Last updated: 06 October 2021
What personal information we collect and how we use it
The personal information we collect about you broadly falls into the following categories:
- Information that you provide voluntarily
Certain parts of our Site may ask you to provide personal information voluntarily. For example, we collect information from you when you enter and submit your information on our Site to contact us. Your personal data we process includes:
- Your contact details (name and email address); and
- Any other personal information you share with us when you contact us through the Site.
We process this personal information to communicate with you, deal with your request, including sending communication directly to you.
- Information that we collect automatically
When you visit the Site, we may collect certain information automatically from your device. Specifically, we collect your device details, such as your IP address. We may also collect your device type, unique device identification numbers, browser, device location, and other technical information including how your device has interacted with the Site, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Site, where they come from and what content on the Site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site to visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading "Cookies and similar tracking technology" below.
- Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
Who we share your personal information with
We do not disclose, sell, exchange, transfer or give your personal data to a third party outside of Devolver without your consent or another valid legal basis. We may disclose your personal information to the following categories of recipients:
- to our group companies;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend our legal rights; or (iii) to protect your vital interests or those of another person;
- to any other person with your consent to the disclosure.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need your personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests, this interest will normally be to operate our Site and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, or improving our Site. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the details set out in the "Contact Us" section of the Site.
Cookies and similar tracking technology
Most modern web browsers give you the option to send a Do Not Track signal to the sites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a site should respond to this signal, and we do not take any action in response to this signal.
Third party sites
We may include links to or widgets from other third party products or services on our website. These third party sites have separate and independent privacy policies. We have no control, responsibility or liability for the content and activities resulting from use of any linked sites, and we encourage you to read the privacy policies on any such third party sites, and proceed only if you are comfortable with such terms.
The security of your personal information is important to us; however, no method of transmission over the Internet, or method of electronic storage is 100% secure. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
We will retain your information as needed to provide you the requested services or where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements as well as to resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
International data transfers
Your personal information may be transferred to, stored or processed in the United States or another host country other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our Site servers are located in Europe, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
Data protection rights
Depending on the context and your country or state of residence, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the details set out in the "Contact Us" section of the Site.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to opt-out of the "sale" of your personal information to "third parties" at any time. As discussed above, we disclose information with certain third parties for the purposes described above. We do not believe that our disclosure in this regard would qualify as a sale, as we do not provide personal information to third parties for monetary or other valuable consideration. Nonetheless, if you are a California or a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt-out by emailing us at the contact address provided below.
- You have the right to be notified of any financial incentives and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without your prior informed opt-in consent. We do not offer any such incentives at this time.
- You have the right to non-discrimination for the exercise of your data protection rights. We will not discriminate against you for exercising any of these rights.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the UK Information Commissioner's Office (ICO) whose details are available here.
- California law also permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.
You can also authorize an agent to submit a request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Where you use an agent, we will ask for verification of your authorization, namely a copy of your written authorization for the agent to submit the request on your behalf.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
If you have any questions or concerns about our use of your personal information, please contact firstname.lastname@example.org or write to 211 E. 7th Street, Suite 620 Austin, TX 78748.
The legal entity responsible for the handling of your personal information is Devolver Digital Inc. Other entities within the Devolver group may also be responsible for your personal information, depending on your location and the type of product or service provided.