Rebellion Group Privacy Policy (For console games) 9th January 2015 INTRODUCTION This privacy policy describes how Rebellion gathers and uses personal data. “Rebellion” is a shorthand name for the following UK based companies: Rebellion Interactive Limited, Rebellion Publishing Limited, and Rebellion Developments Limited (also referred to as “us” and “we” in this privacy policy). All of the personal data described below may be shared within this group of companies. This privacy policy is divided as follows: Part 1 describes the Rebellion ID system; Part 2 describes gameplay and other data provided during ordinary use of games; Part 3 describes information received from visitors to our website (including our cookie policy) and other personal data which is not listed in Part 1 or Part 2. Some of the terms of this privacy policy do not apply to all users of our games. For example, Part 1 (which describes the Rebellion ID system) will not apply to you if you do not participate in the Rebellion ID system. Other privacy policies may also apply to your data. For instance, if you play our game through a console, the console maker may also collect and use data and the console maker’s privacy policy will apply to this data. In addition, you may be able to adjust your privacy settings on the device on which you play your game. CHANGES TO THIS POLICY We may change this privacy policy from time to time. Changes will be displayed on our website and we will use reasonable efforts to communicate important changes to people who play our games. ANY QUESTIONS? If you have any questions about this privacy policy (or about how Rebellion uses your data) please email us at PART 1 – THE REBELLION ID SYSTEM Description. The Rebellion ID System is the system Rebellion uses to collect, store and use personal data of Rebellion customers using single account identifier (called the Rebellion ID) which is not tied to any particular product or platform. The Data We Collect. With the Rebellion ID System, we collect the following data: 1. Information you give us. Any contact details you provide to us, including when registering with us, or when completing an online survey. This may include your name, email address, postal address, Facebook page, Twitter ID, telephone number. 2. Information your device gives us. Data which we receive from your device when you use a Rebellion product, and which may be linked to your account information. This includes records of login sessions, 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. 3. Historical information. 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 use the data we collect through the Rebellion ID System for the following purposes: 1. To manage your orders, including by providing access to digital items you have paid for, and providing support if there are problems. 2. To keep records of our business for administration, accounting and tax purposes. 3. To customise individual user experiences based on previous interactions with Rebellion, including previous purchases. 4. To tell you about other Rebellion’s goods and services which we think might be of interest to you, 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, and you can opt out of these by contacting us as described below. Examples. We may: (a) Send you regular or one-off emails about our goods and services. We may use delivery services like Mailchimp and Sendgrid to do this. (b) Use “retargeted” web and social media advertisements. This means that we provide your personal data, e.g. an email address, to a social media site like Twitter and Facebook, so that they can show you adverts for our goods and services on their platform. We do not see your data on the social media site. (c) Use “look-a-like” audiences. This means that we provide your personal data, e.g. an email address, to a social media site like Twitter and Facebook, and they show adverts for our goods and services to other people who may have similar interests (or be similar in some other way) to you. Again, we do not see your data on the social media site. These systems may use or refer to the following information (including in order to target advertisements and messages): 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. We do not provide your data to other companies so that they can promote goods and services which are not from Rebellion. PART 2 – ANALYTICS Description. “Analytics” means data which is provided to us by your device when you use a Rebellion product or service, which we usually combine with similar data from other players in order to improve our products and services, or to help us to understand more about our customers. The Data We Collect. 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: 1. Your IP address (which may also tell us the country or region in which you are located). 2. Your account ID on the particular console platform you are using. 3. Your device ID. 4. Your Rebellion ID. 5. Information about specific times when you use our products or services. For example, if you play a Rebellion game, this information can include specific events and the times at which they occurred. Some examples of the data collected would include the following: (a) that you pressed a particular button; (b) that your in-game character was killed at a particular location while holding a particular weapon; (c) how long it took for the game or server to find you a game when matchmaking; (d) that you joined a particular lobby; and (e) 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. How we use this data. We use Analytics data for the following purposes: 1. 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”). 2. To improve our products and services, including by identifying problems or bugs. 3. To verify the location of users of pre-release versions of our products (e.g. “Beta” versions) and to understand the countries in which the users of our products and services are located. In most of these cases, your Analytics data is added to the Analytics data of other people so that we can study how the people who use our products and services act as a group. However, in some cases it may be helpful for our bug fixing people to be able to use specific Analytics data when investigating or fixing a bug that you or another specific user has reported to us. PART 3 – COOKIES AND OTHER DATA 1. Cookies. Visitors to our websites (including the Rebellion and 2000AD websites) and online platforms may be tracked by cookies as follows: (a) “First party” cookies are used to personalise your experience when you return to the website (or visit another Rebellion website). These cookies may allow features such as auto-login, welcome messages, pop ups or other targeted content like banners. (b) “Third party” cookies are set by other companies (rather than Rebellion companies). These include cookies which are set if you click a “Facebook” like logo on one of our websites. We do not set this cookie, and the use of this cookie will often be covered by the cookie and privacy policies of the company which provided it. These cookies are often used to show targeted advertisements to you when you are visiting other sites or social media. Some of these cookies can be associated with specific behaviour such as putting a product in a basket, but not buying it, which may allow other companies to show you adverts for that product or similar products. You can adjust your browser settings to deal with cookies as you prefer, and you can delete cookies from your computer, although this might affect your experience of using our websites. 2. Marketing emails. We maintain a number of different mailing lists, including lists relating to 2000AD, Solaris and Abaddon, the Dredd sequel campaign and 2000AD Advance Press Previews. The data in these mailing lists (including email addresses and other data) is voluntarily provided by to us or directly to our mailing platform (such as Mailchimp), usually through an online sign-up form but sometimes through postcards or fliers which have been filled in at public or trade events. The data and the use we make of it depends on the list but usually includes email addresses, region and preferred products or consoles. We also gather the contact and other details of people who buy products or services on the Rebellion Gamestore when they provide their initial registration information, and we add their contact information to our marketing mailing list unless they opted out at the time of registration. We use this data to send marketing emails to the people who provided this data to us, including via platforms like Mailchimp. These emails may be regular or irregular, and may be in the form of newsletters. We do not provide this data to companies outside of the Rebellion group, or use these lists to market the products or services of companies outside of the Rebellion group. You can opt out of these lists at any time by contacting us as specified below. 3. Other data. We also hold additional personal data which is provided to us in the course of our business, including data of purchasers which was provided before we introduced the Rebellion ID system. In general, this data is used in the same way as the Rebellion ID data described in Part 1 above. CONTACTING US If you have any questions about this privacy policy, or if you would like to contact us about your personal data, please do so as follows: