Privacy & Data Policy

Last updated: 7 May 2024

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed and/or published by Cooperative Innovations Ltd. (“Coop” / “we” / “us”).

Our office is at Unit 6, Mercury Quays, Ashley Lane, Shipley, Bradford, BD17 7DB, UK.

We are a company registered in England, with company number 10494498.

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, stvr.app, spaceteamvr.com and coopinnovations.co.uk (“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 info@coopinnovations.co.uk

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 any other terms which we may from time to time provide via our Website or as part of the Games as made available here: coopinnovations.co.uk/privacy.

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 and profile image.
Your Oculus ID and Oculus profile/display name and profile image.
Your PlayStation Network ID and profile/display name and profile image.
Your HTC ID and profile/display name and profile image.

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, game activities, 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.

We may also collect technical information to help us understand how you use our Online Services, and how often, so we can improve them to deliver a better experience for our users. To carry out research and statistical analysis to help improve our content, products and services.

The information we obtain from our use will not usually contain your personal data.

Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not identify you personally.

Our Online Services should display a notice alerting you to this use and requesting your acceptance. If you accept, you will be accepting our use of the Analytics or similar technologies for the purposes described in this privacy policy.

Please note that if you choose to disable Analytics on your device you may be unable to make full use of our Online Services.

“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 Services, including in the following ways. Where you have opted out of cookies the only cookie we will place is one to remember you and that you have opted out.

Cookie Name	Domain	Vendor	Purpose	Category
AWSELB	app.hubspot.com	Amazon	AWS Elastic Load Balancer	Performance
Facebook Pixel	Facebook.com	Facebook	Marketing	Targeting
__utma	hubspot.com	Google	Google Analytics	Targeting
__utmb	hubspot.com	Google	Google Analytics	Targeting
__utmc	hubspot.com	Google	Google Analytics	Targeting
__utmz	hubspot.com	Google	Google Analytics	Targeting
_gauges_unique_hour	hubspot.com	Gauges	Gauges Analytics	Performance
_gauges_unique_day	hubspot.com	Gauges	Gauges Analytics	Performance
_gauges_unique_month	hubspot.com	Gauges	Gauges Analytics	Performance
_gauges_unique_year	hubspot.com	Gauges	Gauges Analytics	Performance
_gauges_unique	hubspot.com	Gauges	Gauges Analytics	Performance
apex__product	hubspot.com	Salesforce	Salesforce Analytics	Strictly Necessary
__hstc	hubspot.com	HubSpot	HubSpot Analytics	Targeting
__hssrc	hubspot.com	HubSpot	HubSpot Analytics	Targeting
__hssc	hubspot.com	HubSpot	HubSpot Analytics	Targeting
hsPagesViewedThisSession	hubspot.com	HubSpot	HubSpot Analytics	Strictly Necessary
hubspotutk	hubspot.com	HubSpot	HubSpot Analytics	Strictly Necessary
hubspot.hub.id	hubspot.com	HubSpot	HubSpot Authentication	Strictly Necessary
hubspotauth	hubspot.com	HubSpot	HubSpot Authentication	Strictly Necessary
hubspotauthcms	hubspot.com	HubSpot	HubSpot Authentication	Strictly Necessary
hubspotauthremember	hubspot.com	HubSpot	HubSpot Authentication	Functionality
_hs_opt_out	hubspot.com	HubSpot	Opt out of HubSpot tracking	Strictly Necessary
hubspotutktzo	academy.hubspot.com	HubSpot	Time Zone Offset	Functionality
__hluid	hubspot.com	HubSpot	In-app usage tracking	Targeting
mp_id_mixpanel	hubspot.com	Mixpanel	In-app usage tracking	Targeting
__cfduid	hubspot.com	Cloudflare	Detection of malicious actors	Strictly Necessary
__cfruid	hubspot.com	Cloudflare	Rate limiting policies	Strictly Necessary

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 Oculus account, your PlayStation Network account, your HTC 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 we 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 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.

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 Mailchimp. You can find out more about how they process personal data here: https://mailchimp.com/legal/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 Coop, 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. 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://oo.apple.com

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 info@coopinnovations.co.uk or by checking boxes on the forms we use to collect your data.

6. 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 info@coopinnovations.co.uk

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.

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 Coop 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.

7. 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.

8. 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 info@coopinnovations.co.uk

9. 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.

10. 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 Coop at info@coopinnovations.co.uk. We will endeavour to respond to any query or questions within two business days.