Privacy Policy

Robot Virtual Games Consumer Privacy Policy

A Robot Virtual Games Company

Updated: April 21, 2021

Robot Virtual Games (“we”, “us”, “our”) is a leading e-competition platform. This Privacy Policy explains what personal information Robot Virtual Games company collect, use, share and otherwise process about individuals (“you”) interacting with our Offerings (“Information”).

The Robot Virtual Games is a joint venture of Cogmation Robotics Inc. and International STEM Education Inc.. In this Privacy Policy, the “Controller” of your Information means the company that decides the purposes for which it is processed and how it is processed. Robot Virtual Games company is the Controller in relation to the processing of your Information.

Under the laws of some countries outside the European Economic Area, we may need your consent to our processing of your Information set forth in this Privacy Policy. Subject to any indications you may give us to the contrary, such as opting out or not opting in if asked, and where permitted by law, by providing Information or otherwise interacting with our Offerings, you consent to our use of Information in accordance with this Privacy Policy.

Scope of this Privacy Policy

Please read this policy carefully. It explains the types of Information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, your rights and how to contact us. This Privacy Policy covers our online data processing activities, including Information that we collect through:

  • Robot Virtual Games website, including activities run through our websites, such as surveys, research studies, focus group tests, promotions, competitions and prize-draws, purchases within our services, calls to action for user-generated content (“UGC”) and subscribing for newsletters;
  • Our fan pages/channels/accounts, our social networks (e.g. official pages on Facebook, Instagram, Twitter).

Please note that we may combine Information that we collect via one source (e.g. a Robot Virtual Games website) with Information we collect via another source (social media platforms).

The Information We Collect

We collect, use, share and otherwise process the following categories of Information:

1) Information we may collect from you:

  • Registration, account, and sign-up Information, including information about you when you register or sign up with us (e.g. name, username, password, email, contact details, date of birth or age, interest in our content, etc.)
  • Information about your participation in tournaments, competitions, games, practice mats, or any type of interaction with you, using your virtual robotics toolkit on any of the aforementioned events.
  • Information about your use of, or participation in an Offering, including information about whether you have opened an email we have sent you, how you (including any account you use) interact with a Digital Service, content that you have viewed or posted, advertisements you have interacted with, games you have played and the level you reached, your preferences and interest in and use of various features, programs, services and content available on a Digital Service. This may also include demographic information, including at an individual or household level.
  • Information you provide when participating in consumer surveys, research studies or focus group tests, including online or written replies and where applicable the recording of your audio or video interviews.
  • Entries to promotions, competitions, prize-draws or calls to action, including images, videos and text.
  • Information shared on Robot Virtual Games public or community forums, including where you share photos, letters, videos or comments, while participating in online forums. Depending on your privacy settings, this Information or content and your username may become public on the Internet or within a community of users. We cannot prevent further use of this Information once you share it in a publicly available or community forum. Please refer to the specific forum’s privacy policies for further information on how they handle your Information.
  • Information about your location, including where it is derived from device information (such as an IP address or country code), your device’s interactions with our Digital Services, or, with your consent, Information about your device’s precise location (e.g. geolocation via mobile devices).
  • Technical/usage Information from your device, including the type of device, browser, unique device identifier, operating system, internet provider, mobile device identifier and/or mobile advertising identifier, connected device identifier (including that of a connected television), IP address, network attributes, television device and application attributes and settings, and other device or browser attributes and settings.
  • Information about your customer queries, including when you contact us through one of our customer helpdesks, email addresses, customer service chat boxes, forms or ticketing systems, Social Media Sites and customer call-centres, where calls may be recorded.

How We Use the Information

We may use Information for the purposes described in this Privacy Policy, or as otherwise disclosed at the time of collection. Below, we explain our various purposes, any processing activities that we believe may need further explanation and, where necessary, the ‘lawful basis’ on which we rely to process your Information.

Please note that while Information may be processed for more than one purpose (e.g. Information we obtain when Providing Our Offering may also be used for Improving and Developing Our Offering and/or for Marketing and Personalized Advertising), not all of the purposes or processing activities below will necessarily apply in every case. Our particular use of your Information will depend on the Offering you engage with and the manner in which you interact with us, including the permissions you give us (e.g. whether or not you consent to certain uses, such as direct marketing) and other controls you exercise regarding our processing of your Information (e.g. whether or not you choose to opt-out, where this is offered).

Providing Our Offerings

We may use your Information for the purpose of setting up your account with us, registering you for an Offering, enabling you to pay for it, providing the Offering, allowing you to participate in a promotion, competition, prize-draw or a call to action to submit UGC, or maintaining the Offering and resolving any issues.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

  • Much of our processing, such as providing, and maintaining our Offerings, is necessary for entering into, or the performance of, the contract we have with you, including enabling new customers to sign-up or register with us and existing customers to log-in to our Digital Services.
  • Other types of processing are necessary for our ‘legitimate interests’ (and those of others), including:
  • Running our business, providing our Offerings and serving our customers;
  • Contacting customers with important notices or updates;
  • Contacting customers about their transactions, purchases and competition wins;
  • Personalizing content and making recommendations for other content;
  • Exercising and/or enforcing the rights granted to us under the terms and conditions of the Offering;
  • Facilitating payment for our Offerings.
  • For other types of processing we may rely on your consent (where given).
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Improving and Developing Our Offerings

We may use your Information for the purpose of analyzing, improving, personalizing and evaluating our Offerings and your use of them, as well as to develop new Offerings. This may include analyzing your responses to consumer surveys.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

  • Some types of processing are necessary for our ‘legitimate interests’ (and those of others), including:
  • Improving and developing our Offerings.
  • Creating efficiencies in our business.
  • Understanding consumer trends and interests, including through customer insights, market research, and measurement of content performance.
  • Compiling statistics about the use of our Offerings.
  • For other types of processing we may rely on your consent (where given).

Marketing and Personalized Advertising

We may use your Information for the purpose of marketing and/or advertising our Offerings and those of our clients and partners. Robot Virtual Games uses AdTech technologies, such as real-time bidding, to monetize advertising space within its Digital Services and/or to create a ‘profile’ based on Information about your interactions with us, including our Offerings, our service providers, and our partners and their websites, apps and online advertising, which is used to provide you with personalized advertising and marketing. We may also aggregate information about users to create groups or categories of users, such as ‘segments’, to communicate with you about our offerings and let you know about our clients’ and partners’ offerings, including on Social Media Sites.

While processing of your Information for this purpose may involve an algorithm automatically selecting advertising which is intended to be of interest to you, we do not make fully-automated decisions that may have a legal or significant effect on you without either your explicit consent, or where otherwise permitted by applicable law.

We may also use UGC for marketing or advertising purposes, subject to the relevant terms and conditions of the Offering.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

  • To use UGC you have submitted, we will rely on the rights granted to us under the terms and conditions of the Offering and the performance of our contract with you.
  • Other types of processing for Marketing and Personalized Advertising are necessary for our legitimate interests (or those of others), including:
  • Furthering our commercial interests by marketing and advertising Our Offerings, including engaging in contextual (non-data driven) advertising, analytics, and measurement of ad performance;
  • Expanding our customer base by deepening relationships with existing customers and developing new customers;
  • Using UGC you have submitted (unless it is not necessary for the performance of a contract with you or we are able to ask for your consent); and,
  • Promoting the Robot Virtual Games brand both online and offline.
  • In certain jurisdictions, for certain types of processing, such as interest-based advertising or where we send direct marketing communications by email, text message or SMS, messages on Social Media Sites, we rely on your consent (where given).

Providing Customer Services

We may use your Information for the purpose of providing Customer Services, including dealing with your queries and complaints (including troubleshooting), whether you contact us by telephone, email, chat boxes, forms or ticketing services, letter, website or via a Social Media Site.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

  • Some types of processing activities will be necessary for us to perform our contract with you to provide an Offering.
  • Some types of processing activities will be necessary to comply with our legal obligations.
  • Some types of processing will be necessary for our legitimate interests (or those of others), including:
  • Responding to our customer queries and complaints;
  • Tracking the progress and effectiveness of our response; and
  • Improving our Customer Services.

Detecting, preventing and investigating criminal and other illegal activities

We may use your Information for the purpose of detecting, preventing or investigating criminal activities (including fraud and copyright infringement), protecting user safety and enforcing our civil rights in the courts. For example, where necessary, we may share your Information with law enforcement bodies or use it to take legal action against you to enforce our rights.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

  • Some types of processing activities will be necessary to comply with our legal obligations.
  • Some types of processing will be necessary for our legitimate interests (or those of others), including:
  • Protecting our business interests and rights, privacy, safety and property, or that of our customers and users;
  • Establishing, exercising or defending legal claims;
  • Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain.

Compliance with legal obligations

We may use your Information for the purpose of complying with our legal obligations, including accounting rules, responding to Individual Rights Requests and responding to requests from regulators, judicial authorities and law enforcement or governmental bodies.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

  • These types of activities are necessary to comply with our legal obligations.

Data Retention

In broad terms, we will only retain your Information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of Information and the reason that we have collected the Information in the first place. For example, some Information related to the provision of our Offerings to you will be kept for a number of years in order to comply with various finance and tax related legal obligations. We have detailed internal retention policies that set out the various retention periods for different categories of Information, depending on our legal obligations and whether there is a commercial need to retain the Information. After a retention period has lapsed, the Information is securely deleted, unless it is necessary for the establishment, exercise or defence of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.

Individual Rights Requests

Under certain conditions, you have the right to ask us to fulfil one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.

  • Right to access and rectification: You can request details of the Information we hold, along with a copy of your Information, and the correction of any errors in your Information.
  • Right to erasure (“right to be forgotten”): The right, in certain circumstances, to ask for your Information to be deleted. In specific cases, we may not be able to delete some types of Information, in particular, where we have a legal obligation to keep that Information (e.g. for regulatory reporting purposes) or, for example, where you want us to continue to provide you with an Offering and the processing of the Information is necessary for the provision of that Offering.
  • Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes.
  • Right to portability: The right in some cases to receive your Information in a digital format or to have it transmitted directly to another controller (where technically feasible).
  • Right to object: The right to object (on grounds relating to your particular situation) to the processing of your Information on the basis of our legitimate interests, including for direct marketing purposes.
  • Right to withdraw consent: You can withdraw your consent at any time in respect of any processing of Information which is based upon a consent.

We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer.

Cookies and Other Technical Information

When you visit our Digital Services, we, third party service providers, and partners may use "cookies" or similar technologies, such as pixels and SDKs to (i) provide, develop, maintain, personalize, protect, and improve our Digital Services and their content (ii) perform analytics, including to analyse and report on usage and performance of our Digital Services and any advertisements displayed on or delivered by or through them (iii) protect against, identify, and prevent fraud and other unlawful activity (iv) create aggregate data about groups or categories of our users (including advertising audiences), and (v) for us, our partners and third party service providers to deliver, target, offer, market, or personalise advertising relating to our Offerings or the offerings of our clients and partners (including limiting how often you see an advertisement).

Cookie Description

1. Required cookies

These cookies are required to enable core website functionality

Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our Digital Services and use their features, such as accessing secure areas. If you disable these cookies, some or all of the Digital Services’ features may not work.

2. Performance cookies

These cookies allow us to analyze usage of our Digital Services so we can measure and improve performance.

Performance cookies or similar technologies: They collect information about how you use our Digital Services, so that we can analyze traffic, understand users’ interactions, and improve the relevant Digital Service. Our emails and newsletters may contain a ’web pixel’ to let us know how you have interacted with what we have sent you. For games, these technologies collect information about your gameplay, including accomplishments, use of features and other in-game activities. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. You can find out more information by clicking on the Google Analytics cookies usage resource link: https://tools.google.com/dlpage/gaoptout?hl=en

3. Functionality cookies

Functionality cookies or similar technologies: These allow our Digital Services to remember choices you make (such as your username or the region you are in) and provide enhanced, more personalized features, including personalized content. They may also be used to provide Digital Services you have asked for, such as watching a video or commenting on a blog.

4. Advertising cookies

These cookies are used by advertising companies to serve ads that are relevant to your interests.

Social media cookies or similar technologies: These are used when you share Information using a social media sharing button or ‘like’ button via our Digital Services, or when you link your account or engage with our content on or through a Social Media Site, such as Facebook or Twitter. The Social Media Site will record that you have done this, and this Information may be linked to targeting/advertising activities, including building custom audiences.

Managing cookies and other technologies. For Digital Services in some jurisdictions, including the EEA, you may learn more information about our use of cookies and other technologies, and provide or withdraw consents, or set your cookie preferences and in some cases object legitimate interest purposes for processing your personal information, by clicking Manage Cookies+ or otherwise adjusting cookie preferences. These settings are accessible on a site or app specific basis, at any time through the ‘Manage Cookies+’ link or a similar link located on webpages or in application settings. You may also use your app/browser settings to set your cookie preferences.

Marketing communications. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences, you can (i) log in to an account you may have created with us to adjust your settings (where the feature is available) or (ii) otherwise submit a request by contacting our Data Protection Officer. You can also follow the ’unsubscribe’ instructions provided in any marketing email you receive.

Ad choices. On our own or working with affiliates or third parties, we may present advertisements and engage in data collection, reporting, ad response measurement, and site analytics on our Digital Services and on third party websites across the Internet and applications over time. We, our affiliates, or third parties may use cookies, web beacons, pixels, SDKs, or similar technologies to perform this activity. They obtain information about applications you use, websites you visit, and other information from across your devices and browsers and across websites, services, and apps over time, in order to help serve advertising that will be more relevant to your interests on and off our Digital Services and across your devices and browsers. This type of advertising is known as ‘interest-based advertising’. We, our affiliates, or third parties may also use this information to associate your different browsers and devices together for interest-based advertising and for other purposes like research, analytics, internal operations, fraud prevention, and enhancing consumer experiences.

Precise location information. To enable or disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection. You may also limit the collection of precise location information from websites through browser settings.

International Transfer

We operate internationally, and some of the processes involved in our use of your Information will require your Information to be stored or processed in countries outside the country where you are located, including countries where the level of legal protection for your Information may be different and where you may have fewer legal rights in relation to it. In particular, your Information may be transferred to, and processed in the United States, where some of our systems are located.

However, whenever we transfer your Information outside of a country or region, such as the European Economic Area, we will make sure that we take steps necessary to comply with applicable legal requirements. Therefore, where required, we will ensure that appropriate safeguards are in place by using appropriate contractual mechanisms, such as the EU Standard Contractual Clauses, or by relying upon the service providers participating in an approved international data transfer mechanism, including the adoption of Binding Corporate Rules.

Notification Regarding Updates

From time to time, we may update this Privacy Policy. We will notify you about any material changes by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you are up to date.

How to Contact Us

If you have any questions about this Privacy Policy, you can contact us and our Data Protection Officer at priyanka@cogmation.com

Complaints

If you are unhappy with how we have dealt with your query, in the first instance please contact us at priyanka@cogmation.com. If you are still unhappy with our response, you may have the right to complain to your Data Protection Authority. Please contact us at priyanka@cogmation.com to obtain details of how to contact them.