The data controller in respect of any Personal Data that you submit to us via the RSI Services (or otherwise) is Roberts Space Industries LLC, a company registered in Delaware, USA, with offices at 12322 Exposition Blvd., Los Angeles, CA 90064 (“RSI”, “we”, “us”, “our”). The Personal Data you submit to us via the RSI Services (or otherwise) will be processed by us or by data processors appointed by us to undertake processing on our behalf.
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
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
- Java On /Off
- Cookies On / Off
- Color settings
- Referral URL (the previously visited page)
- Time of Access
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 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 optimize your experience of the 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.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com
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
- Email address
- Community moniker
- User handle
- Referaal Code(if any)
- Creation date
If you conduct and carry out commercial transactions 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:
- fulfill our contractual obligations set forth in our Terms of Service 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.
We are obliged by applicable law 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, especially for accounting and tax purposes.
The collection of the information set out in this Section 3.2 is mandatory. RSI is prohibited by law from providing you with commercial services without collecting such information. For legal reasons this information will be stored as long as your account remains open and thereafter for the retention periods set forth by law for accounting and tax purposes.
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
If you participate in any competitions, the 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.
We use this information to fulfill our contractual obligations to you, to optimize game play, enhance your game experience and to enforce our rights and the rights of other users in case of suspicion of fraud (see also Sec. 3.4 below).
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 for the applicable statutes of limitations thereafter.
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
- distribution of spam and/or viruses
- gold farming
- defamation, racism, hate speech etc.
- other violations of our Terms of Service
RSI may collect further Personal Data and Non-Personal Data to verify or refute such suspicions within the limits of applicable law and taking into account your reasonable data protection interests. We will use this information to comply with applicable law and enforce our rights under civil and penal law against the respective users.
The collection of the information set out in this Section 3.4 is mandatory. We may not be able to enforce our rights without such information. For legal reasons this information will be stored as long as your account remains open and for the applicable statutes of limitations thereafter.
3.5. Crash Reports, Customer Support
Optionally you may choose to send crash reports or contact Customer Support for any technical and commercial issues.
In addition to the data collected in Sec. 3.1 to 3.4 above the data provided by you may include:
- crash reports
- further machine specifications
- 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 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 for the applicable statutes of limitations thereafter.
3.6 Performance Marketing & Marketing Communications
Subject to your approval we will collect, transfer and process Personal Information and Non-Personal Information for performance marketing as follows:
RSI will receive advertising data from our performance marketing partners, including Google. This data includes 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.
Conversion data is collected using cookies. Advertising data (clicks and impressions) is collected using cookies and (if applicable) Google signed-in data. For the retention period of the marketing cookies see Cookiebot here.
Data collection on performance marketing is not mandatory. You can opt-out of data collection using marketing cookies at any time using the Cookiebot tool here.
Subject to your approval 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.
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) by the receiver of your data. RSI cannot control this use of your data by the receiver and does not assume any responsibility of such use by other users. You should be aware of this possible further use of your data and act accordingly, e.g. 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 Sec. III of our Terms of Service apply here as well.
VOIP and FOIP are not mandatory. You have to activate VOIP and FOIP and 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 include a link to Tobii’s website to acquire the necessary hardware. If you click this link Tobii will track sales through this link.
If you use the Tobii hardware and have the Tobii driver 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 mandatory. You have to activate Eye Tacking in the Game 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 intermediately to interact with the Game and may store analytics data as set forth in Sec. 3.3.
3.8 Retention Periods
RSI stores your Personal Information and Non-Personal Information for as long as this is necessary for the provision of the RSI Services, including as required in accordance with contractual or statutory requirements (e.g. tax law, accounting law and guidelines or other commercial purposes such as invoices). See also Sec. 3.1-3.6 for further reference. Finally, retention periods may also arise in connection with copyrights and other intellectual property.
4. Will RSI Share My Information with Third Parties?
RSI may share your 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”). The legal basis under GDPR is Art. 6 (1) lit. f GDPR with having organizational and financial requirements within the group as legitimate interest.
- third party payment providers which are bound by strict privacy policies to carry out payment transactions with you. The legal basis under GDPR is Art. 6 (1) lit. b GDPR.
- any authority to which we are obliged by law to disclose your Personal Information and Non-Personal Information (e.g. tax authorities for commercial transactions). The legal basis under GDPR is art. 6 (1) lit. c GDPR.
- at your request or your direction.
Notwithstanding the above, we may 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.
Despite these measures, transmission via the internet is not completely secure and we cannot guarantee the security of your Personal Data provided through the internet.
If you have any questions about security on our Website, please contact us at firstname.lastname@example.org .
6. Data Transfer
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 email@example.com . We will be happy to review, update or remove information as appropriate. If you wish to have your account deactivated, please contact firstname.lastname@example.org . Please note that we will retain and use information 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.
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. 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.
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)
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 email@example.com . We will remove the Personal Data in accordance with applicable law.
12. Contact Information
If you have questions or concerns regarding this statement, you may contact us using the following contact information:
Roberts Space Industries LLC
12322 Exposition Blvd.
Data Protection Officer at firstname.lastname@example.org .
Terms of Service: www.robertsspaceindustries.com/tos
13. Additional Disclosures for Nevada Residents
We do not sell personal information 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 email@example.com
14. Additional Disclosures for California Residents
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information 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 information enumerated in the CCPA:
- Identifiers, including name, email address, and online identifiers (such as IP address).
- Customer records, including phone number and billing address.
- Commercial or transactions information, including records of products or services purchased, obtained, or considered.
- Internet activity, including browsing history, search history, and interactions with a website, email, or game.
- Geolocation data, such as imprecise location through an IP address.
- Inferences drawn from the above information about your predicted characteristics and preferences.
For further details on the categories of sources from which we collect personal information as well as our business purposes for processing personal information, please review Section 3 above. For further details on the categories of third parties with whom we share personal information, please review Section 4 above.
We do not generally sell information as the term “sell” is traditionally understood.
14.2 Right to Know and Delete
You have the right to delete the personal information we have collected from you and the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:
- The categories of personal information we have collected about you
- The categories of sources from which the personal information was collected
- The categories of personal information about you we disclosed for a business purpose or sold
- The business or commercial purpose for collecting or selling the personal information
- The specific pieces of personal information we have collected about you
To exercise any of these rights, please submit a request to firstname.lastname@example.org 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.
14.3 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.
14.4 Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
14.5 Shine the Light
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or 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.