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Offer Wall and Privacy Concerns Statement

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  • KaiRoKaiRo ✭✭✭
    One thing I find interesting in Shan's new message today is that apparently the ads in the game have been ironSource all the way, even before the Offer Wall was introduced? Definitely interesting information, whatever you/we/I make of it.
    "Don't try to be a great man... just be a man. Let history make its own judgments."
    -- Dr. Zefram Cochrane, around 2073
  • On the issue of the definition of "personal data": there is a very clear definition of this under GDPR, and it is also rather a wide-ranging one, including "online identifiers" such as IP addresses and device IDs - indeed, even our DBIDs count. Since there is evidence that these are exactly the sort of things being accessed by IronSource, it seems that the use of the term "personal data" in the statement is not aligned with the GDPR definition, and as such the statement is effectively meaningless for those of us in the EU/UK in terms of whether TP is complying with the relevant legislation.

    Given just how long this response has taken, I was really hoping it was because the legal side was grappling with how to ensure compliance and that steps had been taken to ensure that there wouldn't be any doubt whatsoever on that front going forward. The fact that such uncertainty remains is extremely disappointing, and not conducive to the rebuilding of trust that the statement indicates is desired. (I do find it interesting that although this statement has been issued, I have not yet received a response to my GDPR-related CS ticket, which suggests that it is known there is work still to do on that front.)

    I remember at the time of the transfer to Tilting Point that there was mention of how "sticky" STT players are - I feel as though they are on the verge of finding out what it takes to get us unstuck.

    @Shan - I know you won't see this for a while because of the holiday weekend over there, but when possible can you please ask for clarification about what TP does/doesn't consider personal data, and if it's not the same as the GDPR definition, why not?
  • I would also like to add my thanks to @Shan for following up and handling the torches and pitchforks with aplomb.
    Toranith wrote: »
    Still unanswered is whether IronSource's SDK is collecting data beyond what Tilting Point is collecting. This seems quite likely.

    Still unanswered is why Star Trek Timelines is now flagging as malware with multiple companies.

    Still unanswered are many other questions of users from the other thread.

    And this, still.
    Admiral of the Inner Planets Alliance fleets
  • Thank you for the update.

    As for your breakdown:
    Shan wrote: »

    So I will try to deconstruct it a bit, to make sure we are all on the same page.

    We have 3 things at play here:
    - the game in itself
    - ironSource, that is being used for the ads seen in game, and the Offer Wall
    - the various offers presented on the Offer Wall itself

    For these 3 things, there is data involved but not in the same fashion

    - for the game itself, we've covered it in our statement

    - for ironSource, it is operation data to be able to present you with ads in game, and as far as I know (I will ask confirmation on this) the Offer Wall did not change that at all, it is still the same operational data

    For me personally, yes these are the three primary areas of concern, and I amore focused on the first 2, as I will not use the offer wall regardless.

    For #1: Yes you have mostly answered this, although some further reading is required.

    For #2: This is still open, and as you say will get confirmed next week when you can confirm.

    Thank you and have a great long weekend!
  • Is everything still OK to use if we're coming in via the Win10 app or Steam, which don't have the Offer Wall or ads?
  • Is everything still OK to use if we're coming in via the Win10 app or Steam, which don't have the Offer Wall or ads?

    Having credible reports, with screenshots, of a forced update to v7.5.3 on Amazon, i'm sure the rest of Android and iOS is next. That also means Windows & Steam aren't going to be far behind. I sincerity hope that i'm wrong but i seriously doubt that i am.
    [DCC] bebe
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  • Thank you for the update.

    but a fleet mate just told us that a couple hours after doing an offer, where he did not provide his personal email address,

    someone else in a different continent signed him up for a Spotify account with is personal email address.

    How?

    It would be cool to get an update on the bug too. Still baffled this went live while that was still in the wild.
  • Warrior WilloWarrior Willo ✭✭✭✭✭
    Thank you for the update.

    but a fleet mate just told us that a couple hours after doing an offer, where he did not provide his personal email address,

    someone else in a different continent signed him up for a Spotify account with is personal email address.

    How?

    It would be cool to get an update on the bug too. Still baffled this went live while that was still in the wild.

    How do you know this has anything to do with the game?
  • Thank you for the update.

    but a fleet mate just told us that a couple hours after doing an offer, where he did not provide his personal email address,

    someone else in a different continent signed him up for a Spotify account with is personal email address.

    How?

    It would be cool to get an update on the bug too. Still baffled this went live while that was still in the wild.

    How do you know this has anything to do with the game?

    I don't, but the timing is what it is.
  • IronagedaveIronagedave ✭✭✭✭✭
    edited July 2020
    Perhaps more direct questions should be asked:

    1) Was this "disable consent by default" live at the same time the offer wall and IronSource's SDK first went live?
    2) Can you confirm there has not been a data breach of any kind as a result of the offer wall/Ironsource's SDK going live?

    I also note that the question of whether the development team fully tested and vetted this "feature" before going live has also yet to be answered.
    [was on Sabbatical/Hiatus] Currently a trialist at Galaxy SquadronSTAY SAFE and KBO
  • Mirror M'ressMirror M'ress ✭✭✭
    edited July 2020
    And with that, I am done with this game. The statement provided completely missed the point that a 3rd party company has been allowed access to this game with the ability to redirect the user to external websites that could compromise their data. Without even a "are you sure" or a obligatory message to make the user aware of what is going on.
    I'm sorry but I cannot continue, my game will be uninstalled...

    Unnecessary comment removed. ~Shan
  • Mirror M'ressMirror M'ress ✭✭✭
    edited July 2020
    As I understand it and from the podcast it was a collective (not borg) decision by all contributing authors, to remove the big book resource. Which I also understand that authors have the right do so unless they have sold the rights to a publishing company. Do not see the relevance or the need to get personal about this.

    5 year book deal incoming.

    Unnecessary comment removed. ~Shan
  • As I understand it and from the podcast it was a collective (not borg) decision by all contributing authors, to remove the big book resource. Which I also understand that authors have the right do so unless they have sold the rights to a publishing company. Do not see the relevance or the need to get personal about this.

    Every thread seems to have to go down the "...and the equine entity that transported you to this location" path sooner or later. I get tensions are high, but players turning on each other solves nothing. It really doesn't.

    🖖🏿🖖🏽🖖🏼🖖🏻🖖

    it does when it punishes the fandom
  • DScottHewittDScottHewitt ✭✭✭✭✭
    As I understand it and from the podcast it was a collective (not borg) decision by all contributing authors, to remove the big book resource. Which I also understand that authors have the right do so unless they have sold the rights to a publishing company. Do not see the relevance or the need to get personal about this.

    Every thread seems to have to go down the "...and the equine entity that transported you to this location" path sooner or later. I get tensions are high, but players turning on each other solves nothing. It really doesn't.

    🖖🏿🖖🏽🖖🏼🖖🏻🖖

    it does when it punishes the fandom

    Yeah, it affects the players. Including players who may not have been aware there even is a major problem, because they do not frequent the Forums. Which was a way that the people who created and own the assets felt would make a difference.
    "The truth is like a lion; you don't have to defend it. Let it loose; it will defend itself."
  • IronagedaveIronagedave ✭✭✭✭✭
    "all is for the best in the best of all possible worlds"
    [was on Sabbatical/Hiatus] Currently a trialist at Galaxy SquadronSTAY SAFE and KBO
  • As I understand it and from the podcast it was a collective (not borg) decision by all contributing authors, to remove the big book resource. Which I also understand that authors have the right do so unless they have sold the rights to a publishing company. Do not see the relevance or the need to get personal about this.

    Every thread seems to have to go down the "...and the equine entity that transported you to this location" path sooner or later. I get tensions are high, but players turning on each other solves nothing. It really doesn't.

    🖖🏿🖖🏽🖖🏼🖖🏻🖖

    Your comment would be far more persuasive if you applied it to everyone, including biggest bullies in the game. We would have a far stronger community if poor behavior was not condoned based upon one’s spending, which would give all of us more power to oppose tp’s practices that we disagree with.

  • I have reported the posts that contribute nothing to this thread but personal attacks. As if the issue at hand was not severe enough, you're actively derailing a constructive discussion.
    "While some limited items of personal data are necessary for the game to function, we can confirm that we do not collect any personal information without a legal basis such as consent, or our legitimate business interest in providing the best possible game experience to you."

    That is not allowed in Europe because it violates the GDPR. I'm looking forward to the renewed TOS.

    I was going to stay out of the discussion, but the above is not correct. GDPR allows for six ways that processing personal data can be legal. They are: consent, contract, legal requirement, vital interests, public task and legitimate interests. Of those, generally companies would rely on consent or contract, with legitimate interests considered the weakest of the set. The UK ICO says:

    "A wide range of interests may be legitimate interests. They can be your own interests or the interests of third parties, and commercial interests as well as wider societal benefits. They may be compelling or trivial, but trivial interests may be more easily overridden in the balancing test."

    See: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/

    Legitimate Interests is a vast area of woolly words, and I don't believe the legal precedent is yet clear as it requires the data controller to balance the interests of the data subject against their own "legitimate interests". One might argue that there is a conflict of interest...

    It is important, however, that companies are clear and transparent about what they do with data, and under what basis

    Chiming in to agree that Art. 6f is the weakest of all reasonings for data collection. Without going into too much detail, I've worked for an institution that used this as a basis for maintaining communication with their constituents from pre-GDPR to post, instead of presenting each one of them with opt-in messages.

    The assessment of two separate law firms broke down to this (disclaimer: this is not legal advice): You could do it like that, but until EU case law has caught up with the issue, you are shifting the burden of proof from your constituents' side to your side. Meaning for us, if a user filed a complaint about the unlawful collection of their data, and TP could produce a contract, or the paper trail of an informed consent, they would be in the clear. Under "legitimate interest", TP would first have to declare what that interest is and in what way they could fulfil that interest only by the means that they are employing.
  • DScottHewittDScottHewitt ✭✭✭✭✭
    As I understand it and from the podcast it was a collective (not borg) decision by all contributing authors, to remove the big book resource. Which I also understand that authors have the right do so unless they have sold the rights to a publishing company. Do not see the relevance or the need to get personal about this.

    Every thread seems to have to go down the "...and the equine entity that transported you to this location" path sooner or later. I get tensions are high, but players turning on each other solves nothing. It really doesn't.

    🖖🏿🖖🏽🖖🏼🖖🏻🖖

    Your comment would be far more persuasive if you applied it to everyone, including biggest bullies in the game. We would have a far stronger community if poor behavior was not condoned based upon one’s spending, which would give all of us more power to oppose tp’s practices that we disagree with.

    Please provide some examples of my condoning bullying? I would love to hear about how I have done that.....
    "The truth is like a lion; you don't have to defend it. Let it loose; it will defend itself."
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