PRIVACY NOTICE
issued by Bossa Studios Limited
Last Updated: May 2023
INTRODUCTION
We are Bossa Studios Limited (Bossa, we, us and our). We are a company registered in England and Wales with company number 07375707. Our office is at c/o Saffery Champness LLP, 71 Queen Victoria Street, London EC4V 4BE, England. We are a BAFTA-winning independent games developer and publisher based in London. We make genre-defining games that champion innovation and originality, and our games are loved by players worldwide. This policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing our games and wider business (including but not limited to network play connectivity and interactivity, online websites and communities). This policy also provides contact details and important information about data protection rights. This policy was last updated June 2021. We will periodically update this policy so please check back for updates.
WHAT PERSONAL DATA DO WE COLLECT?
Players
We collect personal data directly from players via registration and gameplay. If you link your account to or access it via a third-party service (for example, Facebook, Xbox, Steam, PlayStation and Switch) we collect personal data from that service. The personal data we collect and generate relating to players includes
Username and account details
Game profile (including basic details, game progress and usage)
Game profile ID (a randomly generated identifier)
Analytics ID (used to track game usage)
Third-party ID (if you link your account to or access it via a service such as Facebook, Xbox, Steam, PlayStation to your account)
Device information (including ID, type, time zone setting and location, IP address)
Marketing and communications data (including preferences)
Website users
The websites we operate include the following (our websites)
The information we collect from individuals that visit our websites includes
IP address
Device information (including ID, type, browser type and version, plugins, operating system and platform, time zone setting and location, IP address)
Website usage
Personal data entered into webforms
Purchases and order history
Marketing and communications data (including preferences)
Cookie data (please see cookies section below)
People we work with
We collect personal data directly from individuals we work with and individuals we might work with (including job applicants). We collect personal data from their employers or the organisations they represent. We also collect personal data relating to people we work with from other organisations we work with (for example, industry conferences, gaming media, social media, platforms and stores).
The personal data we collect relating to people we work with includes
Name
Address
Contact details (including telephone and email)
Social media
Professional and employment details
Personal data in correspondence
HOW WE USE PERSONAL DATA
Players
We mainly use personal data relating to players to provide, develop and promote our games and wider business. More specifically, we use personal data relating to players to
Improve our games (including by providing personalised content, language, help and instructions)-
Allow players to participate in certain website features
Account verification and clearance
Direct marketing to let players know about relevant products and services
Provide customer service assistance
Administer surveys and opinion polls
Manage alpha, beta or early access tests (including collecting feedback)
Administer promotions for products, services, news and events
Better understand how our games are used (including checking traffic patterns and what types of content are most popular)
Receive and respond to correspondence
Detect and address hacking, cheating and other activities that harm the experience of our games
Display in-game profiles
Engage with players on third-party social networks (please check the privacy notices of social networks)
Display leader boards, nicknames and any clan/guild information
Detect and address security risks
Detect fraud and other unlawful activity
Exercise legal rights and comply with legal obligations
Website users
We use personal data relating to users of our websites mainly to provide, develop and promote our websites, games and wider business. More specifically, we use personal data relating to website users to
Provide customer service assistance
Better understand how our websites are used (including checking traffic patterns and what types of content are most popular)
Website analytics and improvements
Detect and address security risks
Detect fraud and other unlawful activity
Exercise legal rights and comply with legal obligations
People we work with
We use personal data relating to people we work with mainly to provide, develop and promote our games and wider business. More specifically, we use personal data relating to people we work with to
Manage services provided by our suppliers
Arrange meetings, calls and events
Manage business and professional relationships
Exercise legal rights and comply with legal obligations
OUR LEGAL GROUNDS TO USE PERSONAL DATA
Players
Contract
Our main legal ground for the use of personal data relating to a player is for the performance of our contract with them under a game’s terms of use.
Legitimate interests
We will also use personal data relating to players where necessary for the purposes of legitimate interests pursued by us and organisations we work with. However, we will only use personal data relating to players for the purposes of legitimate interests where players’ interests, rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with. Our legitimate interests include for the purpose of providing, developing and promoting our games and our wider business.
Consent
Our legal ground for sending players users direct marketing is consent. Consent for direct marketing may be withdrawn at any time.
Website users
Legitimate interests
We use personal data relating to website users where necessary for the purposes of legitimate interests pursued by us. Our legitimate interests include for the purpose of providing, developing and promoting our games and wider business. We will only use personal data relating to website users for the purposes of legitimate interests where website users’ interests, rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with.
Consent
Our legal ground for sending website users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.
People we work with
Contract
Where we have a contract in place with the people we work with, our legal ground for the use of personal data relating to such a person is for the performance of such contract.
Legitimate interests
We use personal data relating to people we work with where necessary for
the purposes of legitimate interests pursued by us. Our legitimate interests
include for the purpose of providing, developing and promoting our games and
wider business.
We will only use personal data relating to the people we work with for the
purposes of legitimate interests where their interests, rights and freedoms do
not override our legitimate interests.
AUTOMATED DECISION MAKING
We do not make any legally significant decisions about individuals based solely on automated decision-making.
SHARING PERSONAL DATA
Players
We share personal data relating to players with other players, our staff and the following types of service providers
Platforms
Distributors of our games
Payment processors
Marketing partners
Analytics service providers (see cookies section below)
IT providers
Group companies
Business partners
Professional service providers (for example, accountants and lawyers)
Website users
We share personal data relating to website users with our staff and the following types of service providers
Analytics service providers (see cookies section below)
Payment processors
IT providers
Marketing partners
Group companies
Professional service providers (for example, accountants and lawyers)
People we work with
We share personal data with our staff and the following types of service providers
Online stores
Payment processors
IT providers
Marketing partners
Group companies
Sister studios
Business partners
Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Bossa or our games. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
COOKIES AND SIMILAR TECHNOLOGIES
Essential cookies Our websites will not work properly without essential cookies. For example, we use cookies for security purposes. We also use a cookie from Typeform (attribution_user_id) to make our webforms work. Analytics cookies We use Google Analytics (_ga, _gat, _gid) to learn about how people use our website. For example, which pages users visit most often and where users encounter error messages.
CHILDREN
We do not knowingly collect or use any personal data relating to children under the age of 13.
INTERNATIONAL TRANSFERS
We routinely transfer personal data outside the UK. Where we transfer personal data outside the UK we ensure that appropriate safeguards or exemptions are in place or that the recipient complies with UK data protection laws.
DATA RETENTION
Players
We keep personal data relating to players for the period that the game is available to play. Once we make a game unavailable, we will delete all personal data relating to players of that game. We will also generally delete personal data relating to a player when we receive a specific request for erasure (see rights section below).
Website users
We keep personal data relating to website for as long as necessary for our games or wider business purposes.
People we work with
We keep personal data relating to website for as long as necessary for our games or wider business purposes. You can request we delete personal data using the details below.
RIGHTS
If we hold your personal data, you have the right to
Information about how we use personal data (which is what this notice is for)
Access to personal data
Object to the use of personal data (including the sale of personal data to other companies)
Erasure of personal data
Portability of personal data
Withdraw consent where our use of personal data is based on consent
Rectification of personal data
Restriction of personal data
Complain to your supervisory authority
Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant. The Information Commissioner’s Office provides more information about data protection rights - www.ico.org.uk. You will not be treated differently or discriminated against for exercising any of your rights
IF YOU DO NOT PROVIDE PERSONAL DATA
Where we need personal data for an agreement with you and you do not provide that personal data, we may not be able to perform our agreement. In this case, we may have to cancel your access to our games.
CONTACT INFORMATION
All questions, comments or enquiries should be directed to Bossa at feedback@bossagames.com. We will endeavour to respond to any query or questions within two business days.
© 2023 Bossa Studios Limited. All trade marks are the property of the relevant owners. All rights reserved.