Effective Date: August 4, 2025 | Last Updated: August 4, 2025
1. Data Protection Overview
At SEABIRD Games, data protection is not just a legal requirement—it's a fundamental commitment to our users. This page provides detailed information about our comprehensive data protection framework, technical safeguards, and organizational measures.
1.1 Our Commitment
- Privacy by Design: Data protection integrated into all systems from the start
- Privacy by Default: Most privacy-friendly settings as standard
- Transparency: Clear, understandable information about data processing
- User Control: Easy-to-use tools for managing your data and privacy
- Continuous Improvement: Regular reviews and updates of our practices
1.2 Compliance Standards
🇪🇺 GDPR Compliant
🇺🇸 CCPA Compliant
🇨🇳 PIPL Compliant
🇧🇷 LGPD Compliant
🇨🇦 PIPEDA Compliant
🇦🇺 Privacy Act Compliant
2. Technical Security Measures
2.1 Data Encryption
| Data State |
Encryption Method |
Key Management |
Implementation |
| Data in Transit |
TLS 1.3, HTTPS, WSS |
Certificate rotation every 90 days |
All API communications, website traffic |
| Data at Rest |
AES-256 encryption |
Hardware Security Modules (HSM) |
Database encryption, file storage |
| Backup Data |
AES-256 + additional encryption layer |
Separate key management system |
Automated encrypted backups |
| Application Data |
Field-level encryption for sensitive data |
Application-managed keys |
User credentials, payment info |
2.2 Access Controls
- Multi-Factor Authentication (MFA): Required for all administrative access
- Role-Based Access Control (RBAC): Principle of least privilege
- Zero Trust Architecture: Verify every access request
- Session Management: Automatic timeout and re-authentication
- Privileged Access Management: Enhanced controls for sensitive operations
2.3 Infrastructure Security
- Cloud Security: AWS/Google Cloud with SOC 2 Type II compliance
- Network Security: VPCs, firewalls, intrusion detection systems
- Container Security: Kubernetes with security policies and scanning
- Endpoint Protection: Anti-malware, device management
- Security Monitoring: 24/7 SOC with automated threat detection
2.4 Application Security
- Secure Development: OWASP guidelines, security code reviews
- Vulnerability Management: Regular scanning and penetration testing
- Input Validation: Protection against injection attacks
- Output Encoding: Prevention of XSS and data exposure
- API Security: Rate limiting, authentication, authorization
3. Organizational Security Measures
3.1 Personnel Security
- Background Checks: Comprehensive screening for all employees
- Security Training: Regular mandatory training on data protection
- Confidentiality Agreements: Legal obligations for all staff
- Access Provisioning: Formal process for granting system access
- Departure Procedures: Immediate access revocation upon termination
3.2 Governance and Policies
- Data Protection Officer (DPO): Dedicated privacy oversight role
- Privacy Committee: Cross-functional team for privacy decisions
- Policy Framework: Comprehensive data protection policies
- Regular Audits: Internal and external privacy assessments
- Incident Response: Formal procedures for data breaches
3.3 Vendor Management
| Vendor Type |
Due Diligence |
Contractual Requirements |
Monitoring |
| Data Processors |
Security assessments, compliance verification |
Data Processing Agreements (DPAs) |
Regular compliance reviews |
| Cloud Providers |
SOC 2 Type II, ISO 27001 certification |
Standard Contractual Clauses (SCCs) |
Continuous monitoring |
| Analytics Partners |
Privacy policy review, data minimization |
Data sharing agreements |
Data flow audits |
| Support Tools |
Security evaluation, access controls |
Business Associate Agreements |
Usage monitoring |
4. Data Breach Response
4.1 Incident Response Process
- Detection & Assessment (0-1 hour):
- Automated monitoring systems alert security team
- Initial assessment of scope and severity
- Containment measures activated immediately
- Investigation & Containment (1-12 hours):
- Detailed forensic investigation
- Full containment of the incident
- Assessment of affected data and individuals
- Notification (12-72 hours):
- Supervisory authority notification (within 72 hours)
- Affected individuals notification (without undue delay)
- Internal stakeholder communications
- Recovery & Lessons Learned (ongoing):
- System restoration and security improvements
- Root cause analysis and preventive measures
- Documentation and reporting
4.2 Notification Requirements
- GDPR: Supervisory authority within 72 hours, individuals without undue delay
- CCPA: Individuals without unreasonable delay, AG if required
- PIPL: CAC and affected individuals promptly
- Other jurisdictions: Comply with local notification requirements
4.3 Support for Affected Individuals
- Dedicated incident response helpline
- Clear guidance on protective measures
- Credit monitoring services (if applicable)
- Regular updates on investigation progress
5. Data Subject Rights Implementation
5.1 Rights Exercise Process
| Right |
Request Method |
Response Time |
Technical Implementation |
| Access |
Online portal, email |
30 days (GDPR) |
Automated data export system |
| Rectification |
Account settings, support |
30 days |
Real-time data update system |
| Erasure |
Account deletion, request form |
30 days |
Automated deletion with verification |
| Portability |
Data export tool |
30 days |
Structured data format (JSON/CSV) |
| Restriction |
Privacy settings, support |
30 days |
Processing flags and controls |
| Objection |
Opt-out tools, email |
Immediate |
Real-time processing controls |
5.2 Identity Verification
- Multi-factor verification: Combine account credentials with additional verification
- Document verification: Government-issued ID for sensitive requests
- Risk-based approach: Enhanced verification for high-risk requests
- Fraud prevention: Detection of potentially fraudulent requests
5.3 Appeal Process
- Clear escalation path for disputed responses
- Independent review by Data Protection Officer
- Right to complain to supervisory authorities
- Alternative dispute resolution options
6. Legal Basis and Compliance
6.1 Data Processing Legal Basis
| Processing Purpose |
Legal Basis (GDPR) |
Justification |
Data Retention |
| Game Service Provision |
Contract Performance |
Necessary to deliver game services |
Until account deletion + 30 days |
| Customer Support |
Contract Performance |
Necessary to provide support services |
3 years after last contact |
| Analytics & Improvement |
Legitimate Interest |
Improve user experience and game quality |
13-26 months (anonymized) |
| Security & Fraud Prevention |
Legitimate Interest |
Protect users and prevent abuse |
12 months |
| Marketing Communications |
Consent |
User explicitly opted in |
Until consent withdrawn |
| Legal Compliance |
Legal Obligation |
Required by applicable laws |
As required by law |
6.2 International Data Transfers
- Adequacy Decisions: Transfers to countries with adequate protection
- Standard Contractual Clauses: EU Commission-approved SCCs
- Binding Corporate Rules: Internal privacy rules for multinational companies
- Consent: Explicit consent for specific transfer scenarios
- Necessity: Transfers necessary for contract performance
6.3 Records of Processing Activities
- Comprehensive documentation of all processing activities
- Regular updates to reflect changes in processing
- Available for supervisory authority inspection
- Includes purposes, categories, and safeguards
7. Privacy Impact Assessments
7.1 When We Conduct PIAs
- High-risk processing: New technologies or processing methods
- Large-scale processing: Processing affecting many individuals
- Special categories: Sensitive personal data processing
- Automated decision-making: Profiling with legal effects
- Systematic monitoring: Public area surveillance
7.2 PIA Process
- Necessity Assessment: Determine if PIA is required
- Data Flow Mapping: Document data collection and processing
- Risk Identification: Identify potential privacy risks
- Impact Assessment: Evaluate severity and likelihood
- Mitigation Measures: Implement risk reduction strategies
- Stakeholder Consultation: Engage with affected parties
- DPO Review: Independent assessment by Data Protection Officer
- Supervisory Authority Consultation: If high residual risk remains
7.3 Recent PIA Results
- Mobile Game Analytics (2025): Low risk after implementing data minimization
- Customer Support AI (2024): Medium risk, enhanced human oversight implemented
- Cross-platform Sync (2024): Low risk with end-to-end encryption
8. Certifications and Audits
8.1 External Certifications
- ISO 27001: Information Security Management System certification
- SOC 2 Type II: Service Organization Control audit report
- Privacy Shield (Historical): EU-US data transfer framework
- COPPA Safe Harbor: Children's privacy protection certification
8.2 Regular Audits
- Annual Privacy Audit: Comprehensive review by external auditors
- Quarterly Security Assessment: Technical security controls review
- Monthly Compliance Review: Internal policy compliance check
- Continuous Monitoring: Automated compliance and security monitoring
8.3 Industry Participation
- International Association of Privacy Professionals (IAPP)
- Mobile Game Privacy Coalition
- Entertainment Software Association (ESA)
- Cloud Security Alliance (CSA)
Data protection is at the core of everything we do at SEABIRD Games.
We continuously invest in people, processes, and technology to ensure your personal data receives the highest level of protection.