PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY. BY USING THE WWW.ROBERTSSPACEINDUSTRIES.COM WEBSITE AND RELATED WEBPAGES (THE “WEBSITE”), OR ANY OF THE CONTENT MADE AVAILABLE VIA THE WEBSITE, INCLUDING THE “STAR CITIZEN” GAME AND THE “SQUADRON 42” GAME (COLLECTIVELY, THE “GAME”), AND ANY OTHER PRODUCT, ONLINE SERVICE OR WEBSITE (INDIVIDUALLY AND COLLECTIVELY, THE “RSI SERVICES”), YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

WE RESERVE THE RIGHT TO REVISE AND REISSUE THIS PRIVACY POLICY AT ANY TIME. ANY CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING OF THE REVISED PRIVACY POLICY. YOUR CONTINUED USE OF OUR THE RSI SERVICES INDICATES YOUR CONSENT TO THE PRIVACY POLICY THEN POSTED. IF THE CHANGES ARE MATERIAL WE MAY PROVIDE YOU ADDITIONAL NOTICE TO YOUR EMAIL ADDRESS.

1. Introduction

The data controller responsible for your Personal Data depends on where you live:

If you reside in the United States of America, the data controller is Roberts Space Industries LLC, a company registered in Delaware, USA, with offices at 13420 Galleria Cir. Ste A-250 Bee Cave, TX 78738 USA.
If you reside anywhere else in the world, the data controller is Roberts Space Industries International Limited, a company registered in England (Company number: 08882924) with offices at 6 Goods Yard Street, Manchester, M3 3BG, UK.

In this policy, “RSI”, “we”, “us”, “our” refer to the relevant entity identified above. The Personal Data you submit to us via the RSI Services (or otherwise) will be processed by us or by data processors acting on our behalf in accordance with this Privacy Policy.

RSI respects your privacy rights and recognizes the importance of protecting the information collected about you. We have adopted this Privacy Policy to explain how we collect, use and store your Personal Data and Non-Personal Data.

If you want to know what Data we hold about you or if you have any other queries in relation to this Privacy Policy, please contact us by emailing us at privacy@cloudimperiumgames.com. We will require you to verify your identity before releasing any information to you.

Location Specific Details

Depending on where you are resident, you may have additional rights. These are set out in the following sections for this Privacy Policy:

Nevada – Sections 13;
California – Section 14;
Texas – Section 15;
Delaware – Section 16;
Canada – Section 17;
UK and EU – Section 18;
Australia – Section 19;
Brazil – Section 20;
China – Section 21;
Japan – Section 22;
Philippines – Section 23;

2. What Is Personal and Non-Personal Data?

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.

“Non-Personal Data” means information that we have collected from you, which is not Personal Data, i.e. cannot be used by us to identify you.

3. Which Data Does RSI Collect and Use At Which Stage?

3.1. Use of Our Website

3.1.1. General

If you access or use our Website we may collect the following Personal Data and Non-Personal Data:

Request (Name of the requested file)
Browser type/version (e.g.: Internet Explorer 11.0)
Browser language (e.g.: English)
Operating System (e.g.: Windows 7)
Resolution of the Browser window
Screen resolution
Javascript active
Java On /Off
Cookies On / Off
Color settings
Referral URL (the previously visited page)
Time of Access
Clicks

RSI also may maintain log files which contain IP addresses. An IP address is a numeric address that may be assigned to your computer by your Internet Service Provider and can, in certain circumstances, amount to Personal Data. In general, we use log files to monitor traffic on our Website, run diagnostics and to troubleshoot technical problems. In the event of user abuse of our Website, however, we may block certain IP addresses.

We use the information set out in this Section 3.1.1 to enable, operate and optimize your experience of the Game and RSI Services. The collection of the information set out in this Section 3.1.1 is mandatory. RSI is not able to properly provide you with the RSI Services without this basic information.

3.1.2. Cookies and Tracking Technologies

We may use various tracking technologies to automatically collect the types of information set out in Section 3.1.1 above, including:

Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use several types of cookies, including session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time and generally may be controlled through your browser settings.
Pixels (also known as web beacons), which are code embedded in a website or email that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website or email that contains a pixel, the pixel may permit us to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device.

For an exhaustive outline regarding RSI’s use of cookies, types of cookies, which exact cookies RSI stores and for how long as well as how you can opt out of the use of cookies please see our cookie policy here. Global Privacy Control signals are processed by Cookiebot; for more information, see Section 3.2.

3.2. Account Registration and Commercial Transaction

You will need to register for an RSI account in order to access and use some of the RSI Services (Account). If you register for an Account, in addition to the information we collect under Section 3.1 above we will also collect the following Personal Data:

Account ID
LogIn ID
Display name
Password
Email address
Community moniker
User handle
Referral Code (if any)
Birthday
Creation date

If you conduct and carry out commercial transactions such as the purchase of objects via any of the RSI Services, in addition to the Personal Data set out above, we may also collect the following Personal Data and Non-Personal Data:

First name
Last name
Billing address (including street, ZIP code, country)
Shipping address for physical goods (including street, ZIP code, country)
Telephone number
Date and data of transaction
Object acquired
Pledge value
Confirmation email address

We use this Personal Data and Non-Personal Data to:

fulfil our contractual obligations set forth in our Terms of Service, End User Licence Agreement (where applicable) and comply with applicable law;
track the transactions you have made via the RSI Services;
remember which products you have added to your basket;
provide customer service to you in relation to your use of the RSI Services, to deal with enquiries and complaints relating to the use of the RSI Services and to notify you about any changes to the services that we provide via the RSI Services;
send you reminder and verification notifications such as password reminders.
satisfy verification requirements for account actions or services that implicate account security, identity, or data privacy.

We are obliged by applicable law in some jurisdictions to identify our commercial customers for purposes of enabling our contractual relationships with them. We are also obliged by applicable law to collect and store detailed information regarding all commercial transactions, in particular for accounting and tax purposes.

The collection of the information set out in this Section 3.2 relating to your Account is mandatory and RSI cannot provide you with the RSI Services without this information. For legal reasons this information will be stored as long as your account remains open and as required to comply with regulatory and legal requirements.

3.3. Playing the Game

When you play the Game, in addition to the information we collect under Section 3.1 and 3.2 above we may also collect the following Personal Data and Non-Personal Data:

feature usage
game play statistics and scores (including game progress)
performance data of the game client (including use of CPU, GPU and memory)
user rankings
click paths
data that you may provide in surveys
your account preferences
online profiles

We use this information to fulfil our contractual obligations to you, to optimize game play, enhance your game experience, deliver dynamic content, updates, configuration and feature support, to enforce our rights and the rights of other users in case of suspicion of fraud, and to protect the platform’s integrity and security (see also Section 3.4 below).

If you participate in any competitions, any relevant information such as your results or ranking may be displayed with your community moniker and handle on the Website.

When the Game, or any element or module thereof, is updated or “patched,” our patch routine may check your computer to see that you have the most recent version of Game-specific files.

The collection of the information set out in this Section 3.3 is mandatory as we cannot operate, optimize and enhance the Game properly without collecting this information. If you do not agree with this data collection and storage, we will need to deactivate your account and access to the Game. For legal reasons this information will be stored as long as your account remains open and as required to comply with regulatory and legal requirements.

We may also use this information to produce aggregated usage analytics and product improvement insights as it’s in our legitimate interest to collect this information to improve understand how our services are used and can be improved.

3.4. Misuse and Anti-cheat

In addition to Sections 3.1 to 3.3, if we reasonably suspect that any of the RSI Services or your Account is being, or has been, misused, including without limitation, by virtue of any:

DoS attacks
hacking
cheating
fraud
distribution of spam and/or viruses
object farming
defamation, racism, hate speech etc.
other violations of our Terms of Service and End User Licence Agreement

RSI may collect further Personal Data and Non-Personal Data to verify or refute such suspicions of misuse of the game by using software that runs locally on your device while the game is running. This done solely for the purposes of detecting, preventing, investigating or responding to cheating, hacking, exploitation, tampering, malware, or any behaviour that:

undermines the intended operation of the Game or RSI Services;
compromises our users, systems or infrastructure; or
violates the End User Licence Agreement or the Terms of Service.

We collect this information to ensure that the Game and RSI services are used as intended in line with the terms of the End User Licence Agreement, Terms of Service and/or any acceptable use policy which may be in place from time to time.

We also use this information to comply with applicable law and enforce our rights under civil and penal law against the respective users. Therefore, the collection of the information set out in this Section 3.4 is mandatory. This information will be stored as long as your account remains open and as required to comply with regulatory and legal requirements.

3.5. Crash Reports, Customer Support

Where you contact Customer Support for any technical and commercial issues, we may collect, in addition to the data collected in Section 3.1 to 3.4 above, information you provide to us including:

crash reports
further machine specifications
screenshots
any other data you may choose to provide

The collection of the information set out in this Section 3.5 is not mandatory. However, we might not be able to provide you with the necessary support, run diagnostics, complete technical troubleshooting, fix bugs or handle the technical and commercial issues you have without this information. For legal reasons, this information will be stored as long as your account remains open and as required to comply with regulatory and legal requirements

3.6 Performance Marketing & Marketing Communications

Subject to your approval we will collect, transfer and process Personal Data and Non-Personal Data for performance marketing as follows:

RSI may receive advertising data from our performance marketing partners, including Google. This data may include include: campaign, ad group and click IDs, keywords and placements. For more information on Google’s Ad Privacy Policies see here.
To ensure RSI can report on the effectiveness of the advertising campaign RSI will pass conversion data to our performance marketing partners, including when you register a new account or complete a commercial transaction. Included in the conversion data is a timestamp, conversion ID, revenue, SKU/product, new game package flag, credit/cash flag. Advertising data (clicks and impressions) and conversion data is collected using cookies and (if applicable) Google sign-in data. For more information about how we use cookies and tracking technologies, please see our cookie policy [insert hyperlink].

We may also use the information collected under Sections 3.1 to 3.3 to provide marketing information and special offers for the Game through communications to you (e.g. by email). This use of the information collected under Sections 3.1 to 3.3 is not mandatory. You can opt-out of these marketing communications at any time here.

We maintain a presence on various social media platforms including Facebook, X, TikTok, Twitch, YouTube, and Instagram. We may use these services to interact with you and the general public. From time to time we hold or organize social media events or offers for users of social media. Participation in such events is optional and not required to enjoy the RSI Services. Where we hold events or share offers, your interactions with us or others on the relevant social media platform is subject to that specific platform’s privacy policy, terms of use and acceptable use policies. We have no control over how the information or data you share on these social media platforms is used.

If you choose to link your social media accounts with the RSI Websites or your Account, your Personal Data may be collected and transferred between them. We do not sell any personal data that you submit to the RSI Services to third party social media sites.

3.7 Voice over IP (VOIP), Face (Motion) over IP (FOIP)

The Game offers the features “Voice over Internet Protocol” (VOIP) and “Face over Internet Protocol” (FOIP). With VOIP you transmit your voice during gameplay within your group over the internet (group-based broadcast transmission). With FOIP you can record the motion of your face (not the likeness itself) with an appropriate face motion capture camera during gameplay. The face motion data (not the likeness itself) is transmitted through our servers to other players playing within your group. The face motion data is then rendered on the face of your avatar to the other players of the Game. As a result, you can communicate with your group completely via your avatar, not only using your voice but also using your facial expression.

You should be aware that VOIP and FOIP can be recorded and re-transmitted (e.g. via Twitch or other platforms) by the receiver of your data. RSI cannot control this use of your data by the receiver, or other platforms, and does not assume any responsibility of such use by other users on the RSI Services or other platforms. You should be aware of this possible further use of your data and act accordingly. We suggest that you do not disclose confidential or sensitive information via VOIP and FOIP as it might be spread to an undefined audience. The Rules of Conduct under Section. III of our Terms of Service apply here as well.

VOIP and FOIP are not required for play and it is not mandatory for you to share any of this data in order to participate in the RSI Services. You have to activate VOIP and FOIP and if you wish to use it you are able to turn it off at any time in the Game. We do not store the VOIP and/or FOIP data other than intermediate storage during transmission.

3.8 Eye Tracking, Tobii Partnership

The Game may offer the feature Eye Tracking. To use Eye Tracking you may have to acquire the hardware of Tobii Tech AB, Sweden (Tobii), see www.tobii.com. You will have to install the Tobii drivers and software on your computer to use Tobii’s hardware. For Tobii’s privacy policy see here: www.tobii.com/group/privacy-policy. RSI is not responsible for any use by you of the Tobii software or hardware. The use of your data by Tobii and the Tobii software are governed by and subject to Tobii’s policies, terms and practices.

The Game may include a link to Tobii’s website to acquire the necessary hardware or software. If you click this link Tobii will track sales through this link.

If you use the Tobii hardware and have the Tobii driver(s) installed and running, you may opt to activate the Eye Tracking feature in the Game. In that case, the Game will receive Eye Tracking data from the Tobii software. If you chose this option, you can interact with the Game through your eye/head movement, e.g. control the in-game camera.

Eye Tracking is not required for play and it is not mandatory for you to share any of this data in order to participate in the RSI Services. You have to activate Eye Tacking in the Game in order for it to collect and respond to your eye movements and you are able to turn it off at any time in the Game. If the Eye Tracking feature is activated, we will collect and store the Eye Tracking data as an intermediary to enable you to use this technology to interact with the Game and may store analytics data as set forth in Section 3.3.

3.9 Retention Periods

RSI stores your Personal Data and Non-Personal Data for as long as this is necessary for the provision of the RSI Services, including as required in accordance with contractual or statutory requirements . See also Section 3.1-3.6 for further reference. Some account actions or services which may impact account security or data privacy and may require a verification step; in such cases, the information is maintained for a duration as determined by statute for evidence of compliance and the resolution of disputes. Finally, retention periods may also arise in connection with record keeping for copyrights and other intellectual property.

4. Will RSI Share My Information with Third Parties?

RSI may share your Personal Data where it has a legal reason to do so. This could be your consent, but may not always be. RSI may share Personal Data with:

any of our affiliated companies, including Roberts Space Industries International, Ltd., Roberts Space Industries Germany GmbH, Cloud Imperium Games Ltd. f.k.a. Foundry 42 Ltd., Cloud Imperium Games, LLC and Cloud Imperium Games Texas, LLC (individually and collectively “CIG”).
third party service providers under our control (“Data Processors” under GDPR or “Service Providers” under CCPA) and monitoring where such disclosure is necessary or helpful to enable us to provide you with any of the RSI Services and such third parties are contractually bound to process your Personal Data and/or Non-Personal Data under at least as protective as those set forth in this Privacy Policy (provided that we may permit them to use information that does not identify you for any purpose except as prohibited by applicable law). This may include sharing or receiving data from advertisers and advertising partners where applicable (see Section 3.6 above for further information).
third party payment providers which are bound by strict privacy policies to carry out payment transactions with you.
any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under our Terms of Service (such as law enforcement authorities in case of fraud investigations).
any authority to which we are obliged by law to disclose your Personal Data and Non-Personal Data (e.g. tax authorities for commercial transactions).
in anticipation or consideration of the sale, investment in, or acquisition of our business, where such disclosure is necessary.
during the sale or acquisition of our business to ensure the continuation of our Services.
at your request to you or to a third party.

Notwithstanding the above, we may also share Non-Personal Data (except as prohibited by applicable law).

5. How Does RSI Protect Your Personal Data?

The security of your Personal Data is important to us. We have implemented physical, electronic and managerial procedures in order to help safeguard and prevent unauthorized access, use, alteration, modification and/or disclosure of your Personal Data. We follow applicable law to protect the Personal Data submitted to us, both during transmission and in storage.

The Personal Data that you provide to us will be collected and processed by us or by data processors appointed by us to undertake processing on our behalf. Your Personal Data will be stored on servers which may be owned by data processors under contractual control by us and/or CIG.

If you have any questions about security of your personal data, please contact us at privacy@cloudimperiumgames.com.

6. Data Transfer

Please be aware that information collected through the RSI Services may be transferred to, processed, stored, and used in the EU, the U.S. and other jurisdictions. Data protection laws in these jurisdictions may be different from those of your country of residence.

Where applicable, we will transfer your Personal Data to third countries subject to appropriate safeguards, such as standard contractual clauses.

7. Review, Correction of Your Information, Requesting Removal from Mailing Lists and Deactivating Your Account

You can correct, update, or delete your Account information at any time by logging on our Website and navigating to your Account settings. Should you be unable to log in your Account, please contact us at privacy@cloudimperiumgames.com. We will be happy to review, update or remove information as appropriate. If you wish to have your Account deactivated, please contact support@cloudimperiumgames.com. Please note that we will retain and use information where required as set out in Sections 3.1 to 3.7.

8. Public Information Including User Generated Content, Online Forums, Blogs and Profiles

You may choose to disclose information about yourself in the course of contributing user generated content to the Website or in public online chat rooms, blogs, message boards, user comments, user “profiles” for public view or in similar forums on our Website. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality there. Other users or parties not affiliated with and not controlled by RSI may collect, retain, or further disclose information that you post to these services. If you do not wish for this to occur, it is your responsibility not to volunteer or post such information to these services.

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 to send you unsolicited messages in breach of our Terms of Service or End User Licence Agreement. We are not responsible for the Personal Data you choose to submit in these forums.

If you post a video, image or photo on any of our Website for public view you should be aware that these may be viewed, collected, copied and/or used by other users without your consent. We are not responsible for the videos, images or photos that you choose to submit to the Website.

9. Third Party Sites.

Our Website may contain services which link to other websites such as Twitter, Facebook and YouTube. The fact that we link to a third party website is not an endorsement, authorization or representation of our affiliation with that third party website or the operator of that third party website. If you click on a link to a third party site, you will leave the RSI site you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your Personal Data by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as RSI. We encourage you to review the privacy policies of any third parties from whom you request services. If you visit a third party website that is linked to an RSI Service, you should consult that third party website’s privacy policy before providing any Personal Data.

We may receive some of the information that you submit to any third party website that you access from the RSI Services. Both we and the owner or operator of that third party website will be the data controller in respect of any such information.

10. Products/Services Offered In Partnership With Third Party(s)

Users may register for other products and/or services via the RSI Services. Certain products and/or services available via the RSI Services are provided to you in partnership with third party(s) and may require you to disclose Personal Data in order to register for and access such products and/or services. Such products and/or services shall identify the third party partners at the point of registration. If you elect to register for such products and/or services your Personal Data will be transferred to such third party(s) and will be subject to the privacy policy and practices of such third party(s). We are not responsible for the privacy practices and policies of such third party(s) and, therefore, you should review the privacy practices and policies of such third party(s) prior to providing your Personal Data in connection with such products and/or services.

11. Children

The RSI Services are intended for adult audiences and are not directed at children. We do not knowingly collect Personal Data from children or minors under 18. If you are a parent or guardian and believe we have collected Personal Data from a child or minor in violation of applicable law, contact us at privacy@cloudimperiumgames.com. We will remove the Personal Data in accordance with applicable law.

12. Contact Information

If you have questions or concerns regarding this Privacy Policy or the way your Personal Data is handled, you may contact us or our Data Protection Officer using the following contact information:

For residents of the United States of America:

Roberts Space Industries LLC

13420 Galleria Circle
Suite A-250
Bee Cave
TX 78738, USA

For residents of all other countries:

Roberts Space Industries International Limited

6 Goods Yard Street
Manchester M3 3BG
United Kingdom

Email: privacy@cloudimperiumgames.com (attn: Data Protection Officer)

End User Licence Agreement: https://robertsspaceindustries.com/en/eula

13. Additional Disclosures for Nevada Residents

We do not sell personal data as defined under Nevada law. If you are a Nevada consumer and wish to submit an opt-out request in the event we ever change our practices with respect to sales, please contact us as privacy@cloudimperiumgames.com.

14. Additional Disclosures for California Residents – Notice At Collection – Do Not Sell or Share My Personal Data

These additional disclosures apply only to California residents. The California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. and its amendments and implementing regulations, including the California Privacy Rights Act of 2020 (CCPA), provides additional rights to know, delete, opt-out, limit use of certain categories of statutorily sensitive personal data, and correct, and requires businesses collecting or disclosing personal data to provide notices and means to exercise rights.

14.1 Notice of Collection

In the past 12 months, we have collected the following categories of personal data enumerated in the CCPA:

Category of Information	Purposes	Retention Period
Identifiers name, email address, handles, online identifiers e.g. IP address	account security, competitions, event security, technical troubleshooting, website experience	Service provision; Intellectual Property; Transient
Customer Records phone number, billing address	account security, competitions, event security, delivery of ordered products and merchandise	Service provision; Transient
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	delivery of ordered products and merchandise, fulfilment of contractual rights and obligations, regulatory requirements (accounting, tax, financial), research and development (products, services, performance)	Service provision
Internet Activity local browsing history, search history, and interactions with website, email services, game	account and network security, competitions, fulfilment of contractual rights and obligations, game settings, configuration, preferences, performance marketing (cookie opt-outs), research and development (products, services, performance), service delivery, website experience	Service provision; Contractual lifetime; Intellectual Property;
Geolocation Data imprecise location via IP address	account and network security, research and development (products, services, performance), service delivery	Service provision; Contractual lifetime;
Inferences from the above, regarding predicted characteristics and preferences	account security, customer support, research and development (products, services, performance)	Service provision; Transient

The retention periods described above are:

Service Provision: As long as is necessary for the provision of services, including compliance with contractual, regulatory, or statutory requirements.
* Contractual lifetime*: As long as is necessary for the enforcement of contractual rights.
Intellectual Property: In usages involving intellectual property, as long as needed by relevant statute and regulations
Transient: Transient use: Some account actions or services implicate account security or data privacy and may require a verification step; in such cases, the information is maintained for a duration as determined by statute for evidence of compliance and the resolution of disputes.

We retain information as needed to comply with a legal or regulatory obligation. For example, including but not limited to keeping records of financial transactions and invoices for tax compliance, local content regulations or age verification requirements.

For further details on the categories of sources from which we collect personal data as well as our business purposes for processing personal data, please review Section 3 above. For further details on the categories of third parties with whom we share personal data, please review Section 4 above.

14.2 Right to Opt-Out of Sales and Sharing

You have the right to opt-out of the sharing of your personal data for cross-contextual behavioral advertising purposes and/or from the sale of your personal data for monetary or other valuable consideration. Our use of behavioral advertising services may constitute sharing of your personal data with our advertising partners from which you have the right to opt-out under the CCPA. The categories of personal data shared include Identifiers and Internet Activity as described in the CCPA. You can manage your marketing and advertising opt-in and opt-out preferences at any time using the Cookiebot tool here. Your request to opt-out will apply only to the browser and the device from which you submit the request. We do not otherwise “share” or “sell” personal data as defined by the CCPA. For more information about cookies and tracking please refer to our cookie policy [Link].

We do not use or disclose sensitive personal data (as that term is defined under CCPA) for purposes that California residents have a right to limit under the CCPA.

14.3 Right to Know, Correct, and Delete

You have the right to ask us to correct inaccurate personal data that we have about you and the right to delete the personal data we have collected from you. You also have the right to know certain details about our data practices in the past 12 months. In connection with the right to know, you may request the following from us:

The categories of personal data we have collected about you
The categories of sources from which the personal data was collected
The categories of third parties to whom we disclose personal data
The business or commercial purpose for collecting, selling or sharing the personal data
The specific pieces of personal data we have collected about you

To exercise any of these rights, please submit a request to privacy@cloudimperiumgames.com or through your Account settings here. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

14.4 Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

14.5 Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any your rights under this Section.

14.6 Shine the Light

Customers who are residents of California may request:

a list of the categories of personal data disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and
a list of the categories of third parties to whom we disclosed such information.

To exercise a request, please write to us at privacy@cloudimperiumgames.com.or the postal address set out in Section 12 above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

15. Additional Disclosures for Texan Residents

If you are a resident in Texas, your personal data is handled in line with the Texas Data Privacy and Security Act (TDPSA). Under the TDPSA you have various consumer rights which are detailed in this section. You can exercise your rights at any time by submitting a request to us at privacy@cloudimperiumgames.com specifying which consumer rights you wish to exercise. You will not be discriminated against for exercising any of your rights contained in this section.

15.1 Right to be informed

We process these categories of personal data, for the following purposes:

Categories of Personal Data	Purposes
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address Inferences from the above, regarding predicted characteristics and preferences	account security
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address Internet Activity local browsing history, search history, and interactions with website, email services, game	competitions
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address	event security
Identifiers name, email address, handles, online identifiers e.g. IP address	technical troubleshooting
Identifiers name, email address, handles, online identifiers e.g. IP address	website experience
Customer Records phone number, billing address Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	delivery of ordered products and merchandise
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered Internet Activity local browsing history, search history, and interactions with website, email services, game	fulfilment of contractual rights and obligations
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	regulatory requirements (accounting, tax, financial)
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address Inferences from the above, regarding predicted characteristics and preferences	research and development (products, services, performance)
Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address	network security
Internet Activity local browsing history, search history, and interactions with website, email services, game	game settings, configuration, and preferences
marketing and cookies
website experience
Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address	service delivery
Inferences from the above, regarding predicted characteristics and preferences	customer support

We may share your personal data as described in Section 6 above.

15.2 Right to access: you have the right to request us to confirm whether we are processing and access your personal data.

15.3 Right to rectification: you have the right to request us to correct any inaccuracies relating to your personal data, considering the nature of personal data and purposes of processing.

15.4 Right to erasure: you have the right to request us to delete personal data we hold about you.

15.5 Right to object/ opt-out: you have the right to opt out from your personal data from being processed for the following purposes:

receiving targeted advertising;
the sale of your personal data; and
being subject to profiling that has a legal or similarly significant effect about you.

You can manage your marketing and advertising opt-in and opt-out preferences at any time using the Cookiebot tool here. Your request to opt-out will apply only to the browser and the device from which you submit the request. We do not otherwise “share” or “sell” personal data.

15.6 Right to data portability: you have the right to obtain a copy of the personal data we process about you in a portable, and to the extent technically feasible, readily useable format that allows you to transmit the data to another entity.

15.7 Right to not be subject to automated decision-making: you have the right to opt out from your personal data being used for the purposes of profiling in furtherance of a decision that produces a legal or similarly significant effect concerns you.

16. Additional Disclosures for Delawarean Residents

If you are a resident in Delaware, your personal data is used in line with the Delaware Personal Data Privacy Act (DPDPA). Under the DPDPA you have various consumer rights contained within this section, which you can exercise by contacting us at privacy@cloudimperiumgames.com.

16.1 Right to be informed

We process these categories of personal data, for the following purposes:

Categories of Personal Data	Purposes
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address Inferences from the above, regarding predicted characteristics and preferences	account security
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address Internet Activity local browsing history, search history, and interactions with website, email services, game	competitions
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address	event security
Identifiers name, email address, handles, online identifiers e.g. IP address	technical troubleshooting
Identifiers name, email address, handles, online identifiers e.g. IP address	website experience
Customer Records phone number, billing address Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	delivery of ordered products and merchandise
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered Internet Activity local browsing history, search history, and interactions with website, email services, game	fulfilment of contractual rights and obligations
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	regulatory requirements (accounting, tax, financial)
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address Inferences from the above, regarding predicted characteristics and preferences	research and development (products, services, performance)
Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address	network security
Internet Activity local browsing history, search history, and interactions with website, email services, game	game settings, configuration, and preferences
marketing and cookies
website experience
Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address	service delivery
Inferences from the above, regarding predicted characteristics and preferences	customer support

We may share your personal data in line with Section 6 above.

16.2 Right to receive confirmation of data processing: you have the right to request us to confirm whether we are processing your personal data, and what third parties we’ve disclosed this to.

16. 3 Right to access: you have the right to access your personal data.

16.4 Right to data portability: you have the right to obtain a copy of the personal data we process about you in a portable and, to the extent technically feasible, readily useable format.

16.5 Right to correction/ rectification: you have the right to request us to correct any inaccuracies relating to your personal data.

16.6 Right to deletion: you have the right to request us to delete personal data we hold about you.

16.7 Right to opt-out/ object: you have the right to opt out of the processing of your personal data for the purposes of:

targeted advertising;
the sale of your personal data except where exceptions apply; and
being subject to profiling that has a legal or similarly significant effect about you.

16.8 Right to withdraw consent: you have the right to revoke your consent, where provided. You can withdraw your consent by contacting us at privacy@cloudimperiumgames.com.

16.9 Right to not be subject to automated decision-making: you have the right to opt out from your personal data being used for the purposes of profiling in furtherance of a decision that produces a legal or similarly significant effect concerns you.

16.10 Right not to be subject to discrimination: your personal data will not be processed in a manner that violates the laws of Delaware and US federal laws that prohibit unlawful discrimination against consumers.

16.11 Right to file a complaint: you have the right to file a complaint, by contacting us at privacy@cloudimperiumgames.com.

17. Additional Disclosures for Canadian Residents

If you are resident in Canada, your Personal Data will be processed in accordance with the Personal Data Protection and Electronic Documents Act 2000 (PIPEDA). In addition, if applicable, the Quebec Act respecting the protection of personal data in the private sector (RLRQ chap. 39(1) provides you with the following additional rights:

Right to know, correct, and delete: you have the right to access your Personal Data. You also have the right to correct incomplete or inaccurate data we hold about you, or ask us to erase the Personal Data we hold about you. This request must be completed within 30 days. Should it not be granted, the decision will explain why it is such, the sections of the law it is based on and the time limit for exercising any remedies available. Access to personal data is free of charge except for a reasonable charge for transcription, reproduction or transmission of such information.
Right to portability: At your request, computerized personal information collected from you and not created or inferred using personal information concerning you, will be communicated in a structured, commonly used technological format.
Right to de-index: According to applicable law, the person to whom personal information relates may require us to cease disseminating that information or to de-index any hyperlink attached to his name that provides access to the information by a technological means, if the dissemination of the information contravenes the law or a court order.
Right to be informed of any decision based exclusively on an automated processing: Should we use personal information to render a decision based exclusively on an automated processing of such information, we will inform you accordingly not later than at the time we inform you of the decision. We must also inform you, at the latter’s request,
- of the personal information used to render the decision;
- of the reasons and the principal factors and parameters that led to the decision; and
- of your right to have the personal information used to render the decision corrected.

You are also given the opportunity to submit observations to a member of our personnel who is in a position to review the decision.

Right to complain: you have the right to lodge a complaint with our Privacy Officer and the relevant supervisory authority regarding the processing of your personal information, subject to the conditions set out in applicable law.
Handicapped person: If you are handicapped, reasonable accommodation will be provided on request to enable you to exercise the right of access provided for in this section.

Where consent for processing of Personal Data is required by PIPEDA or the Quebec Private Sector Act, this will either be presumed or implied, unless consent is expressly and specifically sought. You have the right to withdraw your consent at any time.

For more information, on those rights or to access information, please contact privacy@cloudimperiumgames.com.

18. Additional Disclosures for UK and EU Residents

These additional disclosures apply only to UK and EU residents. The General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR), provide you with additional rights, as further detailed in Sections 18.1 to 18.6 below.

18.1 Categories of personal data and retention periods

For details of the categories of Personal Data we collect and their respective retention periods, please refer to Section 3 above.

18.2 Legal basis for processing

In order to process your Personal Data lawfully, we must rely on a legal basis specified under the GDPR. The legal bases on which we rely are set out below:

Type of Personal Data	Purposes	Legal Basis
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address Inferences from the above, regarding predicted characteristics and preferences	account registration provide the services account sercurity	to perform our contractual obligations (Article 6(1)(b) GDPR)
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address Internet Activity local browsing history, search history, and interactions with website, email services, game	competitions	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Identifiers name, email address, handles, online identifiers e.g. IP address Customer Records phone number, billing address	event security	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Identifiers name, email address, handles, online identifiers e.g. IP address	technical troubleshooting	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Identifiers name, email address, handles, online identifiers e.g. IP address	website experience	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Customer Records phone number, billing address Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	delivery of ordered products and merchandise	to perform our contractual obligations (Article 6(1)(b) GDPR)
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered Internet Activity local browsing history, search history, and interactions with website, email services, game	fulfilment of contractual rights and obligations	to perform our contractual obligations (Article 6(1)(b) GDPR)
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered	regulatory requirements (accounting, tax, financial)	to comply with our legal obligations (Article 6(1)(c) GDPR)
Commercial/Transactions Information invoices, records of products or services ordered, obtained, or considered Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address Inferences from the above, regarding predicted characteristics and preferences	research and development (products, services, performance)	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address	network security	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Internet Activity local browsing history, search history, and interactions with website, email services, game	game settings, configuration, and preferences	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
marketing and cookies	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR) with your consent (Article 6(1)(a) GDPR)
website experience	because it is in our legitimate interests to do so (Article 6(1)(f) GDPR)
Internet Activity local browsing history, search history, and interactions with website, email services, game Geolocation Data imprecise location via IP address	service delivery	to perform our contractual obligations (Article 6(1)(b) GDPR)
Inferences from the above, regarding predicted characteristics and preferences	customer support	to perform our contractual obligations (Article 6(1)(b) GDPR)
Biometric data contained within VOIP and FOIP	To enable VOIP and FOIP	with your consent (Article 9(2)(a) GDPR)

18.3 Rights of data subjects

As mentioned in Sections above, as an EU or UK resident you have additional rights under the GDPR and UK GDPR. These are:

Right to know, correct, and delete: you have the right to access your Personal Data, known as a ‘subject access request’. You also have the right to correct incomplete or inaccurate data we hold about you, or ask us to erase the Personal Data we hold about you,
Right to object / opt-out: you may object to how we are using your Personal Data (including objecting to decisions made solely based on automated processing) and withdraw your consent to us handling your Personal Data.
Right to withdraw consent: where we rely on your consent for the processing of your Personal Data you may withdraw your consent at any time.
Right to lodge a complaint: you have the right to lodge a complaint with us or the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales. If you are based in the EU, you can find your relevant supervisory authority here.

To exercise any of these rights, please submit a request to privacy@cloudimperiumgames.com or through your Account settings here. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

18.4 Data storage

We store your data on third party servers which are based both in the UK and outside of the UK. When working with third parties we may need to transfer your Personal Data outside of the UK and / or EU, as per Section 18.5 below.

18.5 Transfers outside of the UK and EU

As in Section 6 above, it may sometimes be necessary for us to transfer your personal data to third countries. When transferring Personal Data outside of the UK and EU to third countries the relevant safeguards are the EU SCCs and UK Addendum.

18.6 EU Representative

RSI’s EU Representative is:

Robert Space Industries Germany GmbH

Tower One, Brüsseler Str. 1-3. 60327 Frankfurt am Main, Germany

If you would like to contact them, please email them at privacy@cloudimperiumgames.com marked “Attn: EU Representative”.

19. Additional Disclosures for Australian Residents

If you are a resident in Australia, your personal data will be processed in accordance with the Privacy Act 1988 (Cth) No. 119 1988 (as amended), Australian Privacy Principles (APP), the Privacy Regulations 2013, The Competition and Consume Act 2010 (Cth), and the CDR Privacy Safeguard Guidelines. Under these laws you have the following rights:

Right to be informed how your personal data is processed;
Right to access: you have the right to request a copy of the personal data we hold about you;
Right to correction/ rectification: you have the right to seek correction of the personal data we hold about you, and to notify of this correction any third parties to whom we provided your personal data;
Right to deletion: we will delete or de-identify your personal data once is has been used for the purposes of collection and is no longer required by law to be kept in an identifiable form;
Right to withdraw consent: for any consent provided, you have the right to withdraw your consent any time;
Right to file a complaint: You have the right to file a complaint about how we process your personal data by contacting us at privacy@cloudimperiumgames.com.

20. Additional Disclosures for Brazilian Residents

If you are a resident of Brazil, your personal data will be processed in line with the General Personal Data Protection Law (as amended). Under this law, Brazilian residents have various rights, which are detailed in this section, which can be exercised by contacting us at privacy@cloudimperiumgames.com.

Your rights:

Right to be informed: we process your personal data for the following purposes:
- to get access or use our website;
- to register for an account and, or carry out a commercial transaction;
- to play the game; and
- to respond provide you with customer support regarding a technical or commercial issue.

Right to receive confirmation of data processing: you have the right to request confirmation of the existence or access to your personal data held by us.

Right to access: you have the right to request information about your personal data that is being processed by us.

Right to data portability: you have the right to request the portability of your personal data in an interoperable format.

Right to deletion: you have the right to request the removal of your personal data which processed under the legal base of consent, unless otherwise exempt.

Right to opt-out/ object: you have the right to object to any processing activities founded on a legal basis other than consent.

Right to withdraw consent: you may revoke your consent at any time.

21. Additional Disclosures for Chinese residents

If you are an individual located in China, your personal data will be processed in line with the Personal Information Protection Law (PIPL), the Cybersecurity Law (CSL), and the Data Security Law (DSL). Under these laws, Chinese residents have various rights, which are detailed in this section. If you wish to exercise your rights, you can do so by contacting us at privacy@cloudimperiumgames.com.

Your rights:

Right to be informed and receive confirmation of processing: you have the right to know how your personal data is used.
Right to access and portability: you have the right to request a copy of your personal data and to enable portability of your data.
Right to correct and delete: you have the right to request us to correct any inaccuracies, or to delete your personal data.
Right to restrict processing and limit use, opt-out/ object and withdraw consent: you have the right to restrict or object to your personal data being used and withdraw your consent, where applicable.
Right not to be subject to automated decision-making: you have the right no to be subject to automated decision-making when the use of automated decision-making produces decisions with a major influence your rights and interests.
Right not to be subject to discrimination: you have the right to not be subject to discrimination, and we may not apply unreasonable differential treatment to you in terms of transaction prices and other transaction conditions.
Right to file a complaint: you have the right to file a complaint against any illegal personal data processing activities.

Your personal data is used for the purposes outlined in Section 3 of this Policy and retained in line with subsection 3.9.

22. Additional Disclosures for Japanese residents

These additional disclosures apply only to Japanese residents. The Act on the Protection of Personal Information (Act No57 of 2003 as amended) (APPI) and the Act on the Use of Numbers to Identify Specific Individual in the Administrative Procedures (act No27 of 2013 as amended) (My Number Act) are the key laws that apply when it comes to handling your personal data.

22.1 Personal information notice

Your personal data is only used for the purposes set out in Section 3. We do not use your information for profiling. Details of how we protect and keep your personal data secure are explained in Section 5.

22.2 Your rights

Under the APPI and My Number Act, you have the following rights:

To request us to disclose in writing what personal data we hold about you.
To request us to revise, correct, amend or delete your personal data.
To request the cessation of use of your personal data if used for a different purpose than those stated above.
To access a record of what third parties we transfer your personal data to.
To request us to stop using or transferring your personal data to third parties if the personal data is no longer needed and is reasonable to do so.

If you wish to find out more about how Cloud Imperium Games handles your personal data, exercise your rights, or to lodge a complaint, you can so by contacting us via email at privacy@cloudimperiumgames.com, or by writing to us at 6 Goods Yard Street, Manchester, M3 3BG, UK.

23. Additional Disclosures for Philippines Citizens and Residents

If you are a citizen or resident of Philippines, your personal data will be handled in accordance with the Republic Act No.10173 Data Privacy Act of 2012 (DPA 2012), and the Implementing Rules and Regulations of the Act (IRR). Under these laws, citizens and residents Philippines have various rights, which are detailed in this section. You can exercise your rights by contacting us at privacy@cloudimperiumgames.com.

Your rights:

Right to be informed and receive confirmation of processing: you have the right to know how your personal data is used.
Right to access and portability: you have the right to request a copy of your personal data in a format that allows you to further use it.
Right to correct and delete: you have the right to request us to correct any inaccuracies, or to delete your personal data.
Right to opt-out/ object and withdraw consent: you have the right to object to your personal data being used and withdraw your consent, where applicable.
Right to file a complaint: you have the right to file a complaint.

If you would like to find out more about what personal data we collect about you and what parties we share it with, please refer to Section 3 and Section 4 respectively of this Privacy Policy.