PRIVACY AND DATA POLICY ISSUED BY STRAIGHT4 STUDIOS
Last Updated: February 2023
1. INTRODUCTIONAND GENERAL TERMS
These terms apply to the use of games and other products developed by Straight4 Studios Limited (‘S4’ / ‘we’ / ‘us’). Our registered office is 128 City Road, London, EC1V 2NX, UK. We are a company registered in England, with company number 14543738.
- all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)”);
- any other online features relating to the Games including our website(https://www.straight4.com/) (the “Website”);
- mailing lists we operate in respect of any Games (the “Mailing List”),
- user support Centre in respect of any Games (the “Support Centre”).
Together the Game(s), the Website, the Mailing List, and the Support Centre are referred to as the “Online Services”.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal data you have provided to us.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATIONWE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data Information
provided by you when using the Online Services.
We will collect the following information from you when you play our Games:
- your console’s unique device ID (Console ID) (if applicable);
- your Steam ID (if applicable);
- any third party platform profile display names;
- your user preferences; and
- core information milestones related to your gameplay, such as your overall progression to a particular level or stage, or the completion of certain activities during your gameplay (for example, completing a tutorial or passing a level).
We may collect the following technical information about your use of the Online Services through the use of tracking technologies and analytics (and you can refer to Section 4 (Cookies) for more information about this tracking technology):
- how many times you visit the Website;
- which pages you go to;
- traffic data;
- your IP and MAC address;
- you internet service provider;
- your Console ID;
- your user ID (which is generated by us and allocated to you when you first play our Games);
- your device operating system & version;
- your device make and model;
- game play attempts, progression and results;
- session game time start, end and duration;
- the country of your device; and
- identification of crashes and defects.
“Mailing List Information”
We may ask you for, or you may submit, your email address and your name to us whenever you sign up to our Mailing List.
“Third Party Log In Information”
When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal data which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook cookies within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.
Content created by our users which we host and display in the Support Centre: when users submit their own user content to the Support Centre, this content may contain personal and non-personal data. This could include information in or about the user content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.
We will collect the following information from you when you submit enquiries, questions, complaints or support requests in relation to our Games or Website [via the Support Centre, email or our Website]: - your name;
- your email address or social media account details; and
- any personal data contained within your enquiry, question or complaint (including any Basic Information).
3. WHY WECOLLECT INFORMATION ABOUT YOU
To provide the Online Services to you
To help us improve the Online Services and fix any problems
Our purpose: We may process information about you (including Basic Information, User Content, Enquiry Information and Analytics) for the purpose of analysing and improving our Games and Online Services.
Our lawful basis for collecting this information: We rely upon your consent to collect Analytics relating to you via the use of tracking technology (and you can refer to Section 4 (Cookies) for more information about this tracking technology). You can withdraw your consent at any time by contacting us at email@example.com. Otherwise, the remaining processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services;(ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Online Services.
To respond to your enquiries and requests for support and to enable you to use the Support Centre
Our purpose: We may process Enquiry Information so that we are able to properly respond to your enquiries, questions, complaints or support requests.
Our lawful basis for collecting this information: This processing is necessary for us to pursue our legitimate interests of (i)ensuring the smooth operation of our business and Online Services; and (ii)understanding our customers; and (iii) improving our Online Services.
To acquire new users and engage current users
Our purpose: We may process Mailing List Information to make suggestions and recommendations to you and other users of our Games about goods and services that may interest you or them, to provide you with information about other games and services we offer that are similar to those that you have already purchased, to notify you about changes to our Games or the services we provide, and to improve the relevancy of our marketing (including the creation of ‘lookalike’ audiences which allows us to offer more relevant marketing to potential new service users without using information that personally identifies individuals).
Our lawful basis for collecting this information: This processing is necessary for us to pursue our legitimate interests of (i)operating our business; (ii) promoting its commercial success; and (iii)acquiring new users for our Games.
To prevent fraud and illegal activity
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
- Authentication: To log you into our Website and Games and keep you logged in.
- Preferences: To remember information about you such as your preferred language and configuration.
-Analytics: To help us understand how you use our Games and Website, and how often, so we can improve them to deliver a better experience for our users. To carry out research and statistical analysis to help improve our content, products and services.
We get your consent to use the above cookies on our Website unless they’re essential for our Website to function.
Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.
Other settings to disable certain similar technologies: Windows Advertising ID | iOS and Mac OS Ad Tracking | Google Analytics | Your Ad Choices.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of SMS, our customers, or others.
Digital Content Stores: Where the Games are downloaded through Steam, Xbox Live, PSN, we may disclose your personal data to Valve Corporation, Microsoft and Sony, respectively for the purposes of facilitating any payments made through these platforms.
6. YOURRIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
Users have the following rights, although these rights maybe limited in some circumstances:
- Ask us to send a copy of your personal data to you or someone else
- Ask us to restrict, stop processing, or delete your personal data
- Object to our processing of your personal data
- Object to use of your personal data for direct marketing purposes
- Ask us to correct inaccuracies in your personal data
If we rely on consent to process personal data you can with draw consent at any time.
To make a request for your rights, please let us know by sending an email to the email address set out in the next section below.
You also have the right to submit a complaint to a supervisory authority. For example, in the United
Kingdom, you can get in contact with the Information Commission’s Office: ico.org.uk. If you live in the United Kingdom or a European country, you can alternatively submit a complaint to the supervisory authority in your country/state. If you live outside of those territories, you may have a supervisory authority in your country whom you can also turn to.
We hold personal data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain personal data to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data,the potential risk of unauthorised access, and legal requirements. If you would like us to delete any User Content that you have posted, please let us know b sending an email to firstname.lastname@example.org.
We will take all appropriate technical and organisational precautions implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk. For example, our databases are password protected and limited to essential employees only (such as S4management or employees whose main role requires system access).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
10. INTERNATIONALDATA TRANSFERS
Any personal data we process, relating to you, is stored in our servers in the United States. Where we transfer your information outside of the United Kingdom, and where we are required to do so, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the Information Commissioner’s Office to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to email@example.com.
All questions, comments or enquiries should be directed toS4 at firstname.lastname@example.org. We will endeavour to respond to any query or questions within three business days.
© 2023 Straight4 Studios Limited. All trade marks are the property of the relevant owners. All rights reserved.