Privacy Policy

This Privacy Policy explains how Departure Gate Studios Ltd (DGS) collects, uses, shares and protects personal data when you use the Departure Gate Studios website, Ascendle® or Ascendle Arena®.

Departure Gate Studios Ltd is the data controller for personal data where DGS decides how and why that data is processed. Company number: 17159156. Email: privacy@departuregatestudios.com.

This policy should be read together with the DGS Cookie Policy and, where relevant, the privacy information provided by a payment provider, app store or sign-in provider.

What this policy covers

This policy applies to personal data connected with the DGS website, Ascendle®, Ascendle Arena®, guest and registered accounts, sign-in, cloud continuity, saved progress, gameplay history, statistics, badges, entitlements, purchases, support, contact and account-deletion requests, and browser, Android and future app-store routes where applicable.

Information we collect

Depending on how you use the service, we may collect or process:

• Account and identity information: email address, sign-in provider information, DGS/Firebase account identifiers and guest or registered account status.
• Gameplay information: saved progress, Daily, Vault and Unlimited records, Arena match results, performance history, statistics, graphs, badges, settings and related gameplay data.
• Purchase and entitlement information: product entitlement, order or transaction reference, purchase route, payment status and information needed to grant, restore, support, refund or revoke paid access. DGS does not need your full payment-card number to provide the game.
• Support and contact information: your name, email address, messages, screenshots, account information and order/reference information that you choose to provide when contacting us.
• Technical and diagnostic information: device, browser or app information, security and error information, service events and similar technical data needed to operate, secure, diagnose and improve the service.
• Advertising and consent information: where advertising, rewarded advertising, cookies or similar technologies are used, information needed to serve, measure, limit or consent to those features.

We do not ask you to provide special category personal data as part of normal gameplay. Please avoid sending sensitive personal information in support messages unless it is necessary for us to deal with your request.

Where information comes from

We receive personal data from information you provide directly, from your use of the games and website, from sign-in and cloud-service providers, and, where you make a purchase, from the relevant payment provider or app store to the extent needed to fulfil and support the purchase.

How we use information and our lawful bases

We use personal data only where we have a lawful basis to do so. Depending on the purpose, this may include:

• Contract: to provide the service you request, maintain an account, save progress, provide purchased entitlements and respond to matters necessary to provide those services.
• Legitimate interests: to operate and improve the games, maintain security and service integrity, diagnose faults, prevent fraud, cheating or misuse, protect DGS and its users, and provide proportionate customer support. Our legitimate interests are the safe, reliable and effective operation of DGS products and services.
• Legal obligation: where processing is necessary to comply with applicable legal, tax, accounting, regulatory or law-enforcement requirements.
• Consent: where consent is required for optional cookies, advertising technologies, marketing or another specific purpose. Where we rely on consent, you may withdraw it at any time.

Payments and app stores

DGS products use one-off purchases rather than recurring subscriptions.

For browser purchases processed by Paddle, Paddle acts as Merchant of Record and processes buyer and payment information under its own privacy terms. Paddle may provide DGS with buyer, order and transaction information needed for product fulfilment, fraud prevention, entitlement management and support.

For purchases made through Google Play, Google processes payment information under its own terms and privacy practices and may provide DGS with purchase or entitlement information needed to provide and support the product. Future app-store purchases will follow the applicable store requirements.

Who we share information with

We may share personal data where necessary with:

• authentication, hosting, cloud-storage and infrastructure providers used to operate DGS services, including Google/Firebase;
• payment providers and Merchants of Record, including Paddle for applicable browser purchases;
• app stores and platform providers, including Google Play where applicable;
• analytics, diagnostics, advertising, consent-management and security providers where those services are enabled;
• professional advisers, insurers, auditors or service providers where reasonably necessary; and
• regulators, courts, law-enforcement bodies or other parties where disclosure is required by law or necessary to establish, exercise or defend legal rights.

We require service providers acting on our behalf to handle personal data appropriately for the services they provide.

International transfers

Some service providers may process personal data outside the United Kingdom. Where UK data-protection law requires safeguards for an international transfer, DGS will rely on an applicable lawful transfer mechanism. This may include UK adequacy regulations or appropriate contractual safeguards recognised under UK data-protection law. Contact us if you would like further information about the safeguards relevant to your personal data.

How long we keep information

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected and for any legitimate legal, security, accounting, dispute-resolution or fraud-prevention requirement.

Account and gameplay data may be kept while an account remains active and for as long as needed to provide account continuity, records and entitlements. Purchase and transaction records may be kept for longer where needed for tax, accounting, fraud prevention, refunds, disputes or legal obligations. Support records are kept for as long as reasonably necessary to resolve and document the enquiry.

When data is no longer required, it is deleted, anonymised or allowed to expire from systems and backups in accordance with the applicable retention process.

Your data-protection rights

Depending on the circumstances and the lawful basis used, you may have rights to request access to personal data, correction of inaccurate data, erasure, restriction of processing, data portability and other rights provided by applicable data-protection law.

Right to object: where we rely on legitimate interests, you may have the right to object to that processing. We will consider the objection in accordance with applicable law.

Where we rely on consent, you may withdraw that consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

To exercise a privacy right, contact Departure Gate Studios Ltd at privacy@departuregatestudios.com. We may need to verify your identity before acting on a request.

If you are in the UK and remain unhappy with how we handle your personal data, you have the right to complain to the Information Commissioner's Office.

Account deletion

You can request deletion of your Ascendle® / Ascendle Arena® account and associated game data through the Account & Data Deletion page.

Some information may need to be retained after an account-deletion request where required for legal, accounting, fraud-prevention, dispute or security purposes. Where retained, it will be limited to what is necessary for that purpose.

Cookies, advertising and similar technologies

The DGS Cookie Policy explains the use of cookies and similar technologies on DGS web services. Where non-essential cookies, advertising or similar technologies require consent, we will provide the applicable choice or consent mechanism.

Security

We use technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. No internet-connected service can guarantee absolute security, but we review the measures appropriate to the data and services we operate.

Children and younger players

Ascendle® and Ascendle Arena® are general-audience word games and are not specifically directed at children. However, we recognise that younger players may use our games. Where DGS processes personal data relating to children, we take account of their age and privacy needs.

If DGS relies on consent as the lawful basis for processing in connection with an online service offered directly to a child, additional UK rules apply. A child aged 13 or over may generally give their own consent for that processing. Where the child is under 13, consent must be given or authorised by a person with parental responsibility, where required by law. This does not mean parental consent is required for every type of processing involving a child; another lawful basis may apply.

If you are a parent or guardian and have questions about a child's personal data, or believe that a child's personal data has been provided or processed inappropriately, please contact DGS so that we can investigate and take appropriate action.

Automated decision-making

DGS does not currently use personal data for solely automated decision-making that produces legal or similarly significant effects on players.

Changes to this policy

We may update this Privacy Policy when our products, providers, commercial arrangements or legal obligations change. The date at the top of this page shows when the policy was last updated.