A summary of this document, written for young people, is available here.
Date: 27 Feb 2024
HERE ARE THE KEY FACTS:
We are committed to protecting your information responsibly and using appropriate security measures. In this policy We explain as to how We look after your Personal Data (regardless of where you visit or access from) when you:
Who are We?
We are a UK videogames developer and publisher called Jagex. Our address is 220 Cambridge Science Park, Cambridge, England, CB4 0WA. You can contact Us at email@example.com
You can always:
Please click on the links below to find out more about each topic below:
Table of contents
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number Fax: 01625 524 510 Live Chat Link
If you're a customer within the EU, you can file a complaint to your local member state data protection authority listed here.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or local DPA, so please get in touch with Us in the first instance.
It is important that the Personal Data We hold about you is accurate and current. Please keep Us informed if your Personal Data changes during your relationship with Us.
We collect, use, store and transfer different categories of Personal Data about you, which We have grouped together as follows:
If you decide to make a payment for any of Our products and services, your Financial Data, which includes your bank account and payment card details, will be collected and processed by Our external payment service provider. We will not have access to, collect, use, store or transfer your Financial Data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.
We use mobile analytics software to allow Us to understand better the functionality of Our mobile software on your device. This software records information such as how often you play Our games, the events that occur within the games, aggregated usage, performance data, and where the games were downloaded from. We do not link the information We store within the analytics software to any personal information you submit within the games.
We collect Personal Data including Identity Data and contact information, player identifiers and email addresses, from publishing platforms that make Our games available. These include but are not limited to Valve (Steam), Apple (iOS), and Google (Android). The publishing platforms are responsible for your accounts and Personal Data on their platforms, and We encourage you to read their privacy policies. We will only retain your Personal Data for as long as your publishing platform account is linked to your Jagex Account.
If you play Our games on your mobile device or tablet, We receive information about you from the IOS or Android app stores and other mobile platform providers. This information includes your username or device ID but does not include any financial information. Some of Our mobile platforms send information to Us that you authorise them to provide. We will only retain your data for as long as your account is linked to your Jagex Account.
When you link your social network account via Google, Facebook, or Apple to play Our games on Our mobile platform or website, We receive information about you from your social network provider. This information includes your name, email address, language preference, and profile picture. We will only retain your data for as long as your account is linked to your Jagex Account.
Where We need to collect Personal Data by law or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with access to one of Our games). In this case, We may have to cancel a product or service you have with Us, but We will notify you if this is the case at the time.
Our legal basis for processing your personal information varies depending on the type of information We collect and the context in which We collect it.
If you are a resident of the United Kingdom or of a jurisdiction where similar legal requirements may apply, such as Brazil, Switzerland, and the European Union, We rely on several legal bases to process information about you. We will process information about you where We have your consent, where We have a Legitimate Interest to do so, where the processing is necessary for the Performance of a Contract with you, and where We have a legal obligation to process your information. For example, We typically rely on the following:
We use different methods to collect data from and about you, including, but not limited to:
Direct interactions. You may give Us your Identity Data, Contact Data and Financial Data by filling in forms or corresponding with Us by post, phone, email or otherwise. This includes Personal Data you provide when you:
Third parties or publicly available sources. We receive Personal Data about you from various third parties and public sources as set out below:
We will only use your Personal Data when the law allows Us to. Most commonly, We will use your Personal Data in the following circumstances:
Generally, We do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting Us using the details at section 2 (Contact Details). The withdrawal of consent will not affect the lawfulness of any processing that took place before the withdrawal.
We have set out below, in a table format, a description of all the ways We may use your Personal Data, and which of the legal bases We rely on to do so. We have also identified what Our Legitimate Interests are where appropriate.
Note that We may process your Personal Data for more than one lawful ground depending on the specific purpose for which We are using your data.
|Type of data
|Lawful basis for processing including basis of Legitimate Interest
|To register you as a new customer
|Performance of a Contract with you
|To process and deliver your order including:
|To manage Our relationship with you which will include:
|To enable you to partake in a prize draw, competition or complete a survey
|To administer and protect Our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you
|To use data analytics to improve Our website, products/services, marketing, customer relationships and experiences
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|To ask you to take part in research to improve Our game platform
|Necessary for Our Legitimate Interests (to develop Our products/services and grow Our business)
|To process your job application to work with Us
|Performance of a Contract with you
|To facilitate a duty of care to you
|Necessary for Our Legitimate Interest (to help you manage aspects of your activities when interacting with Our products/services)
We provide you with choices regarding Our use of your Personal Data for marketing and advertising purposes. We have established the following Personal Data control mechanisms:
You will receive marketing communications from Us if (a) you have opted into Our marketing channels or (b) you have subscribed for an account with Us or purchased goods or services from Us and you have not opted out of receiving that marketing (save where local Data Protection Laws do not allow option (b)).
All of Our marketing communications to you contain an opt out option and you can opt out at any time. Please note that the opt out will not affect the lawfulness of processing that has taken place before the opt out.
We will get your explicit opt-in consent before We share your Personal Data with any company outside Jagex for marketing purposes.
You can ask Us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting Us at any time using the details at section 2 (Contact Details).
The Identifier For Advertising (IDFA) is a unique, user-resettable ID for advertising, provided by the mobile device's operating system. We may use this ID to enhance serving and targeting capabilities, re-target specific campaigns, or pass the ID to Our partners. Advertising ID does not reveal any information about the user or the device. If you prefer to opt-out or reset your IDFA, please follow these standard instructions:
These third-party vendors collect, store, use, process, and transfer information about your activity on our services in accordance with their Privacy Policies and to enable Us to:
Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:
You may opt-out of all personalized advertising by enabling privacy features on your mobile device such as Limit Ad Tracking (iOS) and opt Out of Ads Personalization (Android). See your mobile device help system for more information.
Google Ads (AdWords) remarketing services is provided by Google Inc.
Facebook remarketing services is provided by Facebook Inc.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.
If you have previously allowed Us to access your geolocation data, you can stop making geolocation available to Us by visiting your mobile device's settings for the games or the "settings" page for the games.
When you install Our games on your mobile device you can choose to receive push notifications, which are messages Our games send you on your mobile device even when the game is not on. You can turn off notifications by visiting your mobile device's "settings" page.
We will only use your Personal Data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose.
If We need to use your Personal Data for an unrelated purpose, We will notify you and obtain your consent to do so. Please note that We may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your Personal Data with third parties set out below for the purposes set out in the table in section 8 (How We Use Your Personal Data) above:
Some of Our external third parties are based outside the UK and the European Economic Area (EEA), so their processing of your Personal Data will involve a transfer of data outside the UK and the EEA.
|External Party Category
|a) Technical partner
|a) Provide technical processing services
|b) Marketing partner
|b) Provide marketing services
Whenever We transfer your Personal Data out of the UK and the EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, disclosed or being unavailable. In addition, We limit access to your Personal Data to those employees, agents, professional advisers, contractors, and other third parties who have a business need to know on the principle of least privilege (PoLP). They will only process your Personal Data on Our instructions, and they are subject to a duty of confidentiality. We periodically review all privacy and security policies and update them when necessary, in line with changes in Data Protection Laws or when new technologies are introduced into Our business.
Where the introduction of new technologies results in a high risk to your Personal Data, We will perform a data protection impact assessment and will only proceed if We are able to mitigate any identified high risks. Methods of collecting Personal Data are reviewed by management before they are implemented to confirm that Personal Data is obtained:
a) fairly, without intimidation or deception, and
b) lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to the collection of Personal Data.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.
We will only retain your Personal Data 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. A copy of Our Data Retention Schedule is available upon request.
To determine the appropriate retention period for Personal Data, We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which We process your Personal Data and whether We can achieve those purposes through other means, and the applicable legal requirements.
By law, We have to keep basic information about Our customers (including Contact, Identity, Financial and Transaction Data) for six tax years plus the current tax year as part of Our legal obligations to do so. In some circumstances, you can ask Us to delete your data: see Request erasure below for further information.
In some circumstances, We may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.
Once the data retention periods above expire, digital records are permanently destroyed or fully anonymised if retained for statistical or research purposes. In this case, all personal identifiers are removed permanently so individuals cannot be identified.
Under certain global Data Protection Laws (including UK and EU Data Protection Laws) and under certain circumstances, you have rights in relation to your Personal Data. We set out below a brief description of such rights:
Please note that the above rights are not all absolute and are subject to applicable Data Protection Laws and may be subject to conditions and provisions set out in applicable Data Protection Laws. For further information or if you wish to exercise any of the rights set out above, please get in touch with Us.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, We may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.
We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if your request is particularly complex or you have made a number of requests, in which case We will inform you of an extension period of up to 2 months. In this case, We will keep you informed on progress.
The Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais or LGPD) was passed by the National Congress of Brazil on 14 August 2018 and came into effect on 15 August 2020. The information set out in this section only applies to the processing of the Personal Data of individuals in Brazil.
You may request confirmation of the processing of your data.
Please note that not all of the above rights are absolute. You will not be discriminated against or suffer any sort of detriment if you exercise any of your rights.
Description of the Services
|Web content and solution for personalized games, educational and entertainment content, etc.
|Customized mobile platforms that provide you with access to the published games.
|Game publishing platforms that provide you, via your social networks ID, various of published games that are made available to you from streaming services, such as Valve (Steam), Apple (iOS), and Google (Android).
In this section, the terms "Personal Information" or "Personal Data" refer to information that identifies an individual or relates to an identifiable individual or as otherwise defined under US Privacy Laws, including –
We 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. The following is a list of categories of Personal Information which We may collect or may have been collected from US residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the US Privacy Laws:
This does not mean that all examples of that category of Personal Information were in fact collected by Us but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if You provided such Personal Information directly to Us.
We obtain the categories of Personal Information listed above from the following categories of sources:
We may use or disclose Personal Information We collect for business purposes or commercial purposes, which may include the following examples:
If you are under the age of 13, you are not allowed to use Our services.
We do not knowingly collect Personal Information from minors under the age of 16 through Our services, although certain third-party websites that We link to may do so.
If you have reason to believe that a child under the age of 13 has provided Us with Personal Information, please contact Us with sufficient detail to enable Us to delete that information.
Disclosure and Sharing of Personal Information
We may use, share, or disclose Personal Information related to you, and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes: identifiers; Personal Information categories applicable to the processing; commercial information; or internet or other similar network activity.
When We disclose Personal Information for a business purpose or a commercial 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.
We may sell and may have sold in the last twelve (12) months the following categories of Personal Information: identifiers; Personal Information categories applicable to the processing; commercial information; or internet or other similar network activity.
At any time, you can opt-out of the collection of Personal Information by Our service providers by contacting Us or visiting the "do not sell my personal information" page, available at: https://support.runescape.com/hc/en-gb/articles/360001370829 .
US State Data Protection Laws provide residents of certain states with specific rights regarding their personal information. If you are a resident of the US, US State Data Protection Laws may grant some or all of the rights set out below.
The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
The right to know/access. You have the right to request that We disclose information to you about Our collection, use, sale, disclosure for business purposes and share of Personal Information. Once We receive and confirm your request, We will disclose to you:
The right to say no to the sale or sharing of Personal information (opt-out). You have the right to direct Us to not sell Personal Information related to you. To submit an opt-out request, please see the "Sale of Personal Information" section or contact Us.
The right to correct Personal information. You have the right to correct or rectify any inaccurate Personal Information about you that We collected. Once We receive and confirm your request, We will use commercially reasonable efforts to correct (and direct Our service providers to correct) Personal Information related to you, unless an exception applies.
The right to limit use and disclosure of sensitive Personal information. Jagex does not use or disclose Sensitive Personal Information for purposes that, under applicable law, require Us to offer consumers a "Right to Limit" the use or disclosure of Sensitive Personal Information.
The right to delete Personal information. You have the right to request the deletion of Personal Information related to you under certain circumstances, subject to certain exceptions. Once We receive and confirm your request, We will delete (and direct Our services providers to delete) Personal Information related to you from Our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for Us or Our services providers to:
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
To submit a verifiable request to exercise any of your rights (including your right to opt out of the sale of your Personal Information) please click here: https://support.runescape.com/hc/en-gb/articles/360001370829 .
Only you, or a person registered with the competent Secretary of State that you authorize to act on your behalf, may make a verifiable request related to Personal Information related to you.
Your request to Us must:
We cannot respond to your request or provide you with the required information if We cannot:
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Personal Information related to you that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least annually, and whenever changes to such laws and regulations are made, privacy policies and procedures are revised to conform with the requirements of applicable laws and regulations.
END OF POLICY