Game privacy notice
This notice supplements DreamersWare's Privacy notice and Cookie policy, which still apply to browsing, orders and payments. Here you find what is specific to the PictureFrames game.
Controller: DreamersWare S.r.l.s., Via Carlo Porta 2, 21052 Busto Arsizio (VA), Italy, VAT IT04151010123. For privacy rights: policy (at) dreamersware (dot) com.
1. What data the game processes
- Without an account: no personal data on the server. Preferences, profile, cart and language stay on your device only (the browser's local storage). The game only sends the anonymous counts described below.
- Account: email address; for each passkey its public key, its identifier and a name (e.g. "Passkey · iPhone"); for each signed-in device the browser and system type, the sign-in date and the session cookie (on the server we only keep a fingerprint of it); email sign-in codes, stored as a fingerprint and deleted after 10 minutes.
- Game: nickname, the photographer's look and audio preferences; games and jobs (game seed, inputs, stars, points, date); coins, coin movements, owned content and gear.
- Orders in euros: items bought, amount, country, order status and reference, the age-16 declaration and the waiver of withdrawal (version, language, time). For the order we also send your IP address and browser to the DreamersWare payment gateway, as described in the general notice.
- Leaderboard: if you choose to appear on it, your nickname and points are public on pictureframes.me; if you untick it, they disappear within about a quarter of an hour.
- Newsletter: only if you choose it (the tick box under the email field when you sign in, or from the Account page), your email address receives the game's news. We keep the date you chose it, the language and, as proof of consent, each subscription and withdrawal with where it happened and the version of the tick-box text.
- IP address: the account service only uses it in memory to limit repeated attempts (for a few hours at most) and does not store it. The web server's technical logs keep it for 7 days.
- Anonymous statistics: when you open the game and at the end of a scene, the game only reports "game opened" (and whether it is the first opening of the day on that device) or "scene played, with how many stars", and whether there is an account or not, with no identifier; the server adds these events up per day. To know whether it is the first opening of the day, the game keeps on the device only the date of the last opening, no code. Once a day, from the web server's technical logs, we count how many pages were viewed, by how many different devices (address and browser are compared only in memory, for that day, and are not stored) and which sites visitors come from. We keep only the daily totals, which cannot be traced back to anyone.
2. Why, and on what basis
- Providing the account, the game, coins and purchased content: performance of the contract (art. 6(1)(b) GDPR).
- Checking games, preventing cheating and abuse, protecting the sending mailbox: legitimate interest (art. 6(1)(f) GDPR).
- Anonymous statistics to understand how the game is used and improve it: legitimate interest (art. 6(1)(f) GDPR); the resulting totals are not personal data.
- Publishing your nickname and points on the leaderboard: your choice, which you can withdraw at any time (art. 6(1)(a) GDPR).
- Sending you the newsletter: your consent, which you can withdraw at any time (art. 6(1)(a) GDPR).
- Keeping orders: legal obligation (art. 6(1)(c) GDPR).
3. How long
- Account, games, coins and content: as long as you keep the account. If you delete it, we delete them at once.
- Inactive accounts: after 24 months without signing in we notify you by email; if you do not sign in within 30 days, the account is deleted.
- Signed-in devices: 180 days from last use.
- Daily totals of the anonymous statistics: no expiry, as they do not concern anyone in particular.
- Newsletter subscription: until you remove it (from the Account page) or delete the account.
- Orders in euros: 10 years (Italian Civil Code, art. 2220), also after the account is deleted, kept separate from it.
- Encrypted server backups: renewed and deleted on rotation within a few months.
4. Who sees it
Game data is stored on DreamersWare servers in Germany and Finland (Hetzner Online GmbH, processor), with no transfers outside the European Union. Code emails and the newsletter are sent through DreamersWare's email provider. For orders, the recipients listed in the general notice apply (gateway, payment service provider). No advertising, no profiling, no third-party services in the game.
5. Cookies and device storage
The game uses a single technical cookie, the account session (HttpOnly, secure, 180 days), and the browser's local storage for profile, cart, language and offline play. They are necessary for the service and do not require consent. In the same storage the game also keeps the date of the last opening, used only for the anonymous statistics: it contains no identifier, stays on the device and cannot be used to recognise you or follow you elsewhere.
6. Your rights
From the Account page you can download your data, sign out devices, leave the leaderboard, stop the newsletter and delete the account. For the other rights (access, rectification, restriction, objection, portability) write to the privacy address above; you can also lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or the authority of your country.