Privacy and Data Policy issued by Bossa Studios Limited

Last Updated: May 2018

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed and/or published by Bossa Studios Limited. (“Bossa” / “we” / “us”). Our office is at Zetland House, Unit E 2nd Floor, 5-25 Scrutton Street, London EC2A 4HJ, England.

We are a company registered in England, with company number 07375707.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games, our websites including without limitation, bossastudios.com, worldsadrift.com, iambreadgame.com, and surgeonsim.com (“Website”) and any of our online communities (“Communities”). Together the Game(s), the Website and Communities are referred to herein as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at feedback@bossastudios.com

We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

· What information we may collect about you;
· How we will use information we collect about you;
· Whether we will disclose your details to anyone else; and
· Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy should be read in conjunction with, our terms of use applicable to the Game, Website or Community located here: http://www.bossastudios.com/terms- condition.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Game or Community.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information, which may include your personal data.

Information provided by you when using an Online Service
(“Submitted Information”)

We will collect personal information from you when you use our Online Service or when you contact us for support:

This may include:

· Your name;
· Your address, telephone number and email address; and
· Your Steam ID and Steam profile/display name.

Information about your gaming and activity
(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:
· your IP address and MAC address;
· device information (e.g. device identifier and browser)
· game results, progress and timings; and
· page usage (e.g. buttons clicked, screens viewed).

This also includes the use of ‘cookies’ more details of which can below

“Cookies”

A cookie is a text file placed onto your device when you access the Online Services or Website. We use cookies and other online tracking devices such as web beacons, and flash object storage to deliver, improve and monitor our Online Servcies, including in the following ways

PHPSESSID Unique token, sessional, allows Shopify to store information about your session (referrer, landing page, etc).

wp-settings Used to identify site settings.

wp-settings-time Used to identify site settings.

wpe-auth After log in this identifies your user account.

wordpress_logged_in_{HASH} After log in this identifies your user account.

comment_author_{HASH} When you submit a comment we store this information to populate this field for your next visit.

comment_author_email_{HASH} When you submit a comment we store this information to populate this field for your next visit.

comment_author_url_{HASH} When you submit a comment we store this information to populate this field for your next visit.

Information about you collected from third parties
(“Content Information”)

We may collect information which you make available to us via your social media profiles, including your Steam account, your Facebook account or other social media accounts.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Games to you

To enable operation of the Game

We will use information about you (including Submitted Information and Analytics) to deliver our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly.

In order to enable us to operate the Games in an effective manner e use a company called Playfab, Inc. to process your data and you can find out more about how Playfab processes personal information here.

· https://playfab.com/privacy/

To enable in Game purchases

If you make purchases through the Online Services, your order and Submitted Information may be processed so that you can access these features within the Games. We use a company called Xsolla (USA), Inc. to process your data and you can find out more about how Xsolla processes personal information here:

· https://xsolla.com/privacypolicy/

To provide a level playing field

We use EasyAntiCheat (part of Kamu Ltd) to keep an eye on any cheating or suspicious activities in our games so that you have the best experience when playing any one of our Games. EasyAntiCheat monitors the usage of our games on an anonymised basis through the use of Analytics and you can find out about their policies here:

· https://support.easyanticheat.net/kb/privacy/?lr=en-us

To provide the Communities

Certain Content Information and Submitted which you supply through our Online Service will be shared with other users of the Online Service. In some cases you may be able to select specific recipients (for example if you are sending a forum post, or a private message, to a particular forum or individual) then only those recipients will receive it, however in all other cases, your information may be made publically available.

To respond to your enquiries and requests for support

We may process Submitted Information and Content Information so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us. We use Zendesk to manage our customer support queries, and you can find out how Zendesk, Inc processes personal information here:  https://www.zendesk.com/company/customers-partners/#privacy-policy.

For advertising purposes

We may process Submitted Information, Analytics and Content Information to show you advertisements for third party services. Please note that we use third party providers of adverts and the adverts’ content is provided by these third parties and not Bossa. Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data.

We also use Analytics internally to improve the marketing that we provide to customers.

Our Games integrate with Kissmetrics and Flurry Analytics which we use to improve our marketing. Analytics data will be processed and tracked by those third party services, and you can find out more about the way they use this information at the following locations:

· https://www.kissmetrics.com/privacy/
· https://policies.yahoo.com/us/en/yahoo/privacy/index.htm

To keep you up to date

We use your Submitted Information to send you emails in order to keep you informed of news and products. To do these we use Sendy and Sendgrid. You can find out more about how they process personal data here:

· https://sendy.co/privacy-policy
· https://sendgrid.com/policies/privacy/

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Bossa, our customers or others.

Digital Content Stores: The Game is made available to download via Steam and we may disclose your personal information to Steam for the purposes of making the Game available and facilitating any in-Game payments made through Steam.

5. AUTOMATED DECISION MAKING

We use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

We process your personal information via automated decision-making methods in order to identify users who are cheating in the Game. Our automated decision-making methods are designed to detect cheating by looking for irregularities in game play.

In this scenario, the user will be informed of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Game. If this applies to you, please contact us at feedback@bossastudios.com.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

Where you have linked your Steam account to any of your social media accounts, you can unlink these at any time by adjusting your settings in Steam. You can also remove access in your social media settings. If you are using an iOS device, you can opt out of personalised adverts by visiting https://support.apple.com/en-gb/HT202074

We will obtain your consent to collect your information to be used for marketing purposes. If you prefer that we do not use your data in this way, let us know by writing to feedback@bossastudios.com or by checking boxes on the forms we use to collect your data.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay and within one month at the latest.

To make a request, please let our Data Protection Officer know via feedback@bossastudios.com

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

You can download a copy of your Game account information by following the instructions in your account settings.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing or delete your personal data if:
· you consented to our processing the personal data and have withdrawn that consent;
· we no longer need to process that personal data for the reason it was collected;
· we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Bossa or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
· the personal data was unlawfully processed;
· you need the personal data to be deleted in order to comply with legal obligations;
· the personal data is processed in relation to the offer of a service to a child.

You can delete your accounts by following the instructions in your account settings.

Obtain a machine-readable copy of your personal data, which you can use with another service provider

· If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
· If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

· If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
· If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

8. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

9. CHILDREN

We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at feedback@bossastudios.com.

10. SECURITY

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Online Services; any transmission is at your own risk

11. INTERNATIONAL DATA TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of the Service, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to Bossa at feedback@bossastudios.com. We will endeavour to respond to any query or questions within two business days.

© 2018 Bossa Studios Limited. All trade marks are the property of the relevant owners. All rights reserved.