Privacy Policy

1. Who we are

When we say “Digital Compost” “we” “our” or “us”, we mean Digital Compost Ltd.

Digital Compost makes digital and physical games and game media for players worldwide.

2. What this privacy notice covers

This privacy policy sets out how we process and handle personal information. Personal information means information which relates to or identifies you (even if you are not named). This notice applies to all personal information we collect when people use our products and enter our worlds.

We treat personal information in accordance with applicable privacy laws, including the New Zealand Privacy Act 2020.

3. Information we collect

The information we collect depends on the game, platform, and features you use. We will only collect the personal information we need from you. This may include:

• Account and contact details - such as your name, email address or other contact details, date of birth, and account login details.
• Technical and play information -
• IP address, device and browser information, approximate location, or device identifiers;
• Information about game events, achievements, trophies, progress, and interactions, as well as crash data and analytics.
• Limited purchase and transaction history - Payment card and bank account details are generally handled by third party store or payment platforms, rather than by us. However, we will be aware if a relevant purchase has been made.
• Messages you send us - including support requests, troubleshooting information, and bug reports.
• Your marketing and advertising choices - such as whether you have signed up for updates or opted out.

Some games can be played without an account. In those games, we may still collect pseudonymous or aggregated play and analytics data so we can understand how the game is being used, and gather any information we need to improve it.

4. How we get it

• Directly from you when you create an account, use a game or app, contact us, or sign up for updates.
• Automatically from your device or gameplay through app functionality, platform services, analytics tools, and in some cases, cookies or similar technologies.
• From platform and service providers, including Microsoft PlayFab and store or console platforms

Although we collect the majority of personal information directly or automatically, sometimes we might receive personal information from third parties. For example, platform providers and analytics tools may provide us with information we need to operate and improve our games. We will let you know when personal information has been collected indirectly and how it will be used (e.g. in the legal / privacy section for each game).

5. How we use it

We use your information to:

• Provide games, services, and create and manage accounts.
• Apply age-appropriate settings.
• Save progress, record game events, achievements or trophies, and support cross-session play where available.
• Respond to questions, provide support, investigate faults and fix bugs.
• Understand how our games are used, test ideas, conduct analytics, and improve play experiences.
• Send service messages, such as account, security, or game-related notices.
• Send marketing where you have opted in to receive marketing information. Every marketing email will include an unsubscribe option.
• Protect players, our games and our systems, including detecting fraud, misuse, and security incidents.
• Meet legal and regulatory obligations that apply to our games and services.

Where you have to provide certain information to enter one of our worlds (e.g. an email address, date of birth, or another account detail), we will explain this in the game or account flow. If you don't provide the required information, you may not be able to register, use an account-based feature, or play that particular game.

6. How we share it

We may disclose personal information to:

• service providers that help us operate our games, accounts, analytics, hosting, security and communications;
• platform operators and marketplace providers such as Steam, PlayStation, Xbox, Nintendo, Apple, and other gaming platforms where relevant to the operation of a game or account;
• to the extent necessary, our professional advisers such as lawyers, accountants, and insurers;
• regulators, law enforcement agencies, courts, or other authorities where required or permitted by law;
• another organisation as part of a business transaction, such as a merger, acquisition, restructuring or sale of assets; and
• any other person where you have authorised us to do so or where disclosure is otherwise permitted by law.

7. Third party platforms

We sometimes use third-party services to host accounts, operate games, and connect with gaming platforms. Those providers may process information under their own privacy terms as well as on our instructions. The third-party platforms we use are:

A game event usually records that something happened in a game on a platform account. It does not necessarily include your real-world name or contact details.

8. Information can travel

We operate internationally and use cloud and platform providers whose systems may be located in other countries. This means personal information may be stored, accessed, or processed outside New Zealand. Where we disclose personal information outside New Zealand, we take reasonable steps to ensure it is protected by safeguards that are comparable to those required under New Zealand privacy law. This may include using reputable providers, contractual protections, and appropriate technical or organisational safeguards.

9. Keeping it safe

We use technical and physical safeguards designed for the type of information involved. These include multi-factor authentication, encryption in transit and at rest where supported, access reviews, and platform security monitoring or logging. Internal access is limited strictly to people who need it.

We will take all reasonable steps to protect personal information from loss, misuse, and unauthorised access.

If you think an account or our systems may have been compromised, please let us know immediately.

10. How long we keep it

We keep personal information only for as long as it is reasonably needed for the purposes described in this policy, including while an account or game remains active, and for any additional period required for security, legal, or regulatory reasons. When information is no longer needed, we will delete it, de-identify it (if we want to keep it for analytics), or otherwise dispose of it securely where reasonably practicable.

11. Younger players

Some Digital Compost games may be enjoyed by children or young people (people under the age of 13). The exact approach we take to collection and treatment of the personal information of children or young people depends on the game and the information needed. Where required, we may use age gates, limit features or data collection, or seek a parent or guardian’s involvement or consent. We aim not to knowingly collect more personal information from a child than is reasonably needed to provide the relevant experience and meet legal or safety requirements.

If you are a parent or guardian and believe a child has provided personal information in a way that concerns you or has had an interaction in one of our worlds you are not happy about, contact us. We may need to verify your relationship to the child before acting on a request.

12. Cookies, trackers and web games

Our current focus is game and platform analytics rather than through website tracking. If we offer a web game or add website technologies, we may use cookies or similar tools that are necessary for the service, for example to remember your choices, measure use, or support analytics. Where we use these, we will provide a cookie notice or consent tool with more detail about the technology, purpose and duration.

13. Marketing

We may send email updates and use account information to organise audiences or tailor communications. You can unsubscribe using the link in any marketing email. Opting out of marketing will not stop essential service and account messages. Marketing preferences and opt-outs may be managed through Microsoft PlayFab or another service provider.

14. Your choices and privacy rights

You have the right to ask whether we hold personal information about you, request access to it, and ask us to correct information that you believe is wrong or incomplete.

We may need to verify your identity before completing a request. While we will consider requests for deletion on a case-by-case basis, information may need to be kept where the law allows or requires it.

15. Automated tools and future experiments

Games and digital services evolve. In future, we may test new analytics, automation, or AI-enabled tools. If a tool uses personal information in a way that materially affects this policy, we will assess the privacy impact and update this notice or provide a more specific notice where appropriate. We do not currently use any automated decision-making tools.

16. Changes to this policy

We may update this policy as our games, services, or legal obligations change. We will publish the updated version on our website and change the “Last updated” date. If a change is important, we may also provide an in-game, account, or email notice where appropriate.

17. Talk to a human

For access or correction requests, privacy questions or complaints, contact Digital Compost Ltd at privacy@digital-compost.com.

If you have any concerns with how we have responded to a privacy query, you can contact the Office of the Privacy Commissioner at www.privacy.org.nz.