Disney Speedstorm Privacy Policy 

This Privacy Policy is effective as of April 1, 2023, and was last modified on May 23, 2024.

Your privacy is important to us, and we take our responsibility of caring for it seriously. We respect your privacy rights and are committed to protecting the personal information that is collected about you. This privacy policy (“Privacy Policy”) describes what information Gameloft collects and how we use, disclose, and store it (collectively referred to as "process" or "processing").  It also describes your rights and choices about such collection, use, sharing, and storage. If you do not want Gameloft to process your information in the ways described in this Privacy Policy, you may not be able to take advantage of all Game features.

Gameloft SE, including its subsidiary companies (“Gameloft”), processes your information as a data controller in connection with, and in order to provide and develop, Gameloft’s Disney Speedstorm game (“the Game”) and Gameloft’s game-related web services.This includes the website available at disneyspeedstorm.com and associated domains (“the Website”) (together referred to as the “Services”).

 

All of our Services are governed by this Privacy Policy. This includes:

 

– the Website (including a dedicated web page to purchase, install, and access the Game on PC); and

– the Game, whether used on and/or accessed via PC and/or Console and/or a mobile platform, and/or the Website. 

By using the Services, you hereby acknowledge that you have reviewed this Privacy Policy.

Gameloft is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program ("ESRB Privacy Certified"). To protect your privacy, we have voluntarily undertaken this privacy initiative. All the Services displaying an ESRB Privacy Certified seal have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, we are subject to audits of the Services and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified. 

If you have any questions, comments, or concerns regarding our Privacy Policy and/or Gameloft's privacy practices, please refer to the “How to contact us” section below. 

1 – Information we collect

Gameloft collects information from you, including personal information, in multiple ways.  Personal information includes information such as your: 

• Contact information (such as your email address)

• Your username and password 

• Profile information (such as your player name, player ID, stats, avatar, and motto)  

• Information that you provide when seeking help from customer service (such as your email address, your general location [country], and/or player ID)

• Other information you provide us (such as information used to identify a lost account)

Gameloft collects information from you, including personal information, in multiple ways, including information you provide to us directly, information we collect automatically when you use our Services, and information we obtain from our partners. We describe each type of information collection below.

a – Information you provide to us directly when you:

(a) access the Services and/or create an account
(b) play our Game and/or use the Services, including the Website
(c) make a purchase within our Services (including purchasing the Game on the Website and making in-Game purchases)
(d) sign up for a newsletter on the Website
(e) sign up to promotional offers on the Website
(f) contact Gameloft customer service through the Game and/or the Website (for instance, to take part in technical-support sessions or to exercise your privacy rights as described below)
(g) enter a contest, event or sweepstakes, or participate in a challenge held by Gameloft (either on the Website or in the Game)
(h) signal interest in participating in a playtest
(i) share or contribute to our social media channels and other community websites  

 b – Information we automatically collect directly from you when you use our Services

• Information about your Game progress and activity

• Information about your interactions with other players (for instance, when you view another player’s progress on a leaderboard or when you befriend another player)—please note that these features are disabled for users under the age of 13 in the United States or under 16 in the EU/EEA (except where applicable law establishes a different age for a child)

• Information about your browsing activities, which we collect using cookies and similar tracking technologies when you use the Website (please note that cookies are only set in the web environment; we do not use them in the Game—you can refer to our Cookies Policy to learn more about opting out of such technologies)

• IP address and device identifiers (such as your device ID)

• Information about your device (such as device name and operating system, browser information, including browser type and the language you prefer)

• General location information (country and/or state—not your precise address)

• Gameloft player ID

• Information for technical performance monitoring, debugging/troubleshooting and Game-level analytics (statistical reporting) purposes (including IP addresses, user and/or device identifiers) 

c – Information we obtain from our partners

• Information we may receive from your console and/or the platform you access the Game from. This may include console identifiers for providing eligible players with cross-platform features, or information about your country selection to provide relevant language settings.

• Information from billing partners (when you purchase the Game on the Website and when you make in-Game purchases)

2 – How we use your information

2.1 – Under normal circumstances, we will only use your personal information when:

• we have a legal obligation to use your information (for instance, if there is a valid legal request from law enforcement for us to provide access to, or disclose, information in relation to an investigation)

• we have your consent to do so

• we need to use the personal information to fulfill a contract with you and provide you with the Services, such as customer support services, bug and service-error detection, and fraud prevention

• we need to use the information for our legitimate business purposes (including when we analyze your gaming activities to protect and improve our products and services) except when such use is overridden by your data subject rights, or when we have a legal obligation to collect personal information from you

 We primarily use the information to provide you with a better browsing and gaming experience, but we also use your information, both individually and combined, as follows:

2.2 – To operate our business and to enhance your experience, including to:

• provide you with the Services

• where relevant, adapt the Services to comply with the applicable laws of your country of residence, including laws relating to children and minors (as defined in Section 7 of this Privacy Policy)

• provide gaming experiences that you may like and functionalities you have subscribed to, based on your Game progress

• track your use of the Services (in accordance with applicable laws, including those relating to children and minors as defined in Section 7) to help us learn more about your browsing and gaming activities and understand your preferences and tendencies, so that we can personalize your experience, provide you with in-Game offers and notifications that are tailored to you, and otherwise enhance your gaming experience

• facilitate sharing on social networks, where this option is available

• register your participation in a contest and contact you in the event of a prize

• organize and ensure the proper management of events (e.g. registering your participation in an event, granting access to an event, prize delivery)

• offer you the opportunity to take part in playtesting (game tests)

• protect against cheating, crime or fraud, or for other security reasons

• identify and fix bugs and service errors

• use it for administration, analytics, research, and optimization

• compile statistics

• comply with all regulatory and legal requirements, and answer any requests from data protection or privacy authorities or any law enforcement or regulatory agency

• respect security requirements (e.g. performing audits)

2.3 – To provide you with support, communicate with you and respond to any requests or questions you have submitted through our customer support.

 

2.4 – To personalize our communication with you, including to:

• handle your subscription to, and opting-out of, our newsletters

• contact you to promote our Services and contests we may offer

• send you, with your prior consent, promotions or marketing materials (we will provide you with the opportunity to opt out of receiving such materials in the future)

• offer in-Game surveys

• personalize your content and offers

2.5 – Upon subscription to newsletters from the Website, only users over the age of 13 in the United States and over the age of 16 in the EU/EEA (except where applicable law establishes a different age threshold) may opt in to the sharing of their email address with selected partners for the sole purpose of improving the targeting of Gameloft's advertising campaigns on external sites, including by identifying similar audiences/prospects. Please refer to the section “Selected Partners – Ads Campaigns on External Sites” of this page to view our selected partners.

For some of the purposes described above, Gameloft may use and perform analytics. Analytics information supports business analysis and operations, allows product development, improves products and Services, personalizes content, and makes recommendations. 

3 – How we retain your information

Gameloft retains, uses and stores your information as long as you are using our Services, and for up to two (2) additional years, which may be necessary to fulfill all the purposes described in this Privacy Policy, in compliance with the applicable laws of your country of residence. 

We want to inform you that a longer retention period could be required to resolve disputes, or respond to requests from law enforcement or regulatory agencies. In such cases, the collected information will be used and stored until the request is closed. 

We may also store aggregated, anonymized data.

4 – How we share your information

4.1 – With Gameloft entities

In order to operate the Services, your personal information may be transferred to other Gameloft studios or entities and subsidiaries located worldwide, as described below. (See Section 5 on "International operations and transfers of your information.")

4.2 – With third parties

We use third-party service providers that have limited access to your information for specific purposes, such as administration, analytics, optimization, billing, prize delivery, marketing assistance, customer service, and data analysis. In the mobile version of the Game, these third-party service providers include:

They assist us with our operations. We have agreements with these service providers that permit them to use your information for these purposes only and limit other uses.

While using our Services, whenever you decide to—and where this option is available—you may use social sharing features to third-party social network sites. This may allow the sharing and collection of personal and non-personal information, both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information collection practices.

4.3 – With authorities

We reserve the right to report to law enforcement agencies certain conduct and activities that we, in good faith, believe to be illegal. We will investigate or take action to counter illegal activity, suspected abuse or unauthorized use of the Services, or to protect the property or safety of others. We may also disclose your information if required by any law or court order worldwide, if the information relates to actual or threatened harmful conduct. In that case, we will consider applicable local laws, the nature of the order, as well as the legitimacy and proportionality of your information.

4.4 – In case of sale of our company

In connection with any sale of our company or any line of business (including the assets relating thereto), customer information generally is one of the transferred business assets. In the event of any such sale or disposition of any or all of our business, your information may be transferred to the acquirer. 

5 – International operations and transfers of your information

As part of our international operations, we may transfer personal information to our affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership of Gameloft SE) from time to time for our legitimate business purposes.

Gameloft is headquartered in France, and we have operations, entities and Services provided in Canada, the United States and throughout the world. We have taken measures to ensure that your personal information is treated securely and lawfully, and that it will receive an adequate level of protection in the jurisdictions in which we process it. 

6 – Security and confidentiality of your personal information

We have implemented security measures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the personal information collected through the Services. 
We take, and force applicable third parties to take, reasonable precautions to protect your personal information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use of, or access to, your information that is under our control. When we use third parties to assist us in processing your personal information or credit card information, we take reasonable steps to ensure that they comply with this Privacy Policy and otherwise protect your personal information (including any credit card information).

If there is a breach of security involving your personal information, including credit card information, from our Services, we will inform you immediately according to your local regulations relating to the notification of information breaches, and take commercially reasonable steps to rectify such breach.

If you believe your personal information is being improperly used by us or any third party, please immediately notify us via email at DataProtectionSupport@gameloft.com.

7 – Children 

The privacy and safety of children online is paramount to Gameloft. For the purposes of this Privacy Policy, we define a "child" or an "underage user" as a user under the age of 13 in the United States, and under the age of 16 in the EU/EEA (except where applicable law establishes a different age for a child). 

We adhere to the following practices tailored to the method by which children may access the Game and Services:

PC or Console Platforms: The Game will be accessible to children on PC and/or Console platforms in compliance with applicable law and platform policies.

When accessing the Game on PC and/or Console platforms, parents and/or guardians of children can set age or age categories and establish privacy settings when creating and managing their children’s accounts. Please review the terms and privacy disclosures specific to the platform service provider (e.g., Nintendo Switch™, Microsoft Xbox, etc.) for more details. 

Mobile Platforms: Children may access the game on mobile platforms in compliance with applicable law and the policies of the mobile storefronts. Gameloft implements specific restrictions for children using the Game on mobile applications as follows:

• Limits on children's data collection, use and sharing: Gameloft will not collect, use, or share personal information, as defined by applicable law, from children without obtaining parental consent unless an exception to parental consent applies or applicable law authorizes an alternative method of compliance.

• Privacy-protective settings and restrictions: Gameloft will disable social features to prevent children from disclosing personal information to Gameloft and/or to other players, including but not limited to their real name, and to protect them from unsolicited and/or harmful content or interactions.

Website: To access the Game via the Website, children must have a Gameloft account. Parents and guardians must establish such accounts for children in accordance with applicable law. Newsletter subscriptions and promotional offer options will not be available to children and minors.

Other protections:

In addition to these measures, we encourage parents and guardians to teach their children about privacy and how their information may be used online. Children should never disclose their real name, address or phone number, or any other personal information, without their parents' or guardian's prior permission.

If you are the parent or legal guardian of a child and believe your child has provided us with personal information, please fill out this form and we will delete the information from our systems.

Privacy Rights for Children:

To exercise privacy rights on behalf of children, including access, rectification, erasure of information, or opt-out provisions relating to targeted advertising, please refer to the "Your rights" section of this Privacy Policy.

8 – Your rights

Access, Correction, and Deletion Rights: You can ask Gameloft at any time to give you access to your information, to correct your information, or to delete some or all of it. Parents and guardians may also make requests on behalf of their children. Please specify your request through this form. 

Our team will look into your request and answer you within one (1) month, unless your request requires further investigation. We will inform you if that is the case.

We ask that you ensure the information that you provide to us is up to date.  You can correct any information you have provided by contacting us through this form. You represent and warrant that all information you provide us is accurate, and relates to you and not to any other person (unless you are a parent or guardian contacting us on behalf of your child or an authorized person as per Section 9 – Additional information for Californian users).

The data deletion process being irreversible, if we delete some or all of your information pursuant to your request, we will no longer use or process the deleted information. Please note that some exclusions may apply, and that some data may be retained in accordance with applicable law or to respond to regulatory or law enforcement requests. 

Marketing communications: If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.

Cookies: If you want to decline, to allow, or to set your preferences regarding the use of cookies or other tracking technologies on the Website, please refer to our Cookies Policy. Please note that this Cookies Policy applies to the Website only (not applicable to the Game). 

 

9 – Additional information for Californian users

The California Consumer Privacy Act (CCPA) permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year. If you are a California resident, you have the right to know what personal information we collect, the sources from which we collect it, how long we retain it, why we collect and disclose it, and what personal information we disclose, "sell," and "share" about you and to whom.

In the preceding 12 months, we have disclosed the following categories of personal information, collected directly from you or automatically from you within the course of use of our Services, to the following categories of recipients: 

We collect and disclose this personal information for the business and commercial purposes described in our main Privacy Policy, including to provide you with customer service, to perform marketing / user acquisition operations (enabling Gameloft to measure the efficiency of its advertising operations pertaining to the Game on external sites and apps), and to perform analytics operations (to understand the performance and usage of our Services). Such uses and disclosures may be considered a “sale” or “share” under the CCPA. In the previous 12 months, we may have “sold” or “shared” your personal information to the recipients listed in the table above.

We do not sell or share the information of any individual we know to be under 16 years of age. We do not use or disclose sensitive personal information.

You have the right to request that we provide access to the personal information we collect, use, disclose, and sell (or share), and to request the correction or deletion of your personal information. To exercise your rights, please access this form or refer to the “How to contact us” section of this Privacy Policy.

You have the right to opt out of any “sales” or “shares” of your personal information, as defined by California law, by using this form or referring to the “How to contact us” section of this Privacy Policy. 

Authorized persons may exercise the above-mentioned rights on your behalf, using the dedicated section of this form.

If you submit a request on behalf of another person, you need to be 18 years old or over, and we may require a proof of authorization and verification of identity directly from this person.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another person. Additionally, we will not honor your request when an exception applies, such as when the disclosure of personal information would adversely affect the rights and freedoms of another consumer or when the personal information that we maintain about you is subject to an exception under the CCPA.

You have the right to be free from discrimination if you choose to exercise your privacy rights. We will not discriminate against you for exercising your rights.

10 – Third-party services

The Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we and our service providers treat personal information and non-personal information we collect on the Services. By accessing any external sites, including third-party platforms or social networks, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties.

Therefore, you are encouraged to review the privacy policies of all third-party services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external services. 

11 – Changes to our Privacy Policy

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our Services with the date the modifications were made indicated at the top of the page. We will also provide you with additional notice of such changes by sending an alert within the Game. However, you should still review this Privacy Policy from time to time so that you are aware when any changes are made to it. Your continued use of the Services after such change(s) constitutes an acknowledgement that you have read and reviewed it/them. If you would like further information about any recent changes made, please send your request to DataProtectionSupport@gameloft.com and include "Information about Changes" in the subject line. 

12 – Legal disclaimer

This Privacy Policy is governed by the laws of your country of residence. Any dispute arising from the use of the Services shall be submitted to the competent courts of your country of residence. 

13 – How to contact us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us:

1. by sending an email to DataProtectionSupport@gameloft.com

2. by writing to the Gameloft Data Protection Officer, 14 rue Auber, 75009 Paris, France

As previously mentioned, we are a licensee of the ESRB Privacy Certified program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, you can also contact ESRB Privacy Certified directly at: 

 https://www.esrb.org/privacy/contact/ or privacy@esrb.org.