Team17 Digital Limited and its group companies (collectively the “Company,” “we,” “us” and “our”), respects the privacy rights of our users and is committed to protecting the information collected through our products, services, and websites accessed through internet-capable hardware platforms including gaming consoles, personal computers, mobile computers, or mobile devices, or in-game applications or software platforms including third-party hosts (collectively the “Online Services“).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- What gameplay information does the Company collect?
- Special notes about certain Information the Company collects
- What happens if I refuse to provide my personal data?
- How is my personal data used?
- What is the legal basis for processing of my personal data?
- With whom does the Company share my information?
- How can you unsubscribe from mailings, cancel your account, or review and correct data?
- Your rights as a Data Subject
- Data Retention
- What is your policy regarding links to other sites?
- What safeguards are used to protect my personal data?
- Transfer of your information to other countries
- How do I ask a question or file a complaint?
The personal data we collect about you will normally be provided by you when you:
- Access and use our websites (including when you post in or comment on our message boards, forums, news blogs, chat rooms, or other Online Services);
- Register for Online Services, products, contests, and special events;
- Subscribe to newsletters or alerts;
- Purchase a product or service through our online stores;
- Purchase downloadable content, virtual items, or virtual currency for use with our software and/or Online Services;
- Use “tell a friend,” “email this page,” or similar features;
- Request technical support;
- Download demos, programs, or other software;
- Participate in polls, surveys, and questionnaires; or
- Otherwise through use of our software, including console products, mobile products, and personal computer products, and through the use of our online products or Online Services where personal data is required for use and/or participation.
The types of information collected in connection with the activities listed above will vary depending on the activity. The information we collect may include personal data such as your first and/or last name, e-mail address, phone number, photo, mailing address, geolocation, or payment information. In addition, we may collect your age, gender, date of birth, postcode, hardware configuration, console ID, software products played, survey data, purchases, IP address and the systems you have played on. We may combine the information with your personal data and across other computers or devices that you may use to access our products and services. Prize winners may be required to provide additional information for prize fulfilment.
If you use, purchase, or register for an Online Service through a third-party service such as a gaming console’s network service, an internet based gaming service, or a social network website, or request that we associate a Company account with a third-party service account, then limited user account personal data may be transferred to the Company as part of the registration process and we may be able to collect information about your use of the Online Services. For example, if you purchase virtual currency through a gaming console service, that gaming console service will provide us with information to effectuate the transaction, including the amount of virtual currency purchased and a means to identify your Online Service account.
When you use an application on a Social Networking Site (“SNS“), you allow us to access certain information from your profile from that SNS. The information you allow us to access is affected by the privacy settings you establish at the SNS. For example, our Facebook applications may access and store some or all of the following information, as allowed by you, the SNS and your preferences:
- your “basic information” you have shared with everyone on the SNS (which may include your profile picture or its URL);
- your friends list, your user ID number, which is linked to publicly available information such as name and profile photo; or
- other information indicated as part of the “Request for Permission” prompt from the SNS.
When you use Facebook Connect, OpenID or another multisite ID to log in to an Online Service, those ID services will authenticate your identity and provide you the option to share certain personal data with us to pre-populate our sign up form. Depending on your account settings, multisite IDs may also provide other information to us. Please check the terms of those services before using them to log into an Online Service. When you play certain software products published by the Company, information about your gameplay may be collected and transmitted to the Company through network services or any other internet connection method used by the hardware on which you play such games (collectively and individually your “Internet Connection“). See “What Gameplay Information Does the Company Collect?” below for further details.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
WHAT GAMEPLAY INFORMATION DOES THE COMPANY COLLECT?
When you use products or services on internet-capable hardware, the Company may receive information regarding your gameplay without any additional notice to you or actions taken by you. The Company will not receive personal data such as your name and address, but may receive other information such as a console ID, gaming service ID, game achievements, game scores and performance, IP address, MAC address, or other device ID, other console/device use information, or other information and statistics regarding your usage of the games.
Information about gameplay may be collected while you are offline and transmitted to the Company when you next connect to the Internet whether or not you are currently logged into your Internet Connection from your console, handheld, mobile device, computer, or other gaming platform.
SPECIAL NOTES ABOUT CERTAIN INFORMATION THE COMPANY COLLECTS
1. Aggregated data: We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature. If and when we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2. Member Names & IDs/Gaming Consoles/Social Network Services/Other Third-Party Services: Certain Online Services offered by the Company, including multiplayer gaming and specialized websites, use third-party services to (i) provide authentication for Online Services; or (ii) associate a Company service account with a third-party account such as a Gaming Console ID, Gaming Network Service account, or Social Network Service account. When you use a third-party authentication service or link your Company account with a third-party account, you will be asked to provide account information associated with that third-party account. Certain membership information may be transferred automatically to the Company when you register to join an Online Service from a third-party gaming network system or link your Online Service membership with a third-party service, such as your friends list on that gaming network or social network service.
3. Public Information Including Message Boards, User Generated Content, Forums, News Blogs, Comments, User Profiles and Chat Rooms: Whenever you give out personal data in public areas such as on a message board, chat room, comment field, or profile page, that information can be collected and used by other people. Information that you disclose in any of these forums is public information. You should be aware that any personal data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used for any purpose (for example, to send you unsolicited messages). Accordingly, to the fullest extent permissible by law, we shall have no responsibility for the controlling or processing of such data. If you post a video, image, photo, or other content through an Online Service for public view, you should be aware that these may be viewed, collected, copied, and/or used by other users without your consent. If your screen name or an ID contains your real name, then that name will be made publicly available on leaderboards and elsewhere. Therefore, you are strongly encouraged not to disclose personal data while using our services or use personal data to identify yourself while using our services. You are responsible for any public information or content you post using our Online Services.
4. E-mail Correspondence:
- We may provide e-mail addresses or forms to which visitors can send us questions or comments, or which visitors can use to request customer support. In the process of receiving and responding to such requests, we may collect personal data about you, such as your name, e-mail address or any other personal data contained in the body of your e-mail message. We only use such information for the purpose of responding to or dealing with your questions and/or comments or to provide customer support. In most cases, your message is deleted immediately after we’ve resolved your inquiry; however, in some instances, copies of your requests may be kept on file for our records, for quality control purposes, or to provide ongoing support services you have requested.
- If we have actual knowledge that the person with whom we’re communicating is a child under the age of thirteen, we delete the child’s e-mail address and message immediately after responding.
- In addition to responding to your email correspondence and sending you information you have requested via our email lists, we send activation emails and other transactional emails to your e-mail address as necessary in order to provide the products and services you request. If you do not wish to receive these emails, you have the option to deactivate your account.
5. Children. The Company does not knowingly collect personal data from children under 13 years old (or older, if applicable law provides for different protections). If we become aware that a child has submitted information to the Company, we delete this information immediately. We encourage parents and guardians to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.
6. Resumes/CVs: The Company allows for the online submission of resumes. Personal data collected from resumes will be used solely for the purpose of accepting and evaluating candidate submissions for job postings. A separate policy concerning the application process will be provided to applicants and its terms apply in priority to the terms set out herein.
WHAT HAPPENS IF I REFUSE TO PROVIDE MY PERSONAL DATA?
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Whilst we may be able to provide you with certain products and services notwithstanding your refusal to submit personal data, this may limit your ability to participate in some activities or features or your use of certain Online Services.
- Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Our cookies are typically used to quickly identify a user’s computer, browser, or device and to “remember” things about prior visits (such as the user’s use of various features on the service). You can disable cookies or set your browser to alert you when cookies are being sent to your computer; however, disabling cookies may affect your ability to use certain Online Services. On your mobile device, you may adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
- Flash Cookies: We may also use flash cookies, also known as “shared objects,” on our sites that employ Flash technology. Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site. You can clear Flash cookies already on your device by setting the Flash local storage setting to zero. You may also prevent Flash cookies from being placed by adjusting your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com.
Web Beacons: A “web beacon” is an electronic image that allows websites to count users who have visited certain pages or viewed certain advertisements.
- Internet Log Files: The Company may also keep track of IP addresses used to access its Online Services for various reasons. An IP address is a number that is used by a networked device and will identify your point of connection to the internet. Depending on your network configuration, it may also identify your computer, or other device. A MAC address or other device ID identifies one specific piece of hardware. These log files are tied to your personal data in certain circumstances, such as if you have linked your console user account to Online Service accounts offered by the Company.
- Analytic Metrics Tools and Other Technologies: Other information that may be passively collected by the Company includes log files that record information about your hardware, product use, service use, or website use, including website navigation and game telemetry activity. We also use these log file entries for our internal marketing, service design, technical support, and demographic studies, so we can constantly improve the Online Services we provide you.
Additional information about individual opt-out programs is available on the World Privacy Forum website at https://www.worldprivacyforum.org/. In addition to visiting the websites of each of the vendors listed above, you may opt out of certain targeted advertising by multiple third-party advertising networks at one time if they belong to the Network Advertising Initiative or the Digital Advertising Alliance. Visit the Network Advertising Initiative’s website at https://www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance’s website at https://www.aboutads.info/ to select the applicable networks. For visitors from the European Union, visit Your Online Choices at https://www.youronlinechoices.eu/. On your mobile device, you may adjust your privacy and advertising settings to control whether you want to receive targeted advertising.
HOW IS MY PERSONAL DATA USED?
- personalising content;
- sending you promotional materials;
- providing you with access to our products and services;
- fulfilling product orders;
- fulfilling “tell a friend” requests;
- responding to questions, comments or technical problems;
- market research and demographic studies;
- carrying out other business activities in circumstances where you have, or ought reasonably to have, an expectation that we will process your personal data for a particular purpose (including the fulfilment of any arrangements or agreements between us).
Your participation in tournaments or other online game events is conditional upon our collection, use, storage, transmission and public display of statistical data (such as your scores, rankings, and achievements) generated through your participation.
Online gaming and Social Networking Services are by their very nature open communities where gameplay information including user name, game activity, and leaderboard rankings are publicly posted for other people to see. Therefore, the Company will automatically post certain information, such as your Screen Name or ID and gameplay statistics, within the game, on Social Networking Services, on Online Services, or on specialized game websites. However, we will not post information that we know directly identifies you (such as your real name or email address) unless you provide that information voluntarily for such use. As with other gameplay information services, your gameplay, leaderboards, and multiplayer match information may appear nested in our games or third-party webpages via frames or widgets.
We may match and/or combine information collected in connection with various Online Services and display it publicly, including on our websites, in our games, or in multiplayer game lobbies. For example, if you associate your Company website account with a game console account, your in-game achievements may be displayed combining your website account name with your in-game achievements.
Some of our Online Services offer SNS features and Widgets, such as the Facebook “Like” button, Google + button, or the Share This button. These third-party SNS features may set a cookie to enable the Feature to function properly and may collect information about you when you use them, such as your IP address and which page you are visiting on our site. SNS features and Widgets are either hosted by a third party or hosted directly by our Online Services. Your interactions with these
From time to time, the Company may employ vendors to perform services on the Company’s behalf. These vendors provide internal support to the Company by operating some of the services we provide you such as contest entry collection and email services. Although these vendors, not the Company, may collect, use, or maintain the information in connection with the Online Services, the Company still requires that they adhere to the Company’s stated privacy policies and that they not share your personal data with third parties or use the information for their own marketing purposes.
You may withdraw your consent given under this section at any time by contacting firstname.lastname@example.org. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before withdrawal.
WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF MY PERSONAL DATA?
The Company may process your personal data:
- In accordance with your express consent given under the section above titled “Consent” for the purposes identified under the section above entitled “How is my personal data used?”.
- Where such processing as is necessary in order to perform any agreement between us or comply with any legal obligation.
- Where such processing is necessary for the purposes of the legitimate interests pursued by us or third parties. These legitimate interests include those identified under the section above entitled “How is my personal data used?” as well as:
- Our internal administrative purposes;
- Providing you with our products and services, including the Online Services;
- Personalizing content we send you; and
- Where you may have a reasonable expectation that we will process your personal data for a particular purpose (such as if and when you enter into a competition or online tournament).
WITH WHOM DOES THE COMPANY SHARE MY INFORMATION?
We may share your personal and other information with third parties in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability, including as required by law enforcement or other government officials. We also may share your personal and other information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, investigate, or enforce our policies, terms, and conditions, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on the Company. In addition, your personal and other information may be disclosed to a potential or actual successor or assigned in connection with a proposed or consummated merger, acquisition, reorganization, bankruptcy, or other similar event involving all or a portion of the Company.
We also use third parties for various services related to the Online Services, including customer support, technical support, contest data collection, and email fulfilment. When you enter a contest or sign up to receive a newsletter, for example, we may share your personal data as necessary for third parties to provide services on our behalf. These third parties are not permitted to use such information for their own marketing purposes.
HOW YOU CAN UNSUBSCRIBE FROM MAILINGS, CANCEL YOUR ACCOUNT, OR REVIEW AND CORRECT YOUR DATA
If you are a member of an Online Service, you may use that service’s account and privacy settings to personalize the collection, use and/or display of your data via that service.
If you do not want to receive certain communications such as newsletters or promotional offers, you may decline consent at the time your personal data is collected or later opt-out by using the methods listed below. In addition to the methods below, along with every promotional communication sent to you, the Company gives you the opportunity to discontinue receiving future promotional communications.
If for any reason you wish to unsubscribe to Team17 mailing lists please use the ‘unsubscribe’ or similar link in the relevant email correspondence, email email@example.com or write to us at 3 Red Hall Avenue, Paragon Business Park, Wakefield, WF1 2UL.
YOUR RIGHTS AS A DATA SUBJECT
Subject to any conditions or requirements set out in the GDPR or other applicable law or regulation, the Company hereby informs you that you may have the following rights in relation to the personal data we hold about you:
- the right to request a copy of your personal data held by us;
- the right to correct any inaccurate or incomplete personal data held by us;
- the right to request that we erase your personal data;
- the right to request that we restrict the processing of your data (as set out in the GDPR);
- the right to have your personal data transferred to another organisation;
- the right to object to certain types of processing of your personal data by us; and
In order to make an enquiry about any of these rights please email firstname.lastname@example.org or write to us at 3 Red Hall Avenue, Paragon Business Park, Wakefield, West Yorkshire, WF1 2UL. Please indicate your country of residence in your correspondence.
Without prejudice to your right to ask us to erase your personal data, we will retain your information only for as long as your account is active, as needed to provide you services, or to administer our services. If you wish to cancel your account or request that we no longer use your personal data to provide you services, contact us as described above. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our services. After such period, we will delete personal data, including your email address and log-in credentials, and you may no longer be able to access your account. We will attempt to notify you before we delete your account information so that you have the opportunity to keep your account active. We may still retain some of your information in our files for a reasonable period of time to resolve disputes, enforce our user agreement, administer our services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Online Services, after which we will take steps to delete or archive it.
WHAT IS YOUR POLICY REGARDING LINKS TO OTHER SITES?
WHAT SAFEGUARDS ARE USED TO PROTECT MY PERSONAL DATA?
To protect your personal data, the Company follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. The Company has security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal data collected by the Company is stored in secure operating environments that are not available to the public. To prevent unauthorized electronic access to personal data, the Company maintains information collected online behind a firewall-protected server and uses SSL encryption for purchases made through our online store.
However, no system can be 100% secure and, to the fullest extent permitted under applicable law, we assume no liability for unauthorized access to your information. In addition, you are responsible for maintaining the strength and confidentiality of your login credentials.
Notwithstanding the foregoing, we will notify you as soon as reasonably practicable if we have reason to believe that there has been a personal data breach by us which could adversely affect your rights and freedoms.
TRANSFER OF YOUR INFORMATION TO OTHER COUNTRIES
Information collected or received by the Company in connection with the Online Services may be transferred to other countries and jurisdictions within the EEA or which the EU Commission has approved as having an adequate level of protection.
Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the USA.
HOW DO I ASK A QUESTION OR FILE A COMPLAINT?
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).