Build A Rocket Boy Privacy Notice
This Privacy Notice (the “Notice”) explains how we, Build A Rocket Boy Ltd. (also: “Build A Rocket Boy”, “BARB”, “we“, “us” or “our”), a company registered in Scotland with company number SC537252 and registered office at 2 Ocean Drive, Leith, Edinburgh, Scotland, EH6 6JB, collect and process your Personal Data (defined below) when you access our websites, including any content, services, accounts, products, features, functionalities, software applications and programs, that are made available to you on or through our websites. Together we call these (including any updates, upgrades, patches or modifications that we make to any of these) the “Services”.
This Notice also explains how Build A Rocket Boy collects and processes your Personal Data if we make available to you the following software programs and applications - whether directly via our Services, or via third party platforms, such as, but not limited to: Steam, Epic Games Store, Xbox, PlayStation etc. (“Third Party Platform(s)”):
In this Notice, we call each of these a “Game” and together, the “Games”, and the terms “Game” and “Games” shall include any patches, updates, and downloadable content associated with these software programs and applications, any authorised software needed to operate and access them and any content, services, products, features and functionalities that we make available on or through any of the Games. For clarity, “Services” as used throughout this Notice shall include any such Games, unless otherwise expressly stated.
California Privacy Notice: California consumers can find specific disclosures, including “Notice at Collection” details, please see Section 13 below.
Updates to your Personal Data: It is important that the Personal Data we hold about you is accurate and current. Please keep us updated if your Personal Data changes during your relationship with us. You can do by emailing us at support@buildarocketboy.com to tell us about any updates.
Youth Privacy Notice: Please find a summary of this Privacy Notice, written for young people here (and available at https://www.buildarocketboy.com/youth-privacy-notice). Please note, the Youth Privacy Notice is not a substitute for this Privacy Notice.
1.1 Updates to this Privacy Notice:
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 material changes to the way we process your 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. If you continue to use our Services following such a change, then this means that you are deemed to accept such change.
1.2 Exclusions from this Privacy Notice:
Please note that this Notice specifically excludes information on how we collect and process Personal Data if you apply for a job at Build A Rocket Boy. Please consult the Candidate Privacy Notice available here (and at https://www.buildarocketboy.com/candidate-privacy-notice) for further information.
Furthermore, this Notice excludes information on how Playfusion Limited, a subsidiary of Build A Rocket Boy, collects and processes your Personal Data when you interact with the Playfusion Limited website available here (and at https://www.ascendant.com) and any games, offerings, services and features made available by Playfusion Limited. Please read Playfusion Ltd’s Privacy Policy here for more information (available at https://www.playfusion.com/privacy-policy).
When we talk about Personal Data in this Notice, we refer to all data that identifies you:
We use different methods to collect and process data from and about you, including, but not limited to:
3.1 Player Account Data - which consists of data you provide and which we automatically collect when you create a Build A Rocket Boy account (an “Account”) to access any of our Services:
3.2 Additional Personal Data we may collect
3.3 Gameplay Data – which consists of data we automatically collect throughout your use of our Services:
3.4 Technical Data – which consists of data we automatically collect throughout your use of our Services:
Note: Some of this Technical Data is collected through cookies, pixels and other technologies (“Cookies”). For more information on Cookies please see Section 8.
3.5 Transaction Data – which consists of data you share with us which are automatically collected when you purchase our products or Services or any entitlements to license our Games, including entitlements to license in-game products such as virtual currencies and virtual items:
Please note that your financial data, which includes your bank account and payment card details, will be collected and processed by an external payment service provider. We will not have access to, collect, use, store or transfer any financial data you provide to this external payment service provider.
3.6 In-Game Social Data – which consists of data related to communications and interactions between players. We will collect the data listed below only to the extent the relevant feature is available in the Game you are playing:
3.7 Customer Support Data – which consists of data which is required to provide you with customer support, including through Discord and our press kit Enquiry Channel:
3.8 Marketing Data – which consists of data which is provided by you to us for the purpose of us sending marketing materials about our products and Services. In some cases the data may be provided to us by a third party if you have consented (e.g. by selecting a tick box to confirm your consent) via a third party website or platform, to Build A Rocket Boy sending marketing to you:
Please note you can opt-out of receiving marketing communications from us at any time by contacting us at support@buildarocketboy.com or by clicking on the unsubscribe link in our marketing emails. The opt-out will not affect the lawfulness of processing that has taken place before the opt-out.
The legal basis for processing your Personal Data varies according to the type of information which is collected.
If you are a resident of the United Kingdom or the European Union, we rely on several legal bases to process information about you. We process information about you where we have your consent, a legitimate interest to do so, or a contractual obligation to do so. We typically rely on the following:
We have listed below the ways we may use and process your Personal Data, and which of the legal bases we rely on:
(a) Creating and managing your account: a. Categories of Personal Data i. Player Account Data b.Corresponding legal basis i. This is necessary for us to fulfil our contract with you to create and manage your Account
(b) Developing and improving our services: a.Categories of Personal Data i. Technical Data ii. Gameplay Data b. Corresponding legal basis: i. It 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
(c) Processing and managing your in-game purchase orders, in-game payments and entitlements: a. Categories of Personal Data i. Transaction Data b. Corresponding legal basis i. This is necessary for us to fulfil our contract with you when you purchase our products or Services, including any entitlements you may receive for access to a Game or to access to in-Game virtual currencies or virtual items
(d) To improve gameplay and your in-game experiences: a. Categories of Personal Data i. Account Data ii. Technical Data iii. Gameplay Data b. Corresponding legal basis i. It is our legitimate business interest to develop and improve our Services and gameplay
(e) To provide you with and to manage your social interactions with other players within our Games: a. Categories of Personal Data i. In-Game Social Data b. Corresponding legal basis i. We process this data only when you request or perform such social interactions within our Games (where the relevant Game functionality allows this) and with your consent where required by applicable law
(f) To provide you with a personalized and tailored game experience, including providing you with recommendations we think you’ll like: a. Categories of Personal Data i. Account Data ii. Gameplay Data iii. In-game Social Data b. Corresponding legal basis i. It 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 ii. Where required by applicable laws we will ask your consent
(g) To provide you with helpful and seamless customer support experience: a. Categories of Personal Data i. Customer Support Data b. Corresponding legal basis i. It is our legitimate business interest to provide you with such a helpful and seamless customer support experience
(h) To perform ‘know your client’ processing: a. Categories of Personal Data i. Player Account Data b. Corresponding legal basis i. It is in our legitimate interest to perform any ‘know your client’ processes to protect our business and Services
(i) To protect establish, exercise or defend our and third party partner’s rights, to defend against lawsuits and to detect and prevent crime and fraud within our Services: a. Categories of Personal Data i. Player Account Data ii. Gameplay Data iii. Technical Data iv. Transaction Data v. In-Game Social Data vi. Customer Support Data b. Corresponding legal basis i. It is our legitimate business interest to protect its and third party partner’s rights and to detect, investigate and prevent crime and fraud within or related to its Services, and the products and services of third party partner’s to the extent permitted by law
(j) To comply with our legal obligations, for instance our fiscal, bookkeeping and tax obligations: a. Categories of Personal Data i. Player Account Data ii. Gameplay Data iii. Technical Data iv. Transaction Data v. In-Game Social Data vi. Customer Support Data b. Corresponding legal basis i. This processing is necessary for our compliance with our legal obligations
(k) Providing you with marketing materials for the promotion of Build A Rocket Boy and our products and Services (including our Games): a. Categories of Personal Data i. Marketing Data b. Corresponding legal basis i. It is our legitimate business interest to market our activities and promote the success of our business, website(s), Services and Games. Where required by applicable laws we will ask for your consent.
As per our Terms of Use, if you are under 13 you may not create an Account or use our Services. Some parts of the Services and certain Games have age restrictions: you must only use the applicable part of the Services, and play the relevant Game, if you meet or are above the minimum age rating for such part of the Service or Game.
You can sign-up to create an Account if you are aged 13 or older, although you will require the permission of your Guardian if you are a Minor User (please see Sections 2 and 3 of the Terms of Use here, and available at https://www.buildarocketboy.com/terms-of-use).
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 16 has access to or is playing our Games, please contact us.
Please see a summary of the Privacy Notice, written for young people here (available at https://www.buildarocketboy.com/youth-privacy-notice). Please note, this is not a substitute for this Privacy Notice.
Where relevant and necessary, we may disclose the categories of Personal Data described above to the following third parties described below, for example to provide administrative, transactional, professional, and customer support:
All third party service providers are obliged to treat your Personal Data in accordance with the law. We only permit service providers to process your Personal Data for specified purposes in accordance with our instructions.
Your Personal Data will only be disclosed for the purposes identified in this Notice (as updated from time to time) unless a law or regulation specifically allows or requires otherwise.
Some of the data disclosures to these third parties may be considered a “sale” or “sharing” of Personal Data as defined under the laws of California and other U.S. states. Please see the “How do you exercise your rights?” and “California Privacy Notice and Rights” Sections below for more details.
Finally, we may disclose de-identified information in accordance with applicable law.
We, and our third-party analytics and advertising partners, use Cookies and similar technologies to store and access data on your device to help our websites and services work, and to deliver and tailor interest-based advertising. We and/or our partners also share the data we collect or infer with third parties for these purposes. You can adjust your browser settings to disable these Cookies at any point. Below we explain the Cookies’ 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.
Third party partner’s use of Cookies are subject to the third-party partner’s own privacy policy and not this Notice.
Below is a non-exhaustive list of Cookies we use:
(a) Cookie name: _under13 a. Functionality: Functional b. Duration: 12 months c. Purpose: Applied if a user enters an age under 13. (b) Cookie name: _evUserId a. Functionality: Performance b. Duration: 30 days c. Purpose: Unique ID used to track users between our websites (for example, from the Everywhere website to Account creation) (c) Cookie name: _barbToken a. Functionality: Functional b. Duration: 1 day c. Purpose: Remembers your login information for 24 hours
(d) Cookie name: _barbUserId a. Functionality: Performance b. Duration: 30 days c. Purpose: Unique ID used to track users between our sites (for example, from the Everywhere website to Account creation)
(e) Cookie name: Google Analytics a. Functionality: Targeting b. Duration: 90 days c. Purpose: To track your behaviour on our website and improve the website’s performance.
(f) Cookie name: Third-Party Marketing Cookies (Google, YouTube, Meta, Stackadapt, Reddit, TikTok and Twitter) a. Functionality: Targeting b. Duration: Up to 12 months c. Purpose: For advertising purposes, including Google Ads (https://policies.google.com/privacy) (also for YouTube), Meta (www.facebook.com/privacy/policy), Stackadapt (https://www.stackadapt.com/legal-document-centre/platform-and-services-privacy-policy), Reddit (https://www.reddit.com/policies/privacy-policy), TikTok (https://www.tiktok.com/legal/page/global/partner-privacy-policy/en) and Twitter (https://x.com/en/privacy)
9.1 Outside of the EU or UK
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 partner 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.
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:
We respect the rights granted to you under applicable data protection laws. These rights may be subject to certain limitations or restrictions as allowed or imposed by applicable laws.
Access, restriction, correction, portability, and erasure. 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.
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.
You can request the closure of your Account and the deletion of the associated Personal Data. You also have the right to request that your Personal Data no longer be used or not be deleted during the time we are processing your request.
Targeted advertising. To opt-out from or otherwise control targeted advertising, you can use the controls available through our website cookie banner to decline advertising-related cookies. These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take this action from those devices or browsers to ensure your choices apply to the data collected when you use them.
Data sales. Some privacy laws define “sale” broadly to include some of the disclosures described in Section 7, “Disclosure of Personal Data To Third Party Partners” above. Depending on your location and such applicable laws, you can opt-out from such data “sales” by accessing our “Do Not Sell or Share My Personal Information” link at the footer of our websites and located (available at here https://www.buildarocketboy.com/do-not-sell-or-share-my-personal-information).
Communications preferences. You can choose whether to receive promotional communications from us by email. If you receive promotional email from us and would like to stop, you can do so by following the directions in that email or by contacting us as described in the “Contact details”, Section 14 below. These choices do not apply to certain informational communications including surveys and essential or mandatory service communications.
Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, that may be contained in emails we send you and the automatic connection to the web servers that host those images.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way. We periodically review and update all privacy and security policies, in line with changes in Data Protection laws or when new technologies are introduced into our business.
To exercise your rights, please use the options provided thereto in your Account, or send an email to privacy@buildarocketboy.com. If you have any concerns about our use of your Personal Data, you can make a complaint to us at privacy@buildarocketboy.com.
You are also entitled to lodge a complaint with your local data protection authority.
For any other questions including if your question relates to the hacking of your Account or the use of our Services, please contact customer support at support@buildarocketboy.com. For questions relating to issues with online payments, please contact the Third Party Platform from which you purchased your entitlement to license the Game (and any virtual items or virtual currencies included in it).
11.1 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11.2 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will inform you of an extension period of up to 2 months. In this case, we will keep you informed on progress.
11.3 Authorized Agents
Authorised agents wishing to exercise rights on behalf of an individual may use the submission method noted above. We will honour a request from an authorised agent provided that (i) the individual provides written authorisation to the authorised agent to act on their behalf and we can verify their identity, and (ii) the agent submits proof of authorisation.
11.4 Appeals
You may also have a right to appeal a decision we make relating to requests to exercise your rights under applicable laws. To appeal a decision, please contact us via privacy@buildarocketboy.com and include the phrase “Personal Information Appeal Request” in the subject line.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data, and the applicable legal requirements. Details of any retention period is available upon request.
In some circumstances, we may aggregate and anonymise your Personal Data for research or statistical purposes, in which case we may use this anonymised information indefinitely without further notice to you. We may share this anonymised information with third party partners, such as but not limited Third Party Platforms.
12.1 Data Disposal
Once the data retention periods above expire, digital records are permanently destroyed or fully anonymised if retained for statistical or research purposes. In this case, all personal identifiers will be removed permanently so individuals cannot be identified.
If you are a California resident and the processing of Personal Data about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.
Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of Personal Data and sensitive Personal Data to be collected (see Section 3 above, “What Personal Data do we collect?”), the purposes for which such information is collected or used (see Section 4 above, “Why do we process Personal Data?”), whether such information is sold or shared (see Section 7 above, “Disclosure of Personal Data to Third Party Partners”), and how long such information is retained (see Section 12 above, “How long do we retain Personal Data?”).
Right to Know. You have a right to request that we disclose to you the Personal Data we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such Personal Data. Note that we have provided much of this information in this Privacy Notice. You may make such a “request to know” by emailing privacy@buildarocketboy.com or submitting a request through our webform , and select “Other” (available at https://support.buildarocketboy.com/hc/en-gb/requests/new).
Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate Personal Data and that we delete Personal Data under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, email privacy@buildarocketboy.com.
Right to Opt-Out / “Do Not Sell or Share My Personal Information”. You have a right to opt-out from future “sales” or “sharing” of Personal Data as those terms are defined by the CCPA.
Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data disclosures described in this privacy statement may be considered a “sale” or “sharing” under those definitions. In particular, we let advertising and analytics providers collect identifiers (IP addresses and cookie IDs), activity data (browsing and clicks), device data, and geolocation data through our Games and Third Party Platforms you may use when you access Services, but do not “sell” or “share” any other types of Personal Data. If you do not wish for us or our partners to “sell” or “share” Personal Data relating to your visits to our sites for advertising purposes, you can make your request by visiting our “Do Not Sell or Share My Personal Information” page here (available at https://www.buildarocketboy.com/do-not-sell-or-share-my-personal-information), using a Global Privacy Control, or emailing us at privacy@buildarocketboy.com. If you opt-out using these choices, we will not disclose or make available such Personal Data in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some Personal Data to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” Personal Data or stop all interest-based advertising.
We do not knowingly sell or share the Personal Data of minors under 16 years of age.
Right to Limit Use and Disclosure of Sensitive Personal Data. You have a right to limit our use of sensitive Personal Data for any purposes other than to provide the Services or Games you request or as otherwise permitted by law. Note that we do not use sensitive Personal Data for any such additional purposes.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide, correct, or delete specific pieces of Personal Data we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.
Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided Personal Data to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed Personal Data to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. You can also archive certain content (such as Arcs that you’ve created in EVERYWHERE) which removes it from being seen by others. You can also make a request that we remove content or information by sending a detailed description of the specific content or information you wish to have removed to privacy@buildarocketboy.com. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Full name of legal entity: Build A Rocket Boy Limited
Registered office address: 2 Ocean Drive, Leith, Edinburgh EH6 6JB, Scotland, United Kingdom
DPO email address: privacy@buildarocketboy.com
Name of appointed EU representative: Build A Rocket Boy Ireland Limited
Address of appointed EU representative: FAO Legal, Vistra Ireland, Block A, George's Quay Plaza, George's Quay, Dublin 2, Ireland
EU representative email address: privacy@buildarocketboy.com