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Privacy and Cookie Notice

Last updated November 2023


Introduction

What’s this notice about?

This Privacy Notice (the “Notice”) explains how we, Build A Rocket Boy Ltd. (also: “Build A Rocket Boy“, “BARB” or “we“), collect and use your personal data when providing and maintaining our website www.everywhere.game, as well as our platform “EVERYWHERE” and certain online features, online play connectivity and interactivity and other features relating to EVERYWHERE, to allow you to play, create and connect with others on our platform. In this Notice, our website and EVERYWHERE including all of its features and services are collectively referred to as the “Services”. This Notice also informs you about how we protect your personal data and the rights and options you have to control your data.

This Notice will give you information about:

We advise you to read this Notice carefully and to consult it on a regular basis when you use our Services, as it may be necessary for us to amend this Notice from time to time. If we want to make substantive changes to the way we process personal data, for example if we want to collect new types of personal data or process personal data for new purposes, we will take reasonable steps to inform you in advance.

Please note that this Notice specifically applies to our website www.everywhere.game and our platform EVERYWHERE. If you want to learn more about how we collect and process personal data when applying for a job at Build A Rocket Boy, please consult the candidate privacy notice on www.buildarocketboy.com.


What personal data we collect

When we talk about data or personal data in this Notice, we refer to all data that can be directly or indirectly traced back to you as an individual. Depending on how you use our Services, we collect and process data that you ask us to process or data that we otherwise collect. The categories of data we process are:

Player Account Data – which consists of data you provide and which we automatically collect when you create an account in EVERYWHERE:

  • Name, including your display name and login name
  • Email address, including your parent’s email address if you are under 18
  • Date of birth
  • Country
  • IP address
  • User ID
  • Logging and recovery data related to log in attempts and failures, and account suspensions and blocks
  • Data you voluntarily provide, including your (business) address, (business) phone number and gender

Gameplay Data – which consists of data we automatically collect throughout your use of our Services and during gameplay:

  • Statistical data based on your gameplay within EVERYWHERE, depending on your gameplay this can include statistical data related to avatar customization, game mode and play duration, vehicles and racing, shopping and entitlement, and player location
  • Country
  • IP address
  • Device and platform type
  • User ID

Technical Data – which consists of data we automatically collect throughout your use of our Services:

  • Device and network connection information when you access our website www.everywhere.game, including browser type and settings, access logs, device type and settings, system language, operating system, and other information provided by your browser, the use you make of our website www.everywhere.game (including which pages you visit, which links you click on, the previous websites you’ve come from and the time you spend on our website and how you interact with it)
  • Analytical data related to gameplay, including the time it takes for the game to load, game performance, player coordinates within the game, and user behavior data
  • Logging Information, including log in attempts, error messages, IP address, location data and troubleshooting data

Note: Some of this Technical Data is collected through cookies, pixels and other technologies (“Cookies”), for more information on Cookies please see section 5.

Transaction Data – which consists of data you share with us and which we automatically collect when you purchase in-game products or services:

  • Date and time of purchase
  • IP address
  • First and last name
  • User ID
  • Information on the product or service purchased, including in-game pricing

In-Game Social Data – which consists of data related to communications and interactions between players in EVERYWHERE:

  • Friends lists and connections within EVERYWHERE
  • Text chat
  • Language preferences
  • Logging data related to account suspension or blocks

Customer Support Data – which consists of data which is required to provide you with customer support including through Discord and our presskit Enquiry Channel:

  • EVERYWHERE Username and user ID
  • Discord Username and other identifiers
  • Contact information, including your name and date of birth
  • Game chat and (Discord) support chat history
  • Logging data related to account suspension or blocks
  • Purchase data, including delivery and payment details
  • Account verification data, including multi-factor authentication data
  • Information related to accounts you have linked to EVERYWHERE, such as any social media accounts
  • Information you voluntarily provide us, for example your gender and feedback

Marketing Data – which consists of data which is provided by you to us for the purpose of sending marketing materials about our products and services:

  • Name
  • Email address
  • Social Media Profile(s)
  • Language preferences
  • Marketing preferences
  • Information collected and clearly identifiable to you at the point of your signing up to our marketing communications

Why we process your personal data

Purpose of processingCategories of personal dataCorresponding legal basis
Creating and managing your accountPlayer Account DataThis is necessary for us to fulfil our contract with you to create and manage your EVERYWHERE account
Developing and improving our ServicesTechnical Data, Gameplay DataIt is our legitimate business interest to develop and improve the delivery of our Services (including by understanding how you use the services) and to develop new services or products
Processing and managing your in-game purchase orders, in-game payments and entitlementsTransaction DataThis is necessary for us to fulfill our contract with you when you purchase our in-game products or services, including any entitlements you may receive.
To improve gameplay and your in-game experiencesAccount Data, Technical Data , Gameplay DataIt is our legitimate business interest to develop and improve its Services and gameplay
To provide you with and to manage your social interactions with other players within EVERYWHEREIn-Game Social DataWe process this data only when you request or perform such social interactions within EVERYWHERE and with your consent where required by applicable law
To provide you with a personalized and tailored game experience, including providing you with recommendations we think you’ll likeAccount Data, Gameplay Data, In-Game Social DataIt is our legitimate business interest to provide you with a tailored and personal gameplay experience, including providing you with recommendations we think you’ll like. Where required by applicable laws we will ask your consent
To provide you with helpful and seamless customer support experienceCustomer Support DataIt is our legitimate business interest to provide you with such a helpful and seamless customer support experience
To perform ‘know your client’ processesPlayer Account DataIt is in our legitimate interest to perform any ‘know your client’ processes to protect our business and Services
To protect establish, exercise or defend our and third parties’ rights, to defend against lawsuits and to detect and prevent crime and fraud within our ServicesPlayer Account Data, Gameplay Data, Technical Data, Transaction Data, In-Game Social Data, Customer Support DataIt is our legitimate business interest to protect its and third parties’ rights and to detect, investigate and prevent crime and fraud within or related to its Services, and the products and services of third parties to the extent permitted by law
To comply with our legal obligations, for instance our fiscal, bookkeeping and tax obligationsPlayer Account Data, Gameplay Data, Technical Data, Transaction Data, In-Game Social Data, Customer Support DataThis processing is necessary for our compliance with our legal obligations
Providing you with marketing materials for the promotion of Build A Rocket Boy and our products and services (including EVERYWHERE and MindsEye)Marketing DataIt is our legitimate business interest to market our activities and promote the success of our business, website(s) and services. Where required by applicable laws we will ask your consent

Children’s data

As per our Terms of Use, you can sign up to create an account if you are aged 13 or older. In order to use our Services for EVERYWHERE Alpha testing you have to be aged 18. We do not knowingly collect or process personal data within our Services from minors aged below 13. If we learn we have collected or received personal data from anyone under the age of 13, we will delete such data. Please contact us if you believe we might have collected or received data from minors under the age of 13. In addition, if you believe that a minor aged below 18 has access to or is playing EVERYWHERE, please contact us.


With which third parties we disclose personal data

Where relevant and necessary, we provide personal data to the following third parties:

  • Our group companies, to support us with processing your data for the purposes described in this Notice.
  • Our third-party service providers who support us with providing our Services and conducting our business. This means that your personal data is processed by third party vendors for website and application development, hosting and maintenance, data hosting and cloud (storage) services, backup services, data analysis, information security services, technical infrastructure services, customer support services, and marketing services.
  • Payment service providers for the purpose of processing payments of products or services within EVERYWHERE. These payment service providers use your payment data to process payments and may support us in detection and prevention of fraud.
  • Other parties with whom you choose to share your personal data with, depending on how you use our Services. For instance, social media platforms or other platforms (such as platforms used for customer support), or our business partners.
  • Public authorities, justice and law enforcement, fiscal authorities and other authorities assigned with investigative powers or public authority, to the extent we are legally required or have legitimate interests to do so.
  • With professional advisors, investigators, or credit reference agencies to the extent we are legally required or have legitimate interests to establish, exercise or defend our legal rights, or prevent or detect crime and fraud.
  • Third parties in connection with investments, reorganizations, restructurings, mergers, joint ventures or sale of shares or assets of BARB. It is a legitimate interest of us to enable such investments, reorganization, restructuring, merger or sale of our business in whole or in part.
  • We share press kit questions with The Honest Videogame Company Ltd who manages these communications on our behalf. For information on how they process your personal data, please see their privacy notice here: privacy – HONEST Video Game PR (honest-pr.com).

Cookies

We use Cookies to store and access data on your device to help our websites and apps work. This table explains their purpose, how long they last, and who else can access their data. Where necessary under applicable laws we obtain your consent for using these Cookies on your devices.

Cookie NameFunctionalityDurationPurpose
_under13Functional12 monthsApplied if a user enters an age under 13.
_evUserIdPerformance30 daysUnique ID used to track users between our websites (for example, from the EVERYWHERE website to account creation)
_barbTokenFunctional1 dayRemembers your login information for 24 hours
_barbUserIdPerformance30 daysUnique ID used to track users between our sites (for example, from the EVERYWHERE website to account creation)
Google AnalyticsTargeting90 daysTo track your behaviour on our website and improve the website’s performance.
Third-Party Marketing Cookies (Google, YouTube, Meta, Stackadapt, Reddit, TikTok and Twitter)TargetingUp to 12 monthsFor advertising purposes, including Google Ads (also for YouTube), Meta, Stackadapt, Reddit, TikTok and Twitter

How we transfer personal data internationally

We try to process your data within the EU and UK as much as possible. Sometimes it is necessary to transfer your data outside the EU or UK to a country which does not provide for the same level of data protection as is provided in the EU and the UK, for example, if a third-party service provider is located outside Europe. When we transfer your data outside the EU or UK, we ensure that this is done in accordance with applicable data protection laws and that the protection of your data is adequately safeguarded. We do this, for example, by concluding agreements with third party service providers based on the EU or UK standard contractual clauses for the international transfer of personal data. If you would like to receive more information on the safeguards taken, please contact us via privacy@buildarocketboy.com.


How we protect and store personal data

We have implemented physical, technical and organisational security measures to protect your personal data as required by applicable laws. These measures are aimed at ensuring the integrity and confidentiality of your personal data, for instance by ensuring that only authorised employees have access to your personal data, and to protect it against unlawful or unauthorized destruction, loss, alteration, use or disclosure, or access. We evaluate and update these measures on a regular basis. Please be aware that no information system can be 100% secure. This means that we cannot guarantee the absolute security or availability of your personal data.

We will retain your personal data for the duration of your interaction with our Services, unless a shorter retention period is required by applicable laws or the data is no longer necessary for the purposes for which the data was obtained. Once you no longer interact with our Services, we will retain your personal data for the period of time that enables us to:

  • fulfil our legal obligations, including legal retention periods;
  • initiate, investigate or defend against legal claims;
  • address your questions, requests or complaints; and
  • keep our records for analysis and audit purposes.

How to exercise your rights

We respect the rights granted to you under applicable data protection laws. Depending on your location and such applicable laws, these may include the right to access your personal data that we hold about you, to rectify or erase certain personal data, to restrict processing of your personal data and to get an electronic copy of your personal data for purposes of transmitting it to another company. These rights may be subject to certain limitations or restrictions as allowed or imposed by applicable laws, if this is the case we will let you know in our communications with you.

In addition, where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation and in accordance with the laws applicable to you. For instance, depending on your country this may include a right to opt-out to marketing communications via an opt-out link in the respective marketing message.

Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.

To exercise your rights, please use the options provided thereto in your EVERYWHERE account, or send an email to privacy@buildarocketboy.com.

You are also entitled to lodge a complaint with your local data protection authority.


Our Services may contain links to third party services or websites. We are not responsible for the way in which these third parties handle your personal data. We advise you to read the privacy notice of the third party when you make use of their service or visit their website in order to understand how this third party collects and uses your personal data.


Contact details

Build A Rocket Boy Ltd. 29 Constitution St, Leith, Edinburgh EH6 7BS United Kingdom Email: privacy@buildarocketboy.com


Additional U.S. state disclosures

This section provides information required under various U.S. state privacy laws about how we handle certain personal information we have collected, used, and disclosed and certain rights under applicable state law. These provisions supplement the other sections in this Notice.

Personal Data Collection, Use, Disclosure, and Retention

The chart below provides additional information about the personal data we collect and disclose. You can read more about the personal data we collect in the “What personal data we collect” section above, how we use personal data in the “Why we process your personal data” section above, and how we retain personal data in the “How we protect and store personal data” section above.

CategoryCategories of third parties to whom we disclosed personal data for business purposes
Identifiers (e.g., your name, username, IP address)Our external game backend support platform provider, to the extent you have chosen to share this information
Protected classification characteristics under California or federal law (e.g., your gender)Our external game backend support platform provider, to the extent you have chosen to share this information.
Commercial Information, such as your transaction historyOur external payment service provider if you have chosen to share that information.
Internet or other similar network activity (e.g., information about your interaction with EVERYWHERE)Our cloud service provider.
Geolocation data (e.g., your country)Both our cloud service provider and our external game support platform.
Potentially Sensitive Information (e.g., your account log-in information and bank account details)Our external payment service provider if you have chosen to share that information.

Certain data collection and processing on our Services may be considered “targeted advertising,” a “sale,” or “sharing” for cross-context behavioral advertising under applicable state law. As defined by California law, we “sold” or “shared” identifiers, internet or similar network activity, and geolocation data with our third-party marketing partners to provide you with more relevant advertising. We do not “sell” or “share” the personal information of known minors.

Please note that we use and disclose sensitive personal data only for purposes expressly permitted under California law.

Your Privacy Rights

To the extent provided for by law and subject to applicable exceptions, individuals may have the following rights concerning their personal data:

  • The right to know information about our processing of your personal information, including the specific pieces of Personal Information that we have collected from you;
  • The right to request deletion of your personal information;
  • The right to correct your personal information; and
  • The right to opt out of “sales,” “sharing” for cross-contextual behavioral advertising, or targeted advertising; and
  • The right to be free from discrimination relating to the exercise of any of your privacy rights.

Exercising Your Rights

You may submit requests to know, delete, or correct by contacting us using the contact information provided above. To exercise your rights, please use the options provided thereto in your EVERYWHERE account or send an email to privacy@buildarocketboy.com. Please include the phrase “Personal Information Privacy Request” in the subject line, and specify the Service you are inquiring about, along with your name, address, and email address. To protect your personal data from unauthorized access, change, or deletion, we will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you to protect against fraudulent or spoofed requests.

To submit a request to opt out of “sales,” “sharing” for cross-contextual behavioral advertising, or targeted advertising, please opt out of such or use privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/.

Authorized Agents

Authorized agents wishing to exercise rights on behalf of an individual may use the submission method noted above. We will honor a request from an authorized agent provided that (i) the individual provides written authorization to the authorized agent to act on their behalf and we can verify their identity, and (ii) the agent submits proof of authorization.

Appeals

You may also have a right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please contact us via privacy@buildarocketboy.com and include the phrase “Personal Information Appeal Request” in the subject line.