Privacy Policy

Effective: May 25, 2018

Against Gravity Corp., a Delaware corporation (“we”, “our”, and their derivatives) provides the websites, http://www.againstgrav.com, https://recroom.azurewebsites.net, and http://www.rec.net and the subdomains of each of the foregoing (collectively, the "Website") and the Rec Room® video game (the “Game” and, with the Website, the “Services”).

This privacy policy sets forth our policy about what information we collect from users when they use the Services and how we use, maintain, and disclose such information. This privacy policy does not apply to other websites or services not operated or controlled by us. Under applicable law, Against Gravity Corp. is the “data controller” of personal data collected through the Services.

Please read this privacy policy carefully to understand our practices regarding the collection and treatment of your information. Do not use the Services unless you consent to our collection, maintenance and use of your information as described in this privacy policy.

For our data collection practices regarding children, please see the Children’s section later in this privacy policy. 

PERSONAL INFORMATION

We may collect some personal information from you in accordance with this privacy policy and applicable law. The ways in which we collect personal information and our policies governing its maintenance, use, destruction and disclosure are described in this privacy policy. “Personal information” means any information that can be used to personally identify you, such as your name, postal address, email address, telephone number, voice, social security number, IP address, “personal data” (as that term is defined Article 4(1) of the General Data Protection Regulation), other identifiers by which you may be contacted online or offline, and other similar types of information under applicable law. Additionally, “Personal information” may include some non-personal information when it is linked with other types of personal information or non-personal information (e.g., motion sensor information or motion tracker information).

HOW WE COLLECT YOUR INFORMATION

When you use the Services, we may collect information from you in the following ways:

Information from Third Party Game Platforms. We may automatically receive your personal information from the platform through which you downloaded and play the Game. Personal Information collected by the third-party platform that you use to access the Game is subject to the applicable third-party terms of use and/or privacy policy (for more information, please see the Oculus Privacy Policy, Steam Privacy Policy Agreement and/or Playstation.com Privacy Policy, as applicable). For instance, when you first play the Game using Playstation VR, information associated with your Playstation Network account (including your PSN Online ID) will automatically be transmitted to us, with no action on your part.  Our use of your personal information collected through the Game is limited to the purposes described in the “How We Use Your Information” section below. 

For users under the age of 13 (“Children Users”), we may remove or anonymize the personal information we obtain from the third party platform, or gain prior verifiable consent from a parent or legal guardian (“Parents”) before collecting and storing such information.  See the Children’s section later in this privacy policy for further details regarding our data collection practices for Children Users.

Registration. If you “register” an account with us, you will be required to provide personal information. To register, you may be prompted to provide us with your age or date of birth, email address, your phone number, a password, a unique username, and a display name through our Website. When you register, we will send you an email to verify your email address and complete the registration process. Users should not pick a password that is easy to guess and should not share their password. The registration process for Children Users may be different than the description above (see Children’s section below).  

Direct communications with us. If you send us or one of our representatives an email or otherwise correspond with us directly, we will have access to any information that you provide to us in such correspondence. Our Terms of Service (available at https://www.againstgrav.com/terms-of-service/)(the “Terms of Service”) also govern our use of and ownership of information that you provide to us in direct communications.

Game crash. If the Game crashes during play, we may ask you to provide us with information that may be personal information through an opt-in process. This information may include (1) running/loaded DLLs on your personal computer; (2) your username when using your personal computer; and (3) data gathered from a “small memory dump.” 

Revealing personal information through the Game. You may choose to reveal personal information in the Game through multiplayer chat or other public functions, including through your username, to the extent it contains personal information. In addition to being accessible to other users of the Game with whom you are interacting, we may also capture this information using recording functions that we use to monitor users’ activity in the game. We cannot control how other users will use personal information that you reveal using multiplayer chat or other public functions, so, if you reveal personal information through multiplayer chat or other public functions, you are doing so at your own risk. Similarly, users must not create a username that reflects their own real name or reveals personal information. If you include personal information in your display name, you are doing so at your own risk. Note that the multiplayer chat or public functions described above may be disabled for Children Users. 

Cookies. We may use cookies in connection with automatic data collection through the Website. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you access the Website.

WHERE INFORMATION IS PROCESSED

We’re based in the United States of America. All information that you provide to us is stored on secured servers located in the United States of America using firewalls. No matter where you are, you consent to the processing and transferring of your information, including personal information, in and to the United States of America and other countries. Laws that apply to the collection, maintenance and use of information in the United States of America (or any other country) may not be as comprehensive or strict as the laws of the country where you’re located.

OUR BASES FOR HANDLING YOUR PERSONAL DATA

Some jurisdictions may require us to describe our legal bases for using or disclosing personal data that we may possess. Where such laws apply, our legal bases for processing personal data are as follows:

  • Fulfillment of any purpose for which you have provided your consent;
  • Compliance with applicable law;
  • Exercise of our legitimate interests in:
    • Endeavoring to provide a safe and fun experience for everyone that plays the Game;
    • Responding to customer service inquiries and providing customer service;
    • Making the Game better and improving our business overall;
    • Reviewing job applications; and
    • Addressing legal issues.
  • Fulfillment of our contractual obligations to users of the Game; and
  • Working to protect you and other users.

HOW WE USE YOUR INFORMATION

Our policy is to use your information in a way that is consistent with and subject to this privacy policy.

Where you’ve provided information to us for a specific purpose (e.g., to help us troubleshoot an issue you’re having with the Service), we’ll use your information in furtherance of that purpose. We do not use automated decision-making in connection with the processing of your information, except to the extent necessary for age-gating functions.

We, including our affiliates and subsidiaries, may also use your personal information:

  • To offer, operate, maintain, and improve the Services;
  • To present the Services to you;
  • To operate all features within the Services;
  • To investigate violations of our Terms of Service and attempt to prevent additional violations;
  • To provide you with notices about your registration;
  • To notify you about changes to the Services or any of our related products or services;
  • For purposes of age verification; and
  • For any other purpose with your consent.

Also, where you have given us permission to do so, we may use your information to send you news and updates about our products or services, including special offers and promotions. When we send you news or updates, we’ll also tell you how to opt out of receiving such notices.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not share or otherwise disclose your personal information with or to third parties except:

  • With your consent;
  • As may be necessary to protect your safety or the safety of other users;
  • To our affiliates and subsidiaries, to the extent consistent with this privacy policy;
  • To our lawyers, consultants, accountants, business advisors and similar third parties who owe us duties of confidentiality;
  • In the event of a sale, merger, reorganization, bankruptcy, dissolution or other similar event, where the information of users is among the assets to be transferred;
  • To enable us to take precautions against liability;
  • To protect the safety and security of the Services;
  • Where required to do so by law or legal process; or
  • Where it is in aggregated and/or non-personally identifiable form.

CHILDREN UNDER THE AGE OF 13

This section notifies Parents of our practices with respect to the collection of personal information from children under the age of 13 (“Children”) and the use and disclosure of such information. This section only applies to Children and supplements the other provisions of this privacy policy. 

Junior Mode. If a user of the Game self-identifies or is identified by us as being under the age of 13, their gameplay experience will automatically be set as “Junior Mode.” In order to comply with the Children's Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”), users in “Junior Mode” (“Junior Users” and each a “Junior User”) may have access to fewer features of the Game than non-Junior Users. This is designed to limit our access and the access of users of the Services to the personal information of Children. Junior Users are restricted from communicating with or otherwise making their personal information publicly available to other users of the Services. For example, Junior Users are unable to use “whiteboarding” or voice communication functions of the Game, and Junior Users’ display names will be randomized/anonymized. 

Registration. Junior Users may register an account with us using a registration process similar to the one adults go through; however, in compliance with COPPA, Junior Users may first be subject to a parental notice and/or consent process prior to activation of their account. To initiate the registration and/or consent process for a Junior User, we  collect a Parent’s email address, and the Parent is then requested to create a password for their child’s account, as well as supply additional account information and settings. We will automatically generate randomized display names for registered Junior Users.

Use/disclosure. The personal information we collect from/about Children is used to give Children access to certain features of the Game and communicate with a Parent about the child’s registration, including for the purpose of verifying their Child’s information in connection with registration. We do not share or otherwise disclose Children’s Personal Information except (1) as may be necessary to protect the safety of a child, including by disclosing his or her personal information, where appropriate, to law enforcement agencies or for an investigation related to public safety; (2) to enable us to take precautions against liability; (3) to protect the safety and security of the Services; or (4) where required to do so by law or legal process. 

We and the third-party service providers listed below may collect or maintain Children’s Personal Information through the Services.

  • Exit Games GmbH
  • Amplitude, Inc.
  • Google Analytics
  • Microsoft Azure

Please contact us with questions about our service providers’ privacy policies and collection and use practices. Our contact information is set forth below: 

Against Gravity Corp.
87 Wall St.
Seattle, WA 98121
support@againstgrav.com
(314) 635-8471

At any time, Parents may review their Child's Personal Information maintained by us, require us to correct or delete such Personal Information, request that we delete their child's account, and/or refuse to permit us from further collecting or using the child's Personal Information by contacting us using the email address provided above.  To protect Parents’ privacy and security and the privacy and security of Children that use the Services, we may require Parents to take certain steps or provide additional information, which we will keep strictly confidential, to verify a Parent’s identity before we provide any information or make corrections.

DATA SECURITY AND RETENTION

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. When you directly provide us with personal information, including through registration, we will encrypt that information using secure socket layer technology or similar technologies. We may retain data collected from you, including personal information, to support customer service inquiries and prevent repeated violations or suspected violations of the Terms of Service if your account has been banned or your access to the Services has been disabled for any reason. Additionally, content that you create and share publicly with the Rec Room community will be retained by us and may be accessible to other users of Rec Room, even after you stop using the Services. We may retain your information for as long as is necessary and relevant to your use of the Services and our operations, which may include retaining your information beyond the end of your use of the Services. To dispose of personal information, we may anonymize it, delete it or take other measures we deem to be appropriate. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures used in the Services.

DATA SUBJECT RIGHTS

We aspire to respect the privacy rights of all users, regardless of where they live. Accordingly, except as otherwise provided in this privacy policy, we will promptly act on users’ requests that we:

  • Confirm that we have their personal data;
  • Provide them with access to their personal data that we possess, including in portable format;
  • Correct, update or amend their personal data;
  • Delete and “forget” their personal data;
  • Object to our use or disclosure of their personal data; and
  • Limit our processing of their personal information.

Users may withdraw any consent they have provided us to process their personal information. Exercise of any of the rights listed in this section usually doesn’t apply retroactively from the date of the request and doesn’t affect our ability to continue processing information lawfully. Note that the rights enumerated in this section have certain limitations and exceptions under applicable law.

If you’d like to exercise any of the data subject rights described in this section, please reach out to us by email at support@againstgrav.com. To help us process your request more quickly, please put “Exercise of Data Subject Rights Notice” in the subject line of the email, and include an explanation of the right or rights intend to exercise. We may use your personal information to verify your identity before acting on your request.

Lastly, users will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. However, we’d much rather you contact us first, so we can try to address any concerns that you have about our privacy practices.

CHANGES TO PRIVACY POLICY

We may update this privacy policy from time to time, so please review it frequently. We will post any new or updated privacy policy on our Website, make the new privacy policy accessible in Rec Room and attempt to notify you by email using the email address provided to us through the registration process, if applicable. In the event that any changes we make to this privacy policy affect children in a way that requires prior parental consent under COPPA, we will obtain such prior parental consent.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.