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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)

www.bossagames.com

www.bossapresents.com

www.worldsadrift.com

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

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.