Last updated 15th October 2020.
Rebellion Group Holdings Ltd and its subsidiaries (“us”, “our”, “we”, “Rebellion”) are committed to protecting and respecting your privacy.
This Policy covers our collection, processing and use of personal data when you use any of our Services or Websites.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:
- What is personal data and what do we collect
- How and why do we use/share your personal data
- For how long do we keep your personal data
- Your Right
- Contact Details
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide within our Services or on our Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you agree to share certain data with us, or where you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.
By visiting or otherwise using our Services or Websites, you are agreeing to the practices set out in this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using our Services and Websites.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let you know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.
Please note that our Services and Websites are not directed at children under the age of 13 (each a “Child” together “Children“) and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at firstname.lastname@example.org and request that we cease processing data about your Child
2. WHAT IS PERSONAL DATA AND WHAT DO WE COLLECT?
What is personal data?
Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.
By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Policy.
Data we collect from you when you use our Services
Part 1 – Analytics Data
“Analytics” means data which is provided to us by our game via your device when you use one of Rebellion’s Services, which we combine with similar data from other gamers in order to improve our products and services, or to help us to understand more about people who play our games.
What data do we collect for analytics?
We may collect some or all of the data described below. However, please note that the actual data which we collect may differ depending on the platform on which you use our product, and on the particular product you use:
- Your device ID (for mobile Apps or our websites). For PC or console games we may generate a unique ID for each user of that game which is game-specific and not related to any other identifier.
- The frequency and timing of purchases of Rebellion products, or the dates on which Rebellion products are first used.
- Information about your PC configuration or specification (which may include CPU speed, memory, graphics card / processor and operating system).
- Information about in-game events and how you used or purchased our products or services. For example, the data collected could include the following: (a) that your in-game character was killed at a particular location while holding a particular weapon; (b) how long it took for the game or server to find you a game when matchmaking; (c) that you joined a particular lobby; or (d) that you acquired a particular DLC pack.
You may be able to adjust the privacy settings on your device to change the Analytics data which we can obtain. In particular you will always be able to opt out of providing Analytics data to us through our PC and console games.
The majority of the data that we collect for analytics purposes is not Personal Data, as we are unable to use it to identify individual users. Depending on the Service, we may not provide functionality to enable you to prevent this non-personal data from being collected as much of it is essential in order to enable us to optimise and deliver the Services to users.
How we use this data.
We use Analytics data for the following purposes:
- To monitor how any online products or services or features are operating. We do this in “real time” (sometimes known as “telemetry”) and we also look back over Analytics data for past events (sometimes known as “analytics”).
- To improve our products and services, including by identifying problems or bugs and balancing servers, and better understanding the PC configurations and specifications used by our customers.
- To understand the countries or geographic regions in which the users of our products and services are located.
Part 2 – The Rebellion ID System
The Rebellion ID System is the system that the Rebellion Group uses to identify individual users across our various product and Service lines, which we do by collecting, storing and using various personal data of Rebellion customers using a single account identifier (called the “Rebellion ID”) which is not tied to any particular product or platform.
Creation of a Rebellion ID account can be done voluntarily, but may also be necessary where you purchase certain goods or services from us.
We require the creation of a Rebellion ID account where you purchase goods or services that necessitate us keeping a digital record of your licensed rights in respect of those goods or services. For example, where you purchase digital media from us, we require you to create a Rebellion ID so that you can log in to your Rebellion ID account and access that media across multiple devices (rather than tying that particular media to a single device)
Where users create a Rebellion ID account then we will collect and use their data in the ways set out below.
The Data We Collect where you create a Rebellion ID
With the Rebellion ID System, we collect the following data:
- Information you give us. Any contact details you provide to us, including when registering with us (by way of filling out the registration form), or when completing any online survey in which you declare your Rebellion ID. This may include your name, email address, postal address, Facebook page, Twitter ID, and telephone numbers.
- Information your device gives us. Data which we receive from your device when you use a Rebellion product while logged in with your Rebellion ID, and which may be linked to your account information. This may include records of login sessions, Advertiser ID, device name, location and operating systems and includes data about which game you play, on which platform, and for how long. It may also include information about the country in which you are located.
- Historical information and records of our dealings. This includes details of past orders you have placed and information about which digital products are available to you, and on which devices.
How we use this data.
We may use the data we collect through the Rebellion ID System for the following purposes:
- To manage your orders, including by providing access to digital items you have paid for, and providing support if there are problems.
- To provide rewards and incentives to longstanding and/or repeat purchasers of Rebellion goods and Services.
- To keep records of our business for administration, accounting and tax purposes, and to improve our business.
- To customise your individual user experiences based on previous interactions with Rebellion, including previous purchases.
- To tell you about other Rebellion’s goods and services which we think might be of interest to you (but only to the extent that the law permits, and/or using mediums which you specifically consent to), and to tell other people about Rebellion’s goods and services which we think may be of interest to them. Some examples of how we do this are described below. You can usually opt out of receiving marketing information like this at any time by adjusting your account settings on our website or on the relevant social media site. Marketing emails will also have the option to unsubscribe.
By way of example we may:
- Where we are lawfully permitted to do so (usually where we have received your specific consent) send you regular or one-off emails about our goods and services. We may use third party mailing services or our own systems to do this.
- Use “look-a-like” audiences. This means that we may provide your email address or cookie information to a social media site like Twitter or Facebook, in order for them to show adverts for our goods and services to other people who may have similar interests (or be similar in some other way) to you. The technical performance of this activity is governed by the relevant terms of those social media sites’ respective privacy policies.
- Where you provide your consent to receive the relevant cookies, use “retargeted” web and social media advertisements. This means that we may provide your email address or cookie information to social media sites such as Twitter and Facebook, so that they can show you adverts for our goods and services on their platform. To be clear, this process will not grant us any form of access to personal data that you may have provided to those social media sites.
Finally, our ad targeting systems (and those offered by third party service providers) may use or refer to the following information (including in order to target advertisements and messages) where you consent to provide them with the same: your age, the region in which you are located, the platforms on which you use Rebellion products, the Rebellion products you have licensed, the lifetime value of Rebellion products and services you have paid for your average order value, and the time which has passed since your last purchase or game registration. Further information about the data received by social media sites and how they use that data can be found on their websites.
Other Voluntary Provision of Data
Where you voluntarily supply your personal data to us outside of the channels described above, for example where you; use one of our Websites or Services to upload or send personal data (by filling out a form to describe a fault or bug, subscribe to a publication or newsletter, take part in a survey, post a comment, or engage in similar activities in which you volunteer data about yourself) we may collect, store and use the personal data that you disclose to us.
The personal data we collect from you may include your title, name, address, e-mail address, company, job title, birthday, and phone number, but will depend on precisely what details you volunteer to us as you interact with the Website.
Automated Collection of Data
We may use third party service providers to assist us with Analytics data for mobile apps and Websites only. These may include Google Analytics, Facebook and Adroll. This does not affect the nature of data collected, or how it is used, as described above.
The following are examples of data we may collect:
- information about your device, browser or operating system;
- your IP address;
- information about links that you click and pages you view on our Website
- length of visits to certain pages;
- subjects you viewed or searched for;
- page response times;
- records of download errors and/or broken links;
- page interaction information (such as details of your scrolling, clicks, and mouse-overs);
- methods used to browse away from the page; and
- the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).
We use the data described above for several different reasons. Firstly we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.
Third Party Resources
We also use the services of third parties to help us to collect various data about you and the way that you use the Website in order to enable us to better understand your interests – both so that we can service content to you that we think will be of interest to you, and so that we can ensure that you are shown adverts delivered by third parties which are more likely to be of interest to you.
For details of the cookies that we use on the Website, what those cookies do, and the privacy policies of the third parties which provide them (where relevant) please see our Cookies Policy.
Please note that, while you have the option to consent to specific individual cookies that, unless specifically set out in our Cookies Policy, we rely on our legitimate interests as our condition for processing your personal data on the basis set out in this section (specifically that we have a legitimate interest in optimising the Website content and ensuring that you are served with relevant commercial communications as you use them).
3. HOW AND WHY DO WE USE/SHARE YOUR PERSONAL DATA
Sharing your personal data
In addition to the uses of your Personal Data described above we may share it in the following ways:
- we may share your personal data with any member of the Rebellion Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- with the providers of platforms that we use to distribute our Services to you (such as web stores and the service networks of console providers); and
- with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.
- with third party service providers that assist us in the improvement and optimisation of our Services by processing Analytics data;
We will not share your personal data with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.
We may also disclose your personal data to third parties in the following events:
- if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale;
- if the Rebellion Group or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.
4. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you sign up to receive e-mail marketing from us we will retain your e-mail address on file should you ever ‘opt-out’ of receiving e-mails from us. We will retain your e-mail address in this way in order to ensure that we continue to honour and respect that opt-out request.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.
Rebellion may store your personal data on secure servers either on our premises or in secure third party data centres.
Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about how the mechanism via which your personal data is transferred, please contact email@example.com
If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6. YOUR RIGHTS
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request“).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at firstname.lastname@example.org and telling us which communications you would like us to stop sending you.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us at: