Privacy & Cookies Policy
This is the Privacy & Cookies Policy (the ‘Policy’) of Hutch Games Ltd (‘Hutch’). This Policy describes the ways in which Hutch collects and uses information about you when you visit Hutch’s website at www.hutch.io (the ‘Website’) or when you play one of Hutch’s games (each a ‘Game’ and together the ‘Games’) on a browser, through a social networking site or as an app. It also details how Hutch collects and uses information about you when making a complaint to Hutch by e-mail, as well as if you choose to make a job application.
Hutch may change this Policy at any time and when this happens we will notify you of any changes to this Policy by noting this on our Website as well as within the Games. The changes will apply to your use of the Website and/or our Games after we have notified you. If you do not wish to accept the new Policy you should stop using the Website and/or playing our Games (as applicable). If you continue to use the Website and/or play our Games after the changes, your continued use of the Website and/or your continued playing of any of our Games shows us your agreement to be bound by the new Policy.
For the purposes of data protection legislation, Hutch is the controller for the processing of your personal data. Hutch has notified the Information Commissioner’s Office (“ICO”) of its processing of personal data. The notification indicates what data is processed by Hutch and for what purpose, and to which persons or entities the data will be provided. Hutch’s registration number is ZA369120.
If you have any queries about this Policy, please contact Hutch using the contact details set out at paragraph 12 below.
Personal Data means information that identifies, relates to, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household, including identifiers such as a real name, alias, a device identification number, location data, an online identifier, commercial information (including products or services purchased), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, or as further defined under the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) (as applicable). We indicate in this Policy the information we collect from you.
By playing the Games or visiting the Website you are agreeing to be bound by this Policy in respect of the information collected about you. Hutch may change this Policy at any time. Hutch shall deem your continued use of the Games or access of the Website as indicating your consent to such changes. This Policy applies to the following people:
A. visitors to the Website (including those submitting a job application);
B. people who use the Games; and
C. people who make complaints to us by email.
The Website is essentially a brochure for Hutch’s business, its Games and opportunities to work with and for Hutch. The Website collects information from you in the following ways:
B. Should you choose to contact Hutch via the Website, Hutch will collect your e-mail address together with any other information that you submit in connection with such contact request. Hutch relies on consent to collect this information because you choose whether to contact Hutch or not and can choose how much personal information to provide to Hutch in doing so.
C. Hutch often advertises jobs on the Website. If you choose to respond to any such advertisement, or speculatively submit your CV and details for consideration through the recruitment enquiries section on the Website, any information provided by you to Hutch in connection with such response will be used to assess you as a candidate and undertake criminal record and/or checks with references. Personal information about an unsuccessful candidate shall generally be held for twelve (12) months after the recruitment exercise has been completed after which it shall be destroyed or deleted without further notice unless Hutch reasonably considers that such candidate may be a good candidate for a future role in which case Hutch shall hold such personal information for so long as is reasonable in relation to such information. Hutch may retain anonymised statistical information about applicants to help inform Hutch’s recruitment activities in the future. Hutch relies on either: (i) compliance with a legal obligation; or (ii) the legitimate interests processing grounds in order to collect the information set out in this paragraph. Where legitimate interests are relied upon, it is in Hutch’s legitimate interests to collect such items of personal data because this is necessary in order to carry out certain specific employment related duties relating to your application for employment with Hutch. The items of personal data collected are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
When Hutch receives complaints by email it shall file any relevant document and may retain details of the complainant, and other individuals identified in the complaint. Hutch will only use this information to process the complaint and to check on Hutch’s services and staff.
Hutch shall retain information in relation to a complaint for a maximum of six (6) years after its closure, in a secure environment and access to it will be restricted on a ‘need to know’ basis. Hutch relies on the legitimate interests processing ground to collect the information set out in this paragraph.
It is in Hutch’s legitimate interests to collect such items of personal data listed here because this is necessary in order to analyse and respond to your complaint.
The items of personal data collected are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
A. Game Data:
Hutch will collect the following information from you when you use the Games:
ii. If you sign into one of the Games through Facebook, Google or Apple , in addition to the Analytics Data above, Hutch will also collect such information as Facebook, Google or Apple may allow Hutch to access, namely your full name, and if you sign in using Facebook, your Facebook ID. If you use any of the Game features such as chat rooms and/or support services, Hutch will also collect such information as you submit via such feature (“Player Data” which, together with the Analytics Data is the “Game Data”);
iii. if you make any purchases, Hutch will collect certain information in relation to your purchases (please see paragraph 4(b) below) ("Finance Data");
iv. in F1 Manager, if you opt-in to do so, information including your name, date of birth and e-mail address which is then used by F1 to provide you with a newsletter and other marketing information related to F1 (“F1 Data”);
v. if you consent or where we are otherwise permitted to send such communications in accordance with applicable data protection and electronic marketing legislation, to provide you with a newsletter and other marketing information which we consider you may be interested in (for example in relation to ours or our group’s other games) (“Marketing Data”); and
vi. in certain instances Hutch may use certain information relating to your Game progress and/or Game Spend and/or other Game activity to invite you to complete surveys in relation to its Games, including, for example, to join its “Player Council” and complete any other documents required for you to join (“Survey Data”).
B. Financial Information:
Your purchase and in-app purchases within the Games are handled through the platform on which you purchased the Game or through other payment processors (e.g. the Apple App Store, Google Play, xBox Live, Playstation Network). Hutch does not retain any card or payment details, although Hutch does keep a record of your purchases and your aggregate spending.
C. What if Hutch cannot collect this information:
You can use your browser settings and privacy settings on your social networks to prevent us collecting certain of the above information about you (see, for example, paragraphs 5(f) and 12 below). If you still have concerns about the information we collect please contact us at any time by sending an e-mail to email@example.com.
D. Usage by us:
The categories of personal data mentioned above and otherwise herein have been collected and used by us in the past twelve (12) months for the business purpose(s) indicated herein.
Hutch will use the information it collects as set out in paragraph 4 above to:
A. in relation to the Game Data, offer the Games to the player in question;
B. in relation to the Analytics Data, to facilitate the improvement of the Games and your experience of the Games;
C. in relation to the Game Data and Finance Data to complete your transactions;
D. in relation to the Game Data to provide technical support in relation to player enquires, resolving disputes, collecting fees and troubleshooting;
E. in relation to the Game Data to prevent fraud or illegal activities;
F. in relation to the Game Data to serve targeted adverts to you (where you consent to this). You may opt-out of your Game Data being used for this purpose (or change your settings at any time) within the “Ad Settings” item of the “Settings” menu in-Game or by: (i) for iOS, going to “Settings”, scrolling down to “Privacy”, scrolling down to “Advertising” and then shifting the “Limit Ad Tracking” slider to the right; and (ii) for Android, going to “Settings”, scrolling down and clicking on “Google”, scrolling down and clicking on “Ads” and then shifting the “Opt out of Ads Personalisation” slider to the right.;
G. in relation to the F1 Data for F1 to then provide such newsletters/marketing information to you;
H. in relation to the Marketing Data, to provide information about the Games, applications, services and other digital goods which Hutch thinks may be of interest to you. You can tell us to stop this at any time by sending an e-mail to firstname.lastname@example.org;
I. in relation to the Survey Data for Hutch to provide such survey to you; and
J. share with third parties for the purposes as described in paragraph 7 below.
Hutch relies on the legitimate interests processing ground to collect the information set out in paragraph 4 and use it for the purposes set out in paragraph 5, other than in relation to any Analytics Data which comprises non-essential cookies and/or Technologies, for the purposes of serving targeted advertising and the F1 Data for which Hutch relies on consent or in relation to the information collected by Hutch once a survey is presented to a player where Hutch also relies on consent (no survey is compulsory to complete).
It is in Hutch’s legitimate interests to collect the other items of personal data listed above because this is necessary in order to provide and improve the Games that are offered to you. The items of personal data collected are, in being limited to “business card” and “technical” type data, not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
Hutch will not pass your information to third parties other than as described in this paragraph. Hutch may, subject to its obligations to comply with applicable data protection legislation, share your information with third parties including:
A. its server providers which host and store the Game Data, such as Apple, Google, Microsoft Azure and AWS;
B. the third parties who assist Hutch in collecting the Analytics Data (as listed below);
C. where Hutch carries out any e-mail marketing campaigns, your name and e-mail address will be transferred to Mailchimp which carries out such campaigns on Hutch’s behalf;
D. Helpshift and Keywords in relation to Hutch’s customer support;
E. Get Social and/or KTPlay should you participate in any in-game chat services;
F. F1 in relation to the F1 Data;
G. as part of the Games your information (for example your name, profile picture or user ID) may be posted on a Leaderboard of top scorers within the Game to be shared with other players and your social networks. You may also share elements of your performance or participation in the Games (e.g. your personal car design) with other players and your social networks;
H. other subcontractors which assist Hutch in relation to the day-to-day running of its business, e.g., external recruitment agencies;
I. in relation to the sale of some or all Hutch’s business, or its assets, to any third party, or as part of any business restructuring or reorganisation, but Hutch will take steps with the aim of ensuring that your privacy rights continue to be protected;
J. with its group companies in order to assist and facilitate the services provided to you;
K. in anonymised form with data aggregators and service providers as part of an analysis of player metrics or sales performance;
L. with certain of the technology providers that Hutch uses (as detailed at TABLE 2 below) e.g., in order to assist Hutch in relation to any user acquisition activities; or
M. with law enforcement agencies in compliance with law enforcement.
Third Party advertisers may place or read cookies and/or Technologies on your browser or device in the Games and/or on the Website.
More details of Facebook’s cookies are available on its website and further links to third party cookies and Technologies are also set out in the tables below.
Hutch cannot be responsible for the privacy policies and practices of other sites even if you access them using links from the Games/Website, adverts in the Games/Website or from adverts on a webpage when you are playing the Game/are on the Website.
Hutch recommends that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you link to the Games from a third party site or via a social network (e.g. Twitter, Facebook), Hutch cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Hutch has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
Where you log-in via a social network, you may also change your account settings on your social network to prevent both us and third parties seeing certain information in relation to you, such as your Facebook profile.
Hutch’s physical servers are operated by third party cloud service providers and are located worldwide including in the EEA, USA and Asia. Where such information is transferred outside the EEA, Hutch has taken steps to ensure that its agreements with such third party providers contain provisions ensuring the adequacy of such transfer.
Hutch has a retention policy in place with respect to the data it holds, ensuring that it does not retain such data for longer than is reasonable in line with the purposes for which it was originally collected.
Hutch’s Games are intended for anyone who is legally entitled to own a device that access them and play them and anyone who is legally entitled to make in-app purchases by the payment functionality the Games provide.
However, Hutch does not knowingly collect personally identifiable information in relation to children under the age of 13. If Hutch discovers it has collected personal data in relation to any children under 13 Hutch shall take reasonable steps to delete such information.
You may also be required to obtain your parents’/guardians’ permission to play the Games if you are under 18, as indicated in our Terms of Service.
If at any time you would like to contact Hutch about your views on this Policy or any enquiry relating to your personal information, including but not limited to your rights under the GDPR and/or CCPA (as applicable), you can do so by sending an e-mail to us at email@example.com or write to us at Data Protection Officer, 44-46 Scrutton Street, Shoreditch, London EC2A 4HH, UK.
This is Hutch’s registered address and we are a company incorporated in England and Wales with company number 07692393.
You also have the right to make a complaint to the ICO by contacting them at any time.
You can contact us using the details set out in paragraph 12 above if you wish to:
(i) access a copy of the personal data that we hold about you including what categories of personal data we have collected or sold about you; the categories of sources from which the personal data is collected by us; the business or commercial purpose for collecting or disclosing the personal data; the categories of third parties with whom we share your personal data; and the specific pieces of personal data that we have collected about you);
(ii) correct any items of personal data that we hold about you; (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data; and/or (iv) if applicable pursuant to the CCPA, receive a free copy of your personal data within 45 days of your verifiable request in a structured, commonly used and machine-readable or commonly used electronic format on request.
Hutch may ask you to verify your identity before Hutch responds to such requests.
Please note that under the CCPA, Hutch is not required to delete information that is necessary to perform certain actions as outlined in the CCPA (e.g. to complete a transaction for which the information was collected or to provide the goods or services requested by you).
You will not be discriminated against in retaliation for exercising the above rights and rights under the CCPA.
A. What are Cookies?
Cookies are small text files that are placed on your device when you visit a Website. Other similar technologies, defined in this policy as “Technologies”, are third party technologies used in a Game.
Session cookies enable you to move from page to page within websites, and any information you enter will be remembered but is deleted when you close your browser after a short time.
Persistent cookies allow us to remember your preferences and settings when you browse the Website in the future, in different browser sessions.
We may use your social login (if you access a Game via a social media platform) and/or Hutch User ID for save protection so that you can restore your progress in a Game.
In our Games we use Technologies that track or store your data for advertising, attribution or analytics purposes.
B. Disabling Cookies:
The use of the cookies and Technologies described above improves the functionality of the Games and the Website and your experience using them.
If you do not want these cookies and/or Technologies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device.
Please note that if you do decide to disable cookies and/or Technologies you may not be able to access some of the Games or the Website, some of the features of the Games or the Website, or the Games or Website may not function properly.
By continuing to use the Games, and/or the Website, including using social networking media functionality, you consent to the relevant cookies and/or Technologies being set on your device.
C. More information:
To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org. Information about the Technologies can be found in Table Two below.
Cookies used on the website:
|Cookie Type||Purpose||Further Information|
|Google Analytics||Hutch uses Google Analytics cookies to collect information about how visitors use our Website, which Hutch uses to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.||Google Privacy Overview to opt out of being tracked by Google Analytics visit https://tools.google.com/dlpage/gaoptout|
Technologies used in the games: