The Digging Deep Project Privacy and Data Collection Policy

Introduction

We have updated our privacy policy for easy reading. You can now find an easy overview of all data we process in one place. We explain in simple terms why and how we process your data and what the legal basis for processing is. We also provide an overview of your data protection rights and when we might share your data and why. 

Effective Date: This document applies to content and Applications released on October 21st, 2017, and later. Last updated on 1 August 2022.

About the Digging Deep Project

The Digging Deep Project is a non-profit and fiscally sponsored project of The Giving Back Fund based in Los Angeles, California, United States. The Digging Deep Project is owner and publisher of the Digging Deep Journal, the Shadow’s Edge Guide to Self-Awareness, developer of the mobile game Shadow’s Edge and all related products, websites, and social media sites. (“The Digging Deep Project”, “DDP”, “we,” or “us”).   

Our Data Controller and Data Privacy Officer 

In the context of data privacy, we are classified as a data controller. This means we are the organization that decides why and how we process your data to be able provide our services to you. 

Our representative in the EU is:

Nancy Imado Herbert

Agua Longa, Portugal

nancy@shadowsedge.com

Skype: nancy.imado

Our data privacy officer’s contact details are:  

Kevyn Eva Norton

kevyneva@shadowsedge.com

Zurich, Switzerland
Phone: +41 78 670 03 63
skype: kevyneva

Introduction to our Privacy Policy

We are committed to safeguarding the privacy of our users and players. This Privacy and Data Collection Policy explains how DDP collects, uses and discloses information about you. 

By using our products and services, you consent to this Privacy and Data Collection Policy. This privacy and data collection policy is part of our larger terms of services for our products and services. 

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our homepage or mobile games and applications or by sending you an email notification).   

We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy. 

We may supplement or amend this policy by additional policies and guidelines from time to time. Any changes will be published on our websites: www.diggingdeep.org/privacy and/or www.shadowsedge.com/privacy respectively. 

Information we collect and legal basis 

This Privacy Policy applies to information we collect when you use our website, game, mobile applications, and other online products and services (collectively, the “Services”).  Please note that this Privacy Policy does not affect or impact any of The Digging Deep Project products released prior to the Effective Date.  

We will ensure that any personal data we process is accurate, adequate, relevant, and not excessive, given the purpose for which it was obtained.  We will not process personal data obtained for one purpose for any unconnected purpose unless you have agreed to this or would otherwise reasonably expect this. 

Information You Provide to Us 

Please see the table below to understand what kind of information we collect, where we collect it, why we collect it, and what the legal basis is, that allows us to collect it. 

Type of DataWhere we collect itPurposeLegal basis
Contact Information
EmailGame RegistrationBlog or Newsletter sign-upPlaytests signups surveysContest Sign-upsSo you can login to the gameSo we can send you our newsletter once you signed upSo we can contact you regarding playtest organization once you signed upSo we can send you technical notices, updates, security alerts, as well as support and administrative messages.So we can inform you about upcoming releases and changes in our products.Processing this data is a necessity so we can perform the contract with you and deliver our services to you.
NameBlog or Newsletter sign-upPlaytests signups surveysContest Sign-upsSo we can inform you about our products, services, rewards and news about our services we think will be of interest to youSo we can point out events offered by The Digging Deep Project and our partners.We only collect this data with your explicit consent
HometownAddressPublic campaigns, Contests, sweepstakesSo we can communicate with you about the campaign, contest or sweepstakeWe only collect this data with your explicit consent
Additional identifying information
personal pronounsContact formsSo we address you correctly when we communicate with youProcessing this data is a necessity so we can perform the contract with you and deliver our services to you.
Profile PictureNickname Social Media Game Profileso we can display your profile as per your preferencesProcessing this data is a necessity so we can perform the contract with you and deliver our services to you.
Year of BirthOnline SurveysPublic campaigns, Contests, SweepstakesWe collect the year of birth to understand whether we need to send you a parental consent form to participate in our playtests and surveys.Processing this data is a necessity so we can perform the contract with you and deliver our services to you.
Financial Information:Social Security Numbers  Public campaigns, Contests, sweepstakesWe use this information exclusively for prize fulfilment and related tax purposes.We only process this data with your explicit consent
User Information
User NamePasswordGame Registration and profile updateSo you can login securely into the game.Processing this data is a necessity so we can perform the contract with you and deliver our services to you.
Health related information and other personal information
Specific health conditions
Treatment History
Online Surveys We are creating products for mental and emotional wellbeing. We aim to understand our users’ situation around mental and emotional wellbeing to create products that serve your needs.  We only process this data with your explicit consent. 
Treatment HospitalGame: ShadowgramThe first version of Shadow’s Edge was created for young people who spend time in hospitals due to a chronic or serious illness. We may organize special events for players in specific hospitals. We only process this data with your explicit consent.
Gaming PreferencesOnline surveysWe are creating games that aim to make self-care fun. Thus, we are interested to learn about your preferences. We only process this data with your explicit consent. 
User Generated Content
Shadowgram uploads Game: ShadowgramInformation shared anonymously in the in-game community may be used for our marketing as per our terms of service. Any such information will be strictly anonymous and only if the user has shared it in the public part of the game or our social media or website.We only process this data with your explicit consent.
Journal EntriesGameThese are stored on your device and if you choose also in a cloud databaseJournal prompts and allowing you to reread what you wrote is a core part of the service we provide to you with the game. Processing this data is a necessity so we can perform the contract with you and deliver our services to you.
Painted WallsGameThese are stored on your device and if you choose also in a cloud databasePainted walls and allowing you to create a city that looks like you want it to is a core part of the service we provide to you with the game.Processing this data is a necessity so we can perform the contract with you and deliver our services to you.
Social Media and Contest Entry information
Posts and commentsSocial MediaWe may use information that you have posted on our social media, our website or blog for social media and advertisement campaigns we conduct.We also use this information to respond to your comments, questions and requests and provide customer service.We only process this data with your explicit consent
Contest entry informationPublic campaigns, Contests, sweepstakesWe process and deliver contest entries and rewards. We may use Information specific to participants and prize winners of public campaigns, contests or sweepstakes (including such campaigns with partners) for advertisements, marketing and other campaign related communication, by both The Digging Deep Project and the respective partners.  We only process this data with your explicit consent

Information We Collect Automatically When You Use the Services 

Type of DataCollection PointPurposeLegal basis
Device and Technology Information
Such asHardware modelOperating systemOS Versionunique device identifiersmobile network informationcountryGameWe collect device-specific information when you access our Services from a mobile device to track performance and technical issuesProcessing this data is a necessity so we can perform the contract with you and deliver our services to you.
Use Information
date/timeSuch asAccess timesPages viewednumber of clicksIP AddressPage you visited before navigating to our servicesGameplay activityGame loginsGame progressPages writtenWalls paintedShadowgram postsInteraction with other players stampsWebsitesGameWe use this data to monitor and analyze trends, usage, and activities in connection with our Services. We may also use this data to personalize and improve the Services and provide content, suggested connections or features that match user profiles or activities.
We might also share this data with research partners. This is only done in an aggregated anonymized fashion or with your explicit in case of individual usage data.
Processing this data is a necessity so we can perform the contract with you and deliver our services to you.
We process individual usage data with your explicit consent.
Demographic Information
Such asinternet protocol (IP) addressesbrowser typeinternet service provider (ISP)platform typegenderage groupinterestsWebsitesSocial Media CampaignsApp Store Campaigns
See section cookies and tracking technologies for more information on where we collect this data,
We may also this data to personalize and improve the Services and provide content, suggested connections or features that match user profiles or activities. Processing this data is a necessity so we can perform the contract with you and deliver our services to you.

Cookies and tracking technologies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies or other tracking technologies, this could affect the availability and functionality of our Services. 

Cookies

Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience. They allow us to see which areas and features of our Services are popular and to count visits. We ask your explicit consent prior to the use of these cookies on our websites. To learn more about cookies please refer to: https://allaboutcookies.org  

Please see here a list of cookies used on our websites:

Essential Cookies

Cookie keyDomainTypeExpirationDescription
XSRF-TOKEN  www.shadowsedge.comFirst-partySessionThis cookie is written to help with site security in preventing Cross-Site Request Forgery attacks and iss et by Wix.
hs www.shadowsedge.comFirst-partySessionUsed for security reasons by Wix.
sp_t  .spotify.comThird-party1 yearRequired to ensure the functionality of the integrated Spotify plugin. This does not result in any cross-site functionality
sp_landing  .spotify.comThird-party1 dayRequired to ensure the functionality of the integrated Spotify plugin. This does not result in any cross-site functionality.
ssr-caching www.shadowsedge.comFirst-party29 secondsIndicates how a site was rendered. Set by Wix.

Targeting Cookies

Cookie keyDomainTypeExpirationDescription
svSession  .www.shadowsedge.comFirst-party2 yearsIdentifies unique visitors and tracks a visitor’s sessions on a site
YSC  .youtube.comThird-partySessionThis cookie is set by YouTube to track views of embedded videos.
VISITOR_INFO1_LIVE  .youtube.comThird-party6 monthsThis cookie is set by Youtube to keep track of user preferences for Youtube videos embedded in sites;it can also determine whether the website visitor is using the new or old version of the Youtube interface.

Performance cookies

Cookie keyDomainCookie typeExpirationDescription
_gat_UA-60144440-1.diggingdeep.orgFirst-party1 minuteThis is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It is a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.
_gid.diggingdeep.orgFirst-party1 dayThis cookie is set by Google Analytics. It stores and update a unique value for each page visited and is used to count and track pageviews.
_ga.diggingdeep.orgFirst-party2 yearsThis cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.

Marketing Cookies

Cookie keyDomainCookie typeExpirationDescription
_ga_1GFGQNQH8D.diggingdeep.orgFirst-party2 yearsMarketing cookies set by WordPress
MtidPo_DAmQvhznGdiggingdeep.orgFirst-party1 dayMarketing cookies set by WordPress
JwMLUy-xkYdiggingdeep.orgFirst-party1 dayMarketing cookies set by WordPress
cQtoSaMOiGdiggingdeep.orgFirst-party1 dayMarketing cookies set by WordPress
IvqOntkfyCbudiggingdeep.orgFirst-party1 dayMarketing cookies set by WordPress
fedops.logger.defaultOverrideswww.shadowsedge.comFirst-party
1 minute
Marketing cookies set by Wix
TS01ded329www.shadowsedge.comFirst-partySessionMarketing cookies set by Wix
TS01e921e9www.shadowsedge.comFirst-partySessionMarketing cookies set by Wix
TS01e85bedwww.shadowsedge.comFirst-partySessionMarketing cookies set by Wix
TS01870529www.shadowsedge.comFirst-partySessionMarketing cookies set by Wix

Web beacons

These are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and determine whether an email has been opened and acted upon. They allow us to understand whether a campaign is effective and interesting to you and whether you interact with the content we provide. We use this information to create content that is relevant and useful to you.

Tracking and Analytics Technologies

We share your data with the following tracking and analytics technology providers

Google Analytics

We use Google Analytics to collect audiences to analyze trends, administer the site, and ensure that our site is accessible and viewable by our general audience. We do not have control over nor access to the information collected by this site and we recommend that you view their Privacy Policies for more information. https://policies.google.com/privacy

Twitter Website Universal Tag

This is a tool from Twitter that makes it possible for to track website conversions and manage tailored audience campaigns. We use this to understand whether our twitter campaigns are effective and whether you interact with our content. For more information see https://twitter.com/en/privacy 

Twitter conversion tracking

The twitter ads conversion code allows us to see which campaigns you reacted to. We use this to make our content more relevant. For more information see https://twitter.com/en/privacy 

Facebook Pixel

Facebook Pixel is Facebooks conversion tracking system for ads on Facebook to websites. It allows us to see which Facebook campaigns you clicked on to land on our website or game. For more information see https://www.facebook.com/privacy/policy 

Facebook Conversion Tracking

This technology allows us to see which advertisements you clicked. For more information see https://www.facebook.com/privacy/policy 

Firebase

This technology allows us to track how you use the Shadow’s Edge game, when you first download it, which campaign brought you to it. For more information see https://policies.google.com/privacy

GameAnalytics

This technology allows us to track how you use the Shadow’s Edge game, when you first download it, which campaign brought you to it. For more information see https://gameanalytics.com/privacy/ 

Third party services

We may allow third parties to provide analytics services and provide you with other services, such as rewards programs. We will inform you about these third parties at the point of use with an option for you to opt in or out. These third parties may use cookies, web beacons, your account information (that you set up with these third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked, and conversion information. These third parties may also share this information with their customers and clients.  This information may be used by The Digging Deep Project, and these other companies to analyze and track data, determine the popularity of certain content, and better understand your usage. Some of these third-party service providers offer you a choice to opt out the collection of and/or sharing of this information. Please refer to their websites as to how to opt out.

How we share your Information 

Sharing with partners who help us create our products and services

It takes many kinds of skillsets to create our product and we don’t have all of those in-house. We may share your data with trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.  Partners we are working with that can have access to your information to carry out work on our behalf:

  • For the game development we work with game studio Stickylock ( www.stickylock.com ) to develop the Shadow’s Edge Game.
  • To run the backend of the game, essentially the database where your game progress, journals and art are stored we have a contract with Microsoft Azure in place. ( www.azure.microsoft.com )
  • To help us configure and operate the backend for the game we work with GSD Technologies (www.gsd-technologies.net)

Sharing to comply with Legal requirements

We share your data with legal authorities in the following cases: 

  • In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation; 
  • If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of The Digging Deep Project or others; 
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company 

Sharing with Research Partners

We share your data in an aggregated and anonymized manner with academic research partners and partners who do machine learning on it for analytical purposes such as GSD Technologies mentioned above. By anonymizing and aggregating the data before transfer we ensure no identifiable information about you is shared without your explicit consent.

In case you sign-up for a research that uses the game Shadow’s Edge as an intervention, the research partner will ask for your consent directly to receive your data. We do not share any individual usage data without your explicit consent and for the specific studies you have opted in for.

Plugins used in our services

We use various plugins from providers such as Instagram, twitter, spotify, youtube, WordPress, Wix to display content from those providers on our websites. The plugins may track usage data that can be linked back to your social media profile on those platforms. Please refer to their privacy policies to learn more about their data practices. 

Sharing with Advertising Services 

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties. We do not have Advertising Services in our products.  

Sharing with Partners for Campaigns or Competitions

When you sign up for specific campaigns, competitions or sweepstakes we ask for your consent to process your submission and personal data as listed in the section above about types of data we process. This includes sharing information with partners who help us fulfill prizes and gift vouchers.

Sharing with analytics partners

Please refer to section above on tracking and analytics technologies. 

Information you opt to share via Social Sharing Features 

Our services may offer social sharing features and other integrated tools (such as the “Like” buttons in Facebook or Instagram, or for example the option in Shadowgram to share images with your network). The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features. 

Please note: we inform our players about the best practices of sharing and other community rules of engagement on our website in our Community Guidelines.  

Automated decision making and profiling

We are not using any artificial intelligence or other tools for profiling and deep personalization or predictive technologies. In case we change this practice we will update this policy and inform you about this. 

International Transfer of Data 

The Digging Deep Project is based in the United States and the information we collect is governed by U.S. law.  By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries. 

All game data is stored in Europe in the Microsoft Azure region West data centers in the Netherlands. This means all data you upload to the game will be transferred to the Netherlands. Processing of your data can happen in Europe or in Latin America, if you are located there. The Digging Deep team is located in the US, Switzerland, the Netherlands and Portugal and your data might be accessed from these locations.

Additionally we may transfer data to our partners who do machine learning on the anonymized data. This partner is GSD Technologies based in the USA. We also might transfer data to our partner CINDE in Colombia for research purposes – but only if we have your explicit consent for this.

By reading this privacy policy, you acknowledge that personal data that you submit for publication through our social media channels, website or Shadowgram may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. 

How long we store your data.

We store your personal data for five years after you do not use our services anymore. You can request us to delete your data at any time.

How we keep your data safe / Security 

The Digging Deep Project takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. 

Where other organizations process personal data as a service on our behalf, the persons responsible for GDPR compliance will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organizations. 

We provide great care to protect the privacy of our players. The player’s registration information and player content are stored on their local device and on a central service on Microsoft Azure.  

User generated content can be shared in-game in Shadowgram. Such content is also stored centrally at the Microsoft Service. User generated content can further be shared by taking a screenshot and sharing that screenshot via the device to any media or save it locally. The Digging Deep Project is not responsible for any of such shared content.  

Your data protection rights

Fair and lawful processing

We can only process your personal data for legitimate and specified purposes. 

Right to withdraw consent at any time.

Where we process data based on your explicit consent, you have the right to withdraw this consent at any time. 

Right to lodge a complaint.

You have the right to lodge a complaint with the supervisory authority in your country. 

You have the right to transparency. 

This means that you should receive information on how your personal data will be processed in a clear, concise and transparent way. Information on the processing of your personal data must be provided to you in an easily accessible format. 

You have the right to be informed.

This includes information on how and the purpose for which your data is processed, the identity of the controller who processes your data, the categories of data concerned and to whom data is disclosed, including outside the EU. 

You have the right to access your personal data.

This means that you can, for example, obtain a copy of the data concerned and some information concerning the processing in your specific case, for instance the purpose of that particular processing and the recipients to whom your personal information is disclosed. 

Right to erasure («Right to be forgotten») 

If your personal data is no longer needed by the Digging Deep Project, if you withdraw the consent you previously gave to the processing of your data, or if the processing operation is unlawful, you can ask the Digging Deep Project to erase your personal data. 

Right to restrict the processing of your data. 

Under certain circumstances, for example if you contest the accuracy of the data that the Digging Deep Project is processing about you, or if you are not sure that your data is being processed lawfully, you can ask the controller to restrict the processing of your data. This means that the controller can store your data, but cannot process it in any other way temporarily. 

Right to data portability

This right allows you to obtain the data that the controller has about you and to 

transmit this data from one controller to another. 

Right to rectification.

If your data is inaccurate or incomplete, you can ask us to rectify this data. 

Right to object to automated individual decision making. 

You have the right to object to a decision based on an automated process, such as profiling, if this may result in legal consequences for you or significantly affect you in a similar way. 

Right to object. 

You can object, on compelling and legitimate grounds, to the processing of your data. 

External Links 

Our web site contains links to other sites. Please be aware that The Digging Deep Project, is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this web site. 

Contact Us 

If you have any questions about this document, our Services, our Privacy policy or wish to report a violation, please contact us at: privacy@shadowsedge.com. 

You may also contact our Privacy Policy Administration by writing to: 

Privacy Policy Administration 

The Digging Deep Project

c/o The Giving Back Fund

2208 Canyonback Road 

Los Angeles, CA  90049-1177

USA