We ask that you read this privacy policy carefully. This policy contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and how to contact us and the relevant data protection authority in the event you have a complaint.

This policy is divided into the following sections:

  • Who we are

  • Scope of this policy

  • Collection and use of your personal information

  • Our legal basis for processing your personal information

  • Who we share your personal information with

  • Whether personal information has to be provided by you, and if so why

  • Transfer of your personal information out of the United Kingdom

  • Your data protection rights

  • How to complain

  • Changes to this policy

  • How to contact us

  • Do you need extra help?

Who we are

We are Kinetic Games Limited and our company registered office is at Stag Gates House, 63/64 The Avenue, Southampton, Hampshire, United Kingdom, SO17 1XS. We are a video games developer and publisher; for more information see https://kineticgames.co.uk/. We operate this website.

We use a third party supplier that collects and uses personal information about you on our behalf when you play our games online. We are a ‘controller’ of that personal information and as such we have certain obligations under UK data protection law in relation to that personal information.

Scope of this policy

This privacy policy relates to your use of our games and related online services only.

Our games are designed to let gamers play online with one another. To help facilitate this, information is shared between gamers, their equipment, our supplier and our distributors that provide our games and online services to you.

In order for us to provide our online services to you, we use and link to services owned and operated by certain trusted third parties as follows:

  • Valve Corporation to distribute our game.

  • HTC Corporation to distribute our game.

These third parties may also gather personal information about you in accordance with their own separate privacy policies. For privacy information relating to these other third parties, please consult their privacy policies as appropriate.

Collection and use of your personal information

We collect personal information about and from you when you use our online services.

The personal information we collect about you depends on the particular store you purchased our game from ( the personal information we collect is issued from your use of that store’s software) and your activities carried out through our online services (the personal information we collect is issued from your device). This information includes:

  • certain Steam account details, such as your Steam ID;

  • certain HTC Account details, such as your InfinityTag (ID for HTC Vive users);

  • your IP address; and

  • voice, chat and other interaction and communication through our online services.

Your personal information is used:

  • to provide our goods and services to you;

  • to verify your purchase of our goods and services;

  • so that you can use our online services and connect with other gamers;

  • to share with other gamers while you use our online services;

  • to provide a fair gaming experience to all players; and

  • to customise our online services and their content to your particular preferences.

Our online services are not intended for use by children and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose. Where we rely on consent as a lawful basis to process your personal information, you have the right to withdraw your consent at any time. To do this, please email us (see: “How to contact us”);

  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;

  • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)

  • vital interests: where our use of your personal information is necessary to protect you or someone else’s life; and

  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

Further information — the personal information we collect, when we collect it and how it is used

For further details on when we collect personal information, what we collect and how it is used, please read the following sections:

Gaming Privacy Policy

Please note that we may process your personal information without your knowledge or consent where this is required or permitted by applicable law.

Who we share your personal information with

Your IP address, Steam ID, InfinityTag, username, Steam account details and HTC account details are routinely shared through our online services with third parties, including Valve Corporation and HTC Corporation. This enables you to use our online services.

Your username and voice and other communications through our online services are routinely shared between our supplier, Exit Games Inc. and other online gamers, to enable you to use our online services and play our games with other online gamers.

These third party recipients are (or may be in the case of online gamers) based outside the United Kingdom — for further information including on how we safeguard your personal information when this occurs, see “Transfer of your personal information out of the United Kingdom”.

We will share personal information with law enforcement or other authorities if required by applicable law.

Whether personal information has to be provided by you, and if so why

We require you to provide your personal information to enable your use of our online services. If you do not provide your personal data when asked, you may not be able to access our online services or the functionality of our games may be impaired.

Transfer of your personal information out of the United Kingdom

Your personal information may be transferred outside the United Kingdom (UK) to:

  • the United States of America in order for our supplier, Exit Games, to provide their services;

  • the location of the relevant server you choose to play our game on (e.g. United States of America, Europe, Asia) in order for our supplier, Exit Games, to provide their services; and

  • enable us to provide our services to you and for you to connect with gamers using our online services who are based throughout the world.

These transfers are subject to special rules under UK data protection law.

Some countries have been assessed as providing an adequate level of protection for personal information. Other countries are not considered to have sufficient data protection laws. We will, however, ensure the transfer complies with UK data protection law. We will do this by ensuring one of the following (or one of the other grounds set out in UK data protection law) applies:

  • your personal information is transferred to countries that have been deemed to provide an adequate level of protection for personal information;

  • the transfer is necessary for the performance of a contract between you and us;

  • the transfer is necessary to establish, exercise or defend legal claims;

  • there are adequate safeguards in place between us and the organisation receiving it (e.g. by the use of approved contractual terms); or

  • you have provided explicit consent to the proposed transfer after being informed of any potential risks.

Please contact us (see: “How to contact us”) if you want further information on the specific mechanism used by us when transferring your personal information outside of the UK.

Your data protection rights

UK data protection law gives you certain rights, which you can exercise free of charge. Your rights will differ depending on our lawful basis for processing your personal information. In summary, those include rights to:

  • fair processing of information and transparency over how we use your personal information;

  • access to your personal information and to certain other supplementary information;

  • require us to correct any mistakes in your personal information;

  • require us to delete your personal information in certain situations;

  • ask us to transfer any personal information you provided to us to another organisation in certain situations;

  • object at any time to the processing of your personal information for direct marketing purposes;

  • object to decisions being taken by automated means which effect you legally or have similarly significant affects;

  • object in certain situations to our continued processing of your personal information; and

  • otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK General Data Protection Regulation here.

If you would like to exercise any of your data protection rights, please:

  • email us (see: “How to contact us”);

  • let us have enough information to identify you (e.g. name, username);

  • let us have proof of your identity and address, if required; and

  • let us know the personal information to which your request relates.

How to complain

Your personal information may be transferred outside the United Kingdom (UK) to:

  • the United States of America in order for our supplier, Exit Games, to provide their services;

  • the location of the relevant server you choose to play our game on (e.g. United States of America, Europe, Asia) in order for our supplier, Exit Games, to provide their services; and

  • enable us to provide our services to you and for you to connect with gamers using our online services who are based throughout the world.

These transfers are subject to special rules under UK data protection law.

Some countries have been assessed as providing an adequate level of protection for personal information. Other countries are not considered to have sufficient data protection laws. We will, however, ensure the transfer complies with UK data protection law. We will do this by ensuring one of the following (or one of the other grounds set out in UK data protection law) applies:

  • your personal information is transferred to countries that have been deemed to provide an adequate level of protection for personal information;

  • the transfer is necessary for the performance of a contract between you and us;

  • the transfer is necessary to establish, exercise or defend legal claims;

  • there are adequate safeguards in place between us and the organisation receiving it (e.g. by the use of approved contractual terms); or

  • you have provided explicit consent to the proposed transfer after being informed of any potential risks.

Please contact us (see: “How to contact us”) if you want further information on the specific mechanism used by us when transferring your personal information outside of the UK.

Changes to this policy

This policy was published on 10th June 2021 and last updated on 10th June 2021.

We may change this policy from time to time. When we do we will post the changes on our website. Your contacting us, whether through Discord, Twitter, by post, by email or otherwise shall be deemed acceptance of our latest version of this policy.

How to contact us

Please contact us, by sending an email to [email protected] if you have any questions about this privacy policy or the information we hold about you.

Do you need extra help?

If you would like this policy in another format (for example large print) please contact us (see “How to contact us”).

10th June 2021

Version 1

When information is collected

Information that may be collected

How and why your information is used

When you use our online services

IP address;

Steam ID;

InfinityTag;

the public persona name you have chosen to represent you when using our online services (username);

Steam account details necessary to confirm you are authorised to play the game;

HTC account details necessary to confirm you are authorised to play the game; and

voice and other communication through our online services.

We need your personal information so that we can carry out our contract with you. It is also in your and our legitimate interests for us to use your personal information so that you can access our online services and enjoy the benefit of the full functionality of our games.

We will keep this information :

— in the case of your IP address, Steam ID, InfinityTag, username, Steam account details and HTC account details, for no longer than your use of the online service for that session.

— in the case of voice and other communication, until transmission to other gamers is completed.

— in the case of your IP address, Steam ID, Inf inityTag and username and there is an error during your use of our online services, for no longer than 4 weeks, to enable us and our supplier, Exit Games Inc. (Exit Games), to improve our online services.