivalent legal mechanisms. You may contact us if you would like more information about the safeguards applied to your data.


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. 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 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 our products and services.

4. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. If we make material changes, we will provide notice within the Game or on our website. Your continued use of the Game after such updates means you acknowledge the revised Privacy Notice.