Privacy Policy Agreement

Last Updated October 10, 2018

The terms “Firefly”, “we”, “us”, “our”, “ours” and “Firefly group of companies” when used in this Privacy Policy mean Firefly Holdings Limited, which includes any subsidiaries, divisions, branches or companies under common ownership or control of Firefly Holdings Limited. The terms “you”, “your” and “yours” when used in this Privacy Policy mean any user of our websites or services.

The term “Personal Data” refers to any information relating to an identified or identifiable natural person. GDPR Art. 4(1)(1)

  1. Introduction to Privacy Policy

We are committed to the privacy and confidentiality of information provided by you to us. This Privacy Policy describes our current policies and practices in compliance with the General Data Protection Regulation (GDPR) with regard to Personal Data collected by us from you directly and/or through our websites, games and services. For the purposes of GDPR regulations Firefly Holdings Limited is the “data controller”.

Please note that by submitting Personal Data manually or in electronic form to us and/or by using our websites and/or services you give your consent that all Personal Data on each occasion that you submit may be processed by, and/or shared within the Firefly group of companies, in the manner and for the purposes described in this Privacy Policy.

  1. Notification of changes to this Privacy Policy

We are continually improving our methods of communication and adding new functionality and features to our websites and to our games and services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will notify you of the changes via this page. We encourage you to check this Privacy Policy frequently.

  1. Data Protection Policy

We process gamers’ personal data to provide access to our online games, to develop new games and refine existing games to work better with different devices. This processing is necessary to fulfil our contract with gamers and is in our legitimate business interests to develop new games and refine existing ones to work better with different devices.

We also process personal data to protect the security and integrity of our databases, particularly fraud prevention and take precautions against legal liability. This processing is in our legitimate business interests in protecting the security and integrity of our games and compliance with potential legal obligations.

It is in our legitimate interests to keep our games up to date with new technologies and provide a good user experience. It is also in our legitimate interests to protect ourselves and other gamers from fraudulent activity.

We collect the following data from you –

Data you provide us.

Data we collect automatically.

Why we collect your data

To make the Service work.

To perform the contract, we process data necessary to

To make the Service more suitable for our players.

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

To keep the Service safe and fair.

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

To analyze, profile, and segment.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

We do not collect special category data, that is information about heath, race, religion, political beliefs or sexual orientation.

We recognize that there could be such information in in-game messages but we do not encourage this.

We will share personal data with other companies in our group, which are Firefly Studios Inc., and Firefly Studios Ltd.

Firefly Studios Inc. is incorporated in the US. We have contracts in place with that company incorporating the EU Model Clauses recommended to safeguard the personal data of EU citizens when transferred outside the EEA.

We also transfer data to companies that provide services to us including MailChimp and Amazon Web Servers. These companies both subscribe to Privacy Shield in the US which is a set of data protection principles similar to that in the EU’s GDPR.

We currently hold gamer records indefinitely but we are moving to a seven year retention period to coincide with accounting requirements. We will be deleting any personally identifiable data, such as IP addresses, email addresses etc if an account has not been used for a period of seven years.

  1. Anonymous data collected through our websites

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our websites. For example, we use technology to track which pages of our websites our visitors view. We also use technology to determine which web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our websites.

We use this anonymous data to improve the content and functionality of our websites and our e-mail updates, to better understand our customers and visitors, and to improve the services we offer.

  1. Cookies

A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Firefly uses Cookies to collect information about a user’s visits and to enhance the user’s experience when visiting the Websites and games operated by Firefly. A cookie can be used to store information like your password, or the fact that you have already registered. This allows us to speed up your future activities, saving the time you would normally spend entering information such as your password or registration information.

Cookies can be refused by you by activating the appropriate settings on your web browser. By doing this, please be aware that you may be unable to access certain parts of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our websites.

  1. IP Address

An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. We may track your IP address for, security, site tracking, administration of our websites or services, to prevent abuse of our game servers, or to gather broad demographic information such as determining how many of our visitors are from outside of the UK.

We may also perform IP lookups to determine which domain you are coming from (i.e:, to more accurately gauge our users’ demographics.

  1. Disclosure of your Personal Data

We do not share with, nor sell nor distribute your Personal Data to unrelated third parties, except under these limited circumstances:

  1. Children

Firefly does not direct its websites, games, game engines, or applications to children (usually considered to be under the age of 13, depending on the country where you reside). We also do not intentionally collect personal information from children through our websites, games, game engines, or applications. If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us as described in the Contact US section of this policy and we will delete the information from our records.

  1. Data Integrity and Security

We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our websites and computer systems, aim to protect the loss, misuse or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy. Although we will use reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Accordingly, we assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.

  1. Links to other websites

Our websites and services may contain hyperlinks to websites that are not operated by us. Any such hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.

Our websites contain hyperlinks to other pages on our websites. We may use technology to track how often these links are used and which pages on our websites our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

  1. Transfer of Data Abroad

We may transfer and store your Personal Data between members of the Firefly group of companies, and our offices and third party processors which may be located outside the EEA. Where your Personal Data is transferred and stored outside the EEA we will ensure that the recipient agrees to keep your information confidential and hold it securely in accordance with the requirements of the GDPR.

By providing us with your Personal Data, you consent to the processing, transfer and storage of your Personal Data as set out in this section.

  1. Unsubscribe

We hope you will be delighted with our services. If you no longer wish to receive information from us and want to be removed from our mailing list please, click the Unsubscribe link which may be found at the end of any marketing or promotional communications we send to you. The Unsubscribe link will give you the opportunity to withdraw your consent to receiving such communications in the future. Remember that by stopping the information that you receive from us about our products and services may not benefit you. For example, you may not hear about promotions we are running or additions to our service.

  1. Governing Law

This Privacy Policy forms part of our websites terms and conditions for the supply of our products and services (including the Terms of Use and as such shall be governed by and construed in accordance with the laws of England. You agree to submit any dispute arising out of your use of our websites or service to the exclusive jurisdiction of the courts of England.

  1. Feedback

We welcome comments about this Privacy Policy. If you have any questions about this Privacy Policy, or any part of our service, you may contact us by emailing

Visiting Firefly Internet websites and using our on-line services indicates your acceptance of our Privacy Policy. If you do not accept this Privacy Policy, please do not visit our Internet websites or use our on-line services.

  1. Banned Gamers

If you have been banned from the game, we have taken action to ban you from our game to prevent fraud and stop anti-social behavior in accordance with our terms and conditions.

This is in the legitimate interests of Firefly and to comply with a legal obligation around fraud prevention which is in our legitimate interests to protect ourselves and other gamers from fraudulent and anti-social activity.

If you have been banned from the Game then the following shall also apply.

We will retain an encrypted version of your email address for the sole purpose of preventing you from creating a new gaming account. We will retain no access to the email address and it can therefore not be used for any other purpose.

If your behavior has resulted in a permanent ban from our game, then this information will be held indefinitely as we need to retain the information to enforce the ban.

  1. Your data protection rights

You have the right to ask for a copy of the personal data we hold that relates to you. If you think that information about you which we hold is incorrect or misleading you have the right to have the information corrected provided you can demonstrate that it is incorrect. You can also request the erasure of personal data relating to you in certain circumstances, where we do not require it to meet a legal obligation. You have the right to object to processing on the grounds that it causes you damage or distress and the right to take away a copy of your personal data in electronic format in certain circumstances.

We do not rely on consent as a basis for processing. We provide this privacy notice which explains our use of personal data and the grounds we rely on.

If you are unhappy about the way we use your personal data or the way in which we respond to your request to exercise your data protection rights, you can contact Data Protection Coordination at Firefly Holdings Limited at the address below but you also have the right to lodge a complaint with a supervisory authority, the Information Commissioner at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

All the personal data we hold is supplied ultimately by our gamers. Some of it may come to us indirectly from Google play, Apple i-Tunes, Steam, Microsoft store and other providers of leads. We obtain very limited personal data from third parties. Most of the personal data we hold is provided directly by you when you create an online account.

There is automated decision making in the gaming system. Your ability to purchase game in-game currency is limited depending on the time you have spent in the game, this is for fraud prevention purposes. We also have automatic lock out on accounts from shared IP addresses in line with our game rules to prevent players using multiple accounts.


If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us at the email address below.

Name of the controller: Firefly Studios

Address: Thomas House, 84 Eccleston Square, London SW1V 1PX