Rebel Racing

"When you download one of Hutch's games, Hutch will collect information including your device ID, IP address, country, state or county, postal or zip code and/or IDFA to identify the jurisdiction where you are located. Hutch relies on the legitimate interests basis (Art. 6 para 1(f) GDPR) for this processing."

Hutch collects granular location data down to postal/zip code level at install time, along with the IDFA advertising identifier, justified under 'legitimate interests' rather than explicit consent.

"its group companies to assist and facilitate the services provided to you, or for data analytics, business intelligence, cross-selling, personalized advertising, mergers & acquisitions, development, distribution or general data protection compliance purposes... with certain of the technology providers that Hutch uses (as detailed in Section 17 below) e.g., in order to assist Hutch in relation to any user acquisition activities."

Data is shared broadly with group companies for purposes well beyond service delivery — including cross-selling, personalized advertising, and business intelligence — and with unnamed technology providers for user acquisition.

"Hutch will collect information including your device ID, IP address, country, state or county, postal or zip code and/or IDFA to identify the jurisdiction where you are located... These collect information such as your device ID and other technical/analytical information relating to how you interact and play the Game in question."

Hutch collects device identifiers (device ID, IDFA) and detailed behavioral analytics about how users interact with games, going beyond what is strictly necessary for core game functionality.

"Hutch may change this Policy at any time, please check it from time to time to understand which data we collect and the purposes for which we use it."

Hutch reserves the right to change the privacy policy at any time with no commitment to notify users, placing the burden on users to periodically check for changes.

"Hutch will also assign you a User-ID which is a random string of characters used to identify you as a unique player going forward... 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."

Hutch creates persistent user profiles via assigned User IDs and links them with social network identities (Facebook ID, Google, Apple), enabling cross-service tracking and identification.

"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 shall retain information in relation to a complaint for a maximum of six (6) years after its closure."

While complaint data has a 6-year retention period, the general game data retention policy is vague — 'reasonable' and 'in line with purposes' — with no specific deletion timelines disclosed for the bulk of user data.

"It may not always be possible for us to process requests. If we are unable to identify your data within our systems then we will not be able to retrieve or delete your data. For example, if you uninstalled the app without recording your User ID and did not log in via social media, we are highly unlikely to be able to identify your data within our systems."

Hutch disclaims the ability to delete user data if it cannot identify the user, effectively meaning data may persist indefinitely for users who uninstalled without saving their User ID.