Privacy Policy and Terms of Service

Introduction

Who are we?

We are X R Games Limited (Company Number: 10698843), a company incorporated and registered in England and Wales with a registered address at The Half Roundhouse, Graingers Way, Leeds, LS12 1AH, UK ("XR Games", "we" or "us") and we are a game development studio.

Where we decide the means or purpose of processing your personal data, we are the "data controller".

What's this notice about?

This notice explains how we process personal data, as a data controller, relating to:

• visitors to our website ("Website Users"): xrgames.io (the "Website"); and
• users of our games ("Game Users"), including "STARSHIP TROOPERS: CONTINUUM", " "HITMAN 3 VR: Reloaded", "ZOMBIELAND VR: HEADSHOT FEVER", "ZOMBIELAND: HEADSHOT FEVER RELOADED", "ANGRY BIRDS UNDER PRESSURE VR" and "ALL STAR FRUIT RACING VR" (the "Games"), which are accessible via third-party applications and/or games platforms including, without limitation; Steam, Oculus, PlayStation and Meta (each a "Platform").

Together, the Website Users and Game Users shall be the "Users" (and each one shall be a "User"). References to "you" or "your" shall refer to any User.

We update our Privacy Notice from time to time, so Users should check back on a regular basis. Where appropriate, we will actively notify you of updates.

Where Games are available via a Platform, such Platform will act as an independent controller of your personal data. Your use of each Platform is subject to the terms of use and privacy policy applicable to that Platform (as may change from time to time).

Please also note that other websites or services mentioned or linked to on the Website or within Games are not operated by us. You should refer to the privacy policies on those websites or services to understand how they may be using your personal data.

We do not accept any responsibility or liability for the privacy practices of any third party services or any Platform, and your use of those is at your own risk.

What are your rights?

Users have the following rights:

• Be informed about the collection and use of your personal data (as set out in this Privacy Notice)
• Ask us to send a copy of your personal data to you or someone else
• Ask us to restrict, stop processing, or delete your personal data
• Object to our processing of your personal data
• Object to use of your personal data for direct marketing purposes
• Ask us to correct inaccuracies in your personal data
• Obtain and reuse your personal data for your own purposes across different services
• Rights related to automated decision making, including profiling

If we rely on consent to process personal data, you can withdraw consent at any time.

To make a request under one or more of your rights, please let us know by sending an email to support@xrgames.io

You also have the right to submit a complaint to a supervisory authority. In the UK, you can get in contact with the Information Commissioner's Office: https://ico.org.uk/concerns. If you live in another EU member state, you can alternatively submit a complaint to the supervisory authority in your country.

How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: support@xrgames.io

Your Personal Data and How We Use It

Your personal data and why we use it

Leaderboard processing activities

We process the following personal data so that we can maintain a leaderboard for the Games:

• Username
• Score
• Time spent on Game level
• Leaderboard rank

Our legal justification for using your personal data

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We process this information as it is necessary legitimate interests (being to promote the success of the Games, our business and the services), and such interests are not overridden by your interests or fundamental rights and freedoms

Sources & recipients

Sources

We collect this personal data from the Platforms.

Recipients

We make this personal data available to certain members of staff and Website Users who have registered for our careers newsletter.

Your personal data and why we use it

Enquiry data

We process the following personal data in relation to Website Users when they get in touch with us. For example, when they submit any enquiries, complaints or questions about our Games, Website, products or services:

• Email address
• Any other information that Website Users submit as part of their enquiries, complaints or questions.

We use this personal data to communicate with you and provide our support services.

Our legal justification for using your personal data

We may process this data in accordance with our Website's End-User License Agreement (which you can access here: End-User License Agreement/ XR Games or to take steps at your request prior to entering a contract.

We also use this to pursue our legitimate interests, including:

• Our interest in responding to enquiries to ensure smooth operation of our business and services
• To understand our customers and improve our Services, by taking on-board your feedback.

Sources & recipients

Sources

We collect this data directly from Website Users

Recipients

This information is available to certain members of our staff and Wix, our third-party website hosting service provider.

Your personal data and why we use it

Blog Data

We process any information that Website Users submit as part of their comments on blog posts published on the Website ("Website Blogs") to allow Website Users to interact with each other in relation to Website Blogs and understand how Website Users interact with our Website Blog content.

Our legal justification for using your personal data

We may process this data to pursue our legitimate interests, including:

• To understand how our Website Users interact with our Blog, including taking on-board feedback and comments
• Allowing our Website User's to interact with each other

Sources & recipients

Sources

We collect this data directly from Website Users

Your personal data and why we use it

Job application processing activities

We process the following personal data in relation to Website Users when they submit a job application on our Website:

• First name and last name
• Email address
• Address
• Phone number
• Resumé/CV
• Website, blog or portfolio
• Information about how the job vacancy was brought to your attention
• Any other information you include in your CV

We use this personal data to assess whether you are suitable for a role at XR Games, including to consider your skills and qualifications. We'll also communicate with you about the role and the recruitment process and keep appropriate records of the process.

Our legal justification for using your personal data

We process this personal data to pursue our legitimate interests being to:

• Hire suitably qualified individuals
• Operate our business and promote its success

Sources & recipients

Sources

We collect this data directly from Website Users via social media platforms (such as LinkedIn) or via third party employment websites (such as Indeed).

Your personal data and why we use it

Direct marketing

If you opt in to our mailing list, we process the following information for the purpose of sending a careers newsletter to individuals. We make suggestions and recommendations to you about: (i) news and updates relating to us and our services; (ii) services that may interest you; and (iii) other promotional activity and events we think may be of interest:

• Name
• Address
• Whether you have applied for a job with us in the past
• Other information you provide to us when you sign up to our marketing communications
• The fact you have provided, or declined to provide, consent to receive marketing from us

Our legal justification for using your personal data

We process the fact that you have provided or declined to provide, consent to receive marketing to pursue our legitimate interests, being to:

• Ensure that marketing services are provided lawfully
• Ensure that our mailing lists function effectively so that you only receive the communications you have asked for

We process all other direct marketing information based on your consent. You can withdraw your consent at any time by emailing hello@xrgames.io

Sources & recipients

Sources

We collect this data directly from you

Recipients

This information is available to certain members of our staff and Mailchimp

Storage, Transfers and Disclosure

Data retention

We hold personal data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain personal data to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature and sensitivity of the data, the potential risk of unauthorised access and legal requirements.

Storage & Transfers

We are based in the United Kingdom, regularly collaborate with an international network of partners and may from time to time use subcontractors and service providers based in other countries. Where we transfer your information outside of the UK and/or EEA, we will have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. For more information, send an email to support@xrgames.io

Disclosure

We may disclose your personal data:

• Where required to do so by law, government, competent authorities or the courts to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With suppliers and subtractors, for example Wix and Mailchimp, as necessary for the purposes set out in this notice.
• With other members of our corporate group and our international network of partners.
• If we are involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

Cookies

Cookies are very small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners and operators of the site. The table below explains the cookies we use and why.