Privacy

Ripstone ltd

Last Updated: February 2022

  1. INTRODUCTION AND GENERAL TERMS

We are RIPSTONE LTD.; game development company.  We are a company incorporated in England under company number 07489192, and our registered address is at Elevator Studios, 25 Parliament Street, Liverpool, L8 5RN (“Bulkhead”, “we”, “us“, “our”).

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of our games (the “Game(s)”), and all related online services (including online network play connectivity and interactivity) made available by us specific to the Games (the “Online Service“).

If you have any questions or comments about this Privacy Policy, please contact us at privacy@ripstone.com

We are committed to respecting your privacy and complying with laws and regulations to ensure that the personal information you give us is kept secure and processed fairly.

The Privacy Policy explains the basis on which personal information we collect from you will be processed by us within the scope of this Privacy Policy. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

  • 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 information you have provided to us.

This Privacy Policy should be read in conjunction with our terms of use for the Games.

The Online Service may contain hyperlinks to services owned and operated by third parties. The linked services operate fully independent from us and have separate and independent privacy policies that we encourage you to review when you visit those sites. They will govern the use of personal information 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.

We may make changes to this Privacy Policy in future, which will be posted on this page. Where appropriate we may notify you of changes through the Games.

  1. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information, which may include your personal data.

Information provided by you when playing the Games

(“Basic Information”)

We will collect the following information from you when you play the Game.

This may include:

  • your in-Game username
  • your platform ID
  • your actions and activity within the Game including in-Game player chat
  • your console network ID

Contact information provided by you when you contact us

(“Contact Information”)

We may ask you for, or you may submit, certain contact information to us whenever you contact us via privacy@ripstone.com

This may include:

  • your email address; and
  • your name.

How you play the Game and use the Online Services

(“Analytics”)

We may collect technical information about your use of the Game and/or Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

  • your console ID
  • dates of logins to the Game
  • game play results (e.g. wins/losses, kills/deaths)
  • game play progress
  • game play time (e.g. start, end and duration)
  • any purchases you have made in the Game
  • identification of crashes and bugs.
  1. WHY WE COLLECT AND USE YOUR PERSONAL INFORMATION

We may collect and use your personal information for the following purposes:

To provide the Game and the Online Services to you

We will use information about you (including Basic Information and Analytics) for delivering the Game to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within the Game, and to ensure the Game delivers the features promised and function properly, so that you have the best experience when playing the Game and using the Online Services.

To help us improve the Game and Online Services, and to fix any problems

We may process Basic Information and Analytics about you so that we can analyse and improve the Game and Online Services.

This processing is also 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 our Game and using the Online Service; (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 Game and Online Service.

To respond to your enquiries and requests for support

We may process Contact Information so that we are able to pursue our legitimate interests of properly responding to your enquiries and support requests via privacy@ripstone.com, and so that you are able to play the Game and/or use the Online Service.

You are under no obligation to provide us with any details, but if you don’t provide all relevant information we may not be able to help with your enquiry or support request.

To improve the Game via in-game purchases

We may process information (including Basic Information and Analytics) to understand how users use the Game and spend money within the Game, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within the Game. This processing is necessary for us to pursue our legitimate interests of improving the Game and increasing the amount of revenue generated.

To Prevent Cheating, Fraud and Illegal Activity

We process personal data for the legitimate interests of ensuring that use of the Game and the Online Service is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

  1. HOW WE PREVENT CHEATING

PLEASE NOTE: We do not use automated decision-making methods which do not involve human involvement to process your information.

Currently we do not process your personal information via automated decision making methods in order to identify users who are cheating in the Games. Instead, we rely on our community to look out for and report irregularities in game play behaviour.

If users are determined to be or suspected of cheating or acting in violation of our terms of use for the Game, the following actions may be taken:

  • indefinite suspension from playing the Game, although they will still have access to their Game account; and
  • anything acquired relating to the Game, be it through credits or real-money purchase, will be lost.

In this scenario, the user will be informed of the outcome and will have the right to express his or her point of view and to contest our decision to block access to the Game.  If this applies to you, please contact us at privacy@ripstone.com.

  1. WHO WE SHARE YOUR INFORMATION WITH

We will share your information with third parties only in the ways that are described in this Privacy Policy.

Third Parties:  As reasonably necessary for the purposes set out in this privacy policy, we may share your personal information with carefully-selected third parties (including suppliers and subcontractors), who are engaged to help us run, manage and improve the quality of the Online Services that we offer, as well as for marketing and fraud prevention purposes and to protect and defend our rights and property.

Third party service providers named in this Privacy Policy which carry specific activities for managing purchases, logins and players.

We only provide these companies with the information which they need to carry out their services for specified purposes and in accordance with our instructions, and they will not be permitted to use the information for other purposes. We require all third parties to treat your personal information as carefully and confidentially as we do and to take appropriate security measures to protect your personal information in line with our policies.

Group members, personnel,: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) and our personnel, insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

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:  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).

Digital Content Stores:  Where the Game is downloaded through third party games store, we may disclose your personal information to those game stores respectively for the purposes of facilitating any payments made through these platforms.

  1. SECURITY

We will take all reasonable technical and organisational precautions such as encryption and password protection of your data, to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Please be aware that, while we make the security of your personal information a high priority and we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all security breaches.

  1. INTERNATIONAL DATA TRANSFERS

Specific providers we work together with may be based outside the European Economic Area (EEA). Countries outside of the EEA offer varying standards for the protection of personal data and your privacy rights and in some cases these standards are lower than equivalent EEA standards.

When we send your personal data outside the EEA to our service providers, we have in place the EU Commission-approved standard contractual clauses in the form of an appropriate data transfer agreement or other adequate safeguards to ensure appropriate data protection.  For further information about these safeguards you can contact us at privacy@ripstone.com.

  1. RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you want us to delete any personal information that we hold about you for any reason you can ask us to do so by contacting us via privacy@ripstone.com. Please note that where you have purchased in-game items or perks you may no longer have access to these if you ask us to delete your personal information (this will be the case even where you have paid for these items or perks).

  1. CHILDREN’S PRIVACY

We do not knowingly solicit data from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from playing the Game and accessing the Online Service. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@ripstone.com. We will delete any personal information that relates to children under the age of 13, if we become aware of such information, within a reasonable time.

  1. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay in response and within one month at the latest from the date of a request made by you.  You have the right to:

  • request a copy of personal data we are processing about you and have inaccuracies corrected. We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to);
  • request us to restrict or stop our processing, or to delete your personal data. You can delete your Game account by following the instructions in your account settings;
  • request a machine readable copy of your personal data, which you can use with another service provider. If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
  • make a complaint to a data protection regulator.

Please send your requests to privacy@ripstone.com. Please note that we may require you to verify your identity before allowing you to access your personal information.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to us at privacy@ripstone.com. We will endeavour to respond to any query or questions within a reasonable time.