The data controller pursuant to the General Data Protection Directive (“GDPR”) in respect of any Personal Information that you submit to us via the RSI Services (or otherwise) is Robert Space Industries International Limited, a company registered in England and Wales (company number: 08882924) and located at Freedom House, Church Street, Wilmslow, Cheshire, SK9 1AX, United Kingdom (“RSI”, “we”, “us”, “our”). The Personal Information 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 Information?
“Personal Information” is information that we have collected from you that identifies you, or which, in conjunction with other information that is in our possession, or is likely to come into our possession, may be used by us to identify you.
“Non-Personal Information”, is information that we have collected from you which 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 Non-Personal Information:
- 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 Information. 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.
We may also store flash cookies, also known as “local shared objects,” on your Internet enabled device if the Website uses Adobe Flash. Flash cookies are small files similar to cookies and are used to remember the Website’s settings to personalize the look and feel of the Website. Flash cookies only collect data in the aggregate. Like normal cookies, Flash cookies are represented as small text files on your internet enabled device.
3.1.3. Analytic Metrics Tools And Other Technologies
Our website uses Google Analytics. To learn how Google uses your data and how you can opt out click here: https://www.google.com/policies/privacy/partners/. The collection of the information set forth in this Section 3.1.3 is not mandatory.
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 Information:
- Account ID
- LogIn ID
- Display name
- Email address
- Community moniker
- User handle
- Referral code (if any)
- Creation date
If you conduct and carry out commercial transactions via any of the RSI Services, in addition to the Personal Information set out above, we may also collect the following Personal Information and Non-Personal Information:
- 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 Information and Non-Personal Information to:
- fulfill our contractual obligations set forth in our Terms of Service and comply with applicable law
- track the purchases 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. 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 Information and Non-Personal Information:
- 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
then RSI may collect further Personal Information and Non-Personal Information 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 statues of limitations thereafter.
3.5 Crash Reports, Customer Support
Optionally you may chose 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 statues of limitations thereafter.
3.6 Marketing Information
Subject to your approval we may also use the information collected under Section 3.1 to 3.3 to provide marketing information and special offers for the Game to you. This use of the information collected under Sections 3.1 to 3.3 is not mandatory. You can opt-out of this use of your data at any time here.
4. Will RSI Share My Information With Third Parties?
RSI may share your Personal Information with:
- any of our affiliated companies including Roberts Space Industries, LLC, Foundry 42 Ltd., Cloud Imperium Games, LLC and Cloud Imperium Games Texas, LLC (individually and collectively “CIG”)
- third party payment providers which are bound by strict privacy policies to carry out payment transactions with you
- 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)
We will not disclose your Personal Information to anybody else without your explicit approval.
5. How Does RSI Protect Your Personal Information?
The security of your personal information is important to us. We follow the GDPR to protect the Personal Information submitted to us, both during transmission and in storage.
The Personal Information 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 pursuant to Art. 28 GDPR. 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 Information.
If you have any questions about security on our Website, please contact us at email@example.com.
6. Review, Correction Of Your Information, Requesting 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 firstname.lastname@example.org. We will be happy to review, update or remove information as appropriate. If you wish to have your account deactivated, please contact email@example.com.
7. 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 Information 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 Information 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.
8. Third Party Sites
We may receive some of the information that you submit to any third party website that you access from an advertisement contained on any of 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.
9. Products/Services Offered In Partnership With Third Party(s)
10. Contact Information
If you have questions or concerns regarding this statement, you may contact us using the following contact information:
Roberts Space Industries International Limited.
Terms of Service: www.robertsspaceindustries.com/tos