Política de privacidad

Effective date: December 10, 2021

Iron Galaxy Studios LLC ("us", "we", “Iron Galaxy”, “IG”, or alternative first person reference) wants to thank you for your interest in connection with our video game, Rumbleverse (the “Game”). If you are here, you have been directed here through the Game, a digital storefront where the Game is made available, or through our website, located at https://www.rumbleverse.com (the “Website”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services, as defined below, your rights to your data under U.S. and International Law, including but not limited to the EU Directive 2002/58/EC and the EU General Data Protection Regulation (“GDPR”), Brazil’s the Lei Geral de Proteção de Dados (commonly referred to as the “LGPD”), the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM”), the U.S. Children’s Online Privacy Protection Act (“COPPA”), and the California Consumer Privacy Act (“CCPA”), and the choices you have associated with that data. This Privacy Policy applies to the Game (including without limitation enhancements thereto or future DLC), and our Website, content, services, patches, updates, or tools thereto (each individually a “Service” and collectively the "Services") where this Privacy Policy is referenced, regardless of how you access or use the Services.

This Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible through our Services. We encourage you to review the privacy policies of any other Service Provider from whom you request Services. If you visit a third party website that is linked to our Game, you should consult that website’s privacy policy before providing any personal information.

We may use your data to provide and improve the Services. This Privacy Policy is solely intended to inform defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible here: www.rumbleverse.com/terms-of-service.

This Privacy Policy describes:

The information we may collect, how we may collect such information and the purposes of our collection;
How we may use and with whom we may share such information;
How you can access and update your information; and
How we protect the information we may store about you.

Disclosure to California Residents: In our efforts to comply with applicable regulation, we ask and advise that California residents review the CCPA Disclosure section at the end of this Privacy Policy. Although we do not sell End User data, we will provide notice if at any time those circumstances change.

Disclosure to Residents of Brazil: The LGPD grants residents of Brazil certain rights about the processing of their personal information and we ask and advise that residents of Brazil review the relevant section under the “Your Rights” heading of this Privacy Policy.

Definitions

Personal Data

Personal Data means information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, a device identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself.

Cookies

Cookies are small pieces of data stored on an End User’s device.

Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

End User

The End User is you - the individual using our Service! The End User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection And Use

We may collect different types of information for various purposes to provide and improve our Services.

Types of Data Collected

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you for gameplay telemetry, questions regarding this Privacy Policy, or to provide updates to our Services ("Personal Data").

Personally identifiable information may include, but is not limited to:

E-mail address
First name and last name
Platform specific username
Usage Data

We may use your Personal Data to contact you with, updates, participation guidelines and other information that may be of interest to you in relation to the Game. You may opt in to participate and receive any, or all, of these communications from us by providing your e-mail address upon enrollment in our Services.

Usage Data

We, or third parties operating through our Services, may also collect information concerning your access and use of the Services ("Usage Data"). This Usage Data may include information such as unique device identifiers and other diagnostic data.

Tracking Cookies Data

We, or third parties acting on our or their own behalf may use Cookies and similar tracking technologies to track your activity in connection with our Services and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies may also be used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some portions of our Services.

Examples of Cookies that may be present as well as their uses:

Session Cookies. To operate our Service.
Preference Cookies. To remember your preferences and various settings.
Security Cookies. For security purposes.

Use of Data

We may use your personal information to provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:

To provide and maintain our Services;
To notify you about changes to our Services;
To allow you to participate in interactive features of our Services when you choose to do so and to the extent applicable;
To provide information in the event you have questions regarding this Privacy Policy; and
To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities.

We may also use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:

To improve gameplay and delivery with regard to our Game and Services;
Gather analysis or valuable information so that we can improve our Services;
Monitor the usage of our Services;
Detect, prevent and address technical issues; and
To enforce any Terms and Conditions with respect to our Game and Services, to the extent applicable.

With your consent, we may use your personal information to:

Provide you with updates and general information about our Game and Services; and
Contact you in the event that you contact us with questions regarding this Privacy Policy.

You have the right to withdraw your consent at any time.

Retention of Data

Iron Galaxy will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Iron Galaxy will also retain Usage Data for internal analysis purposes which may be used to strengthen the security or to improve the functionality of our Services. We may retain this information for as long as we are legally or contractually obligated to do so.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Iron Galaxy will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. The transfer of such data is typically for the purpose of fulfilling our contract with you, as specified above. Therefore, any request to delete or modify such Personal Data may result in the termination or interruption of our Services with respect to your usage of such Services.

Disclosure Of Data

Service Providers

In accordance with this Privacy Policy, Iron Galaxy may disclose your Personal Data to third party Service Providers (defined below) as may be necessary to provide Services to you. We may share (i) aggregated information (information about you and other End Users collectively, but not specifically identifiable to you); (ii) anonymous information; (iii) certain technical information (including IP addresses, device or player IDs and platform specific usernames) to develop and deliver Services to you; (iv) personally identifiable information, including address, phone number, identify verification, and other personal information as may be necessary to provide Services. We direct all such third party Service Providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on Iron Galaxy’s behalf.

Disclosure for Law Enforcement

Under certain circumstances, Iron Galaxy may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

Iron Galaxy may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation;
To protect and defend the rights or property of Iron Galaxy;
To prevent or investigate possible wrongdoing in connection with the Service;
To protect the personal safety of End Users of the Service or the public; and
To protect against legal liability.

Change of Control

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our privacy standards. Should such an event occur, we will require that the new combined entity follow this Privacy Policy with respect to your Personal Data. If we intend to handle your Personal Data for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your Personal Data for the new purposes.

Security Of Data

We protect your Personal Data using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use may include firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

California Do Not Track Disclosure
The California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) requires operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

While some browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the websites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, Do Not Track is inapplicable to our Services; accordingly, the choices that we provide you concerning our collection and use of personally identifiable information will continue to operate as described in this Privacy Policy. For information about Do Not Track, please visit: www.allaboutdnt.org.

Your Rights

Iron Galaxy aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You may update, correct, or provide additional information to your Personal Data by resubmitting your information or contacting us directly. If you are correcting information provided to a third party (such as those identified in the “Service Providers” section below) please correct your information via the methods and direction provided by the applicable third party.

If you wish to be informed what Personal Data we may hold about you and if you want it to be removed from our systems, please contact us via any of the contact options provided at the end of this Privacy Policy.

You have the right:

To know what personal information we maintain about you;
To receive a copy of your personal information in a structured, commonly used and machine-readable or commonly used electronic format on request;
To update and modify personal information is incorrect or incomplete;
To object to our processing of your personal information when collection is based on a legitimate interest; and
To delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our Services.

Please note that we may ask you to verify your identity before responding to such requests.

How to Control Your Information

Under the GDPR, individuals residing in the EU and other territories that have adopted GDPR compliance or comparable regulation have a right to:

Access their End User data;
Correct the data they have provided to us;
Have information provided to them in a portable format;
Request the deletion of the data we have collected;
Restrict processing; and
Object to processing or the legal basis on which we rely to process their data.

Please note that we may ask you to verify your identity before responding to such requests.

You may send an e-mail to GDPR@irongalaxystudios.com with your request to exercise any of the rights identified above. Place the reason for your request (e.g., “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and e-mail address in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to inquiries related to this Privacy Policy, will be retained for legal purposes.

We are unable to delete data controlled solely by third parties; for example, if you access any our of Services through third party social media or service platforms, or if you are routed to a third party service provider’s web page through our Services, you will need to make any deletion requests to those respective third parties separately.

Individuals Located in Brazil: The LGPD grants you certain rights about the processing of your personal information. In addition to any applicable rights mentioned above, eligible residents of Brazil also have the right: (i) to the anonymization, blocking, or elimination of your personal information, if you believe we are processing your personal information in an unnecessary, exceeding or non-compliant manner with the LGPD; (ii) to request the portability of your personal information; (iii) to request information about the entities with which we have shared your personal information; and (iv) to request information about the possibility and consequences of denying consent. While our processing of personal information generally does not include automated decision-making, you are also entitled to a review of our decisions that are made solely based on automated processing of personal information that affect your interests. Notwithstanding any other references to the contrary within this Privacy Policy, in accordance with the LGPD, we will respond to your request within fifteen (15) days after receipt and we will provide any requested information free of charge to you. You may also file a complaint with the National Data Protection Authority in Brazil, the Autoridade Nacional de Proteção de Dados (“ANPD”) for alleged violations of the LGPD, in addition to or alternatively to seeking judicial redress.

Opt Out Options

Opt Out Limitations

Please note that if you opt-out of our communications, we may still e-mail or communicate with you from time to time if we need to: provide you with information and updates concerning this Privacy Policy or our Terms and Conditions, , or for other legitimate non-marketing reasons.

Service Providers

We may engage third party companies and individuals to facilitate our Services ("Service Providers"), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services are used.

These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose except as necessary to perform services on our behalf or comply with legal requirements.

Web Services, Payment Processing and Analytics

We may use Service Providers to monitor and analyze the use of our Service. We have provided links to their respective privacy policies as follows:

https://privacy.microsoft.com/en-us/privacystatement

https://www.playstation.com/en-us/legal/privacy-policy/

https://aws.amazon.com/privacy/?nc1=f_pr

Links To Other Sites

In utilizing our Service you may be exposed to links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Game is family friendly, and we encourage parents and guardians to use our Games with their children ages 13 and above. However, we take children’s privacy very seriously, and we do not directly or knowingly collect any Personal Data from End Users deemed to be children under their respective national laws through our Services. We strive to comply with the Children’s Online Privacy Protection Act of 1998, the U.S. law that protects the privacy and information of children. We strongly encourage parents and guardians to learn more about this important regulation. For more information, you can visit: https://epic.org/privacy/kids/#introduction. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

If you are under the age of 13 and using our Services, please have a parent or guardian nearby to provide any information we may request, including an e-mail address or platform specific username, as applicable.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via e-mail and/or a prominent notice on this page, corresponding with such change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

Reach us by e-mail: EULA@Irongalaxystudios.com
By visiting this page on our website: https://irongalaxystudios.com/
By phone number: 1+312-429-7800
Or by mail at:

Iron Galaxy Studios LLC

P.O. Box 2193
Chicago, IL 60690

California Consumer Data Rights

Iron Galaxy complies with the California Consumer Privacy Act of 2018 (CCPA) as amended, that secures specific privacy rights for California consumers.

Categories of Data We Collect and Their Uses

In addition to the details provided in our Privacy Policy, we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category	Examples	Collected	Reason for Collection	“Sold” to 3^rd Pty?
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes	To ensure End User save data is linked to the correct accounts and devices. To properly gate access to the application. To properly link accounts between services. To communicate with the End User about new games and events.	No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes	To respond to an End User’s questions regarding this Privacy Policy.	No
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No	N/A	N/A
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	To properly process Real Money Transactions in platform stores.	No
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No	N/A	N/A
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes	Gameplay telemetry is essential to understanding End User behavior and balance within the Game.	No
Geolocation data.	Physical location or movements.	No	N/A	N/A
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A	N/A
Professional or employment-related information.	Current or past job history or performance evaluations.	No	N/A	N/A
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No	N/A	N/A
Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Inferences may be drawn from gameplay telemetry data solely with regard to the Game.	No

Personal Information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We may obtain the categories of Personal Information listed above from the following categories of sources:

Directly from our End Users. For example, from End Users who provide feedback to us, or in the event that you contact us with questions regarding this Privacy Policy.
Indirectly from our End Users. For example, through information we collect in the event that you contact us with questions regarding this Privacy Policy.
Directly and indirectly from activity through the Services. For example, from APIs, and other information related to improving our Services.
From third parties that interact with us in connection with the Services we perform.

All such Personal Information is used as otherwise described above in our Privacy Policy.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose;

Identifiers.

Your Rights and Choices

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Information we collected about you;
The categories of sources for the Personal Information we collected about you;
Our business or commercial purpose for collecting that Personal Information;
The categories of third parties with whom we share that Personal Information; and
The specific pieces of Personal Information we collected about you (also called a “data portability” request).

We generally do not sell End User data. However, if we do sell your Personal Information for a business purpose, we will also disclose to you:

The Personal Information that each category of recipient purchased; and
Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

Complete any transaction for which we collected the Personal Information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products, including our Game, to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1+312-429-7800
Sending us a letter at:

Iron Galaxy Studios LLC

P.O. Box 2193

Chicago, IL 60690

Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.