Last updated: 16 March 2023
We understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who plays our games and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
In this policy, “we,” “us,” and “our” means Futurlab Limited, a limited company registered in England under company number 04961083, whose registered address is Preston Park House, South Road, Brighton, East Sussex, UK, BN1 6SB, and whose main trading address is Regent House, Hove St, Hove BN3 2DW.
1. About this Policy
This policy deals with where we are acting as a ‘data controller’ under the data protection legislation: which essentially means where we are responsible for deciding what personal information we collect and how we use it. When we refer to “personal information” we mean information relating to you personally or from which you can be identified. Some of the information mentioned in this policy is not ‘personal information’ as is meant under data protection legislation, but we may refer to it to help you understand what we do.
We are committed to protecting and respecting the personal information of everyone we deal with – that is important to us and we know it is important to you.
In this policy you will find information about what types of personal information we hold about you, how and why we collect it, how we use it, and how we keep it secure. You’ll also find information about your rights and how you can exercise them.
Please read this policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal information, you can reach us by email at email@example.com or by post at the address above.
2. What information do we collect about you?
We will collect some information about you to enable you to play the Game, to improve or optimise your gaming experience, to provide player services, to improve the services we provide and for marketing (see below for more details). This may include:
- Your game profile – including information needed for the game to function, such as in-game progress, achievements and an inventory of in-game items.
- Player ID – a randomly generated identifier used to distinguish activity from one game account versus another.
- Third party account ID – for example your account with Steam, Xbox, PlayStation, Nintendo Switch or other third parties which you may use to play the Game.
- Usage and telemetry data including information about how you use the Game, and related services and technical information about the device you are using.
- IP address including rough location information.
3. How we collect information about you
We will collect this information in a variety of ways depending on how we interact with you.
You may give us your identity, contact or other information by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- use our products or services;
- interact with customer services;
- subscribe to our mailing lists;
- enter a competition, promotion or survey;
- register for alpha, beta or other early access to game features;
- give us feedback; or
- provide services to us.
Automated technologies or interactions
As you interact with the Game we may automatically collect technical data about your device, in-Game actions and patterns. We collect this personal data by using third party analytics software such as PlayFab, telemetry data, server logs and other similar technologies.
We may receive personal data about you from a third party platform or distributor for example from your account with Steam, Xbox, PlayStation, Nintendo Switch or other third parties which you use to sign into the Game.
4. How we use your information
We use different information in different ways:
- providing and managing the Game and its related services;
- to answer your enquiries or deal with your complaints;
- account verification and clearance;
- displaying your in-game profile;
- displaying leader boards, nicknames and any clan/guild information;
- to help us develop improve the Game;
- detecting hacking, cheating and other activities that ruin the experience of players using the Game;
- detecting and reporting fraud and other unlawful activity;
- direct marketing to let you know about products and services that may be of particular interest to you;
- administering surveys and opinion polls;
- managing competitions and/or promotions and your registration for the same;
- managing alpha, beta or early access tests including collecting your feedback; and
- complying with legal or regulatory requirements.
We do not make any legally significant decisions about individuals based solely on automated decision-making.
5. Legal basis for processing
There are a number of different legal grounds for processing personal information. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that:
- you have provided your consent to us using your personal information in that way;
- our use of your personal information is in our legitimate interest as a commercial organisation. However, we will only use personal data relating to players users for the purposes of legitimate interests where players’ interests, and rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with. Our legitimate interests include for the purpose of providing, developing, improving and promoting the Game and our wider business;
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or
- our use of your personal information is necessary to comply with a relevant legal or regulatory obligation.
6. Sharing your information
The personal information you provide to us may be shared with other players, our staff and the following types of third parties:
- platforms and distributors of our games such as Steam, Xbox, PlayStation, Nintendo Switch;
- service providers such as game back-end providers (like PlayFab), data analytics providers, data storage providers, marketing partners, and customer service support partners;
- our auditors, insurers, lawyers and other professional advisers;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
- other wholly-owned subsidiary, sister or holding companies in our corporate group; or
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
If you have agreed to be contacted for marketing purposes we may use your personal information to send you information about us and our services. You can unsubscribe from receiving them at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further such e-mail or other marketing communications from being sent to you by emailing firstname.lastname@example.org.
We will action any opt out request from you as soon as we can.
We do not knowingly collect or use any personal data relating to children under the age of 13.
9. International transfers
We routinely transfer personal data outside the EEA. Where we transfer personal data outside the EEA to a country that has not been recognised as providing an adequate level of data protection we use the standard contractual clauses unless we have identified another appropriate safeguard or relevant exemption.
10. How long will we keep your information?
We keep personal data relating to players for the period that the Game is available to play. Once we make the Game unavailable, we will delete all personal data relating to players of the Game.
In some circumstances you can ask us to delete your data: see “Your Rights” below for further information.
Sometimes we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
11. Your Rights
Everyone has the right to:
- Information about how we use personal data (which is what this notice is for)
- Access to personal data
- Object to the use or disclosure of personal data for certain purposes
- Erasure of personal data
- Portability of personal data
- Withdraw consent where our use of personal data is based on consent
- Rectification of personal data
- Restriction of personal data
- Complain to your supervisory authority
Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant.
You will not be treated differently or discriminated against for exercising any of your rights.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.
13. Terms of Service
14. Changes to this Policy
We may need to amend this policy from time to time, for example, in order to ensure that we remain compliant with applicable law or to reflect any changes we make to the Game and its related services.
Your continued use of the Game and its related services after any changes to the policy have been made by us will mean that you accept those changes. If you do not agree to any changes to the policy, you may not continue to use the Game and its related services.
Any changes to this policy will not affect your accrued rights and will not have any retrospective effect.
If you wish to contact us, please email email@example.com.