Privacy Policy

Privacy Statement version 1

Date of issue: 21 May 2018

Privacy Statement

Ninja Theory Limited (“We”) are committed to ensuring that your privacy is protected. This privacy policy sets out how we use and protect information that you give to us when you use any of our websites. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of this privacy policy, the data controller is:

Ninja Theory Limited of Suite 20, Building 5 Westbrook Centre, Milton Road, Cambridge CB4 1YG.

Ninja Theory may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

Websites to which this policy applies:

Ninjatheory.com

Store.ninjatheory.com

Senuastudio.com

Hellblade.com

Data protection compliance

Personal information we collect from you is processed in accordance with the General Data Protection Regulation (“GDPR”), a European Union Regulation which regulates the processing of personal data in the UK and the EU. In accordance with guidance from the Information Commissioner’s Office, we are registered as a ‘data controller’ and comply with UK data protection and privacy law.

This website is targeted at a UK users, but if you choose to use our services from outside the UK, you do so with the understanding that personal information will be collected, stored and used in accordance with the GDPR.

Information we collect from you

We will collect and process the following data about you:

• Information you give us.
  • This is information about you that you give us by filling in forms on the website, or by corresponding with us in any other way, including but not limited to the email addresses on the ‘Contact Us’ or ‘Careers’ pages. This information will typically include your name, email address and other contact information required by us to respond to your query.
  • If you contact us in response to a job vacancy listed on this website you will be asked to provide us with the information contained in the application. Our use of your personal data in this context is subject to additional privacy obligations contained in our Candidate Statement.

Where we collection other types or categories of personal data from you, these will be subject to first obtaining your consent at the point of collection.

• Information we collect about you.

When you use any of our websites we will automatically collect the following information:

• technical information, including your Internet protocol (IP) address and browser type;
• where you are on the internet – for example, the URL that you came to our website from and where you go after you’ve been on our website;
• the pages that you view on our websites any terms that you search for within the website;
• your location data. Determination of your location is approximate and is not intended to pinpoint your location exactly, but provides us with analytics on where our users visit our website from.

It is in our legitimate interests to collect this information in order to provide and run the website for you to use and to troubleshoot errors.

Information we receive from other sources.

This is information we receive about you from third party service providers who provide us with analytics services on this website.

Other Cookies and Tracking Technologies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

On occasion, we may gather information about your computer for our services, and to provide statistical information regarding the use of our Website to our partners. Such information will not identify you personally, it is statistical data about our visitors and their use of our site. This statistical data does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with the Website so that we can continue to develop and improve this Website.

We may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You have the ability to decline or block cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies (including essential cookies), you may be unable to access all or particular areas of our Website.

What we use your data for

Personal Data which you provide to us, and any other data which, when combined with other data we hold about you could be used to identify you, are held by us securely and in accordance with the GDPR.  We will only use the data we collect from you on our websites for the following purposes which we believe represent our legitimate interests in providing our website and services to you:

• To provide our websites and their content to you
• To effectively administer the websites
• To provide and deliver game content to you
• To ensure the proper use of our games on the platforms you play on;
• For security, anti-cheat and moderation purposes
• For fulfilling your orders from the Ninja Store
• To contact you about your order from the Ninja Store
• For statistical analysis to allow us to improve this website and the user experience
• If you consent, to send you emails and newsletters related to products and services which may be of interest to you.
• Identify, fix, and troubleshoot bugs and service errors;

We will not contact you by telephone, e-mail or in writing except for the purposes set out above and you confirm that you do not and will not consider any of the above as being a breach of any of your rights under the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Emails and Newsletters

If you wish to sign up for newsletters and other communication from us you will be asked to provide your consent to receive these communications at the time your register for them.

If you no longer wish to be contacted by us, you may unsubscribe from email communications at any time by clicking the link at the end of the email or by emailing us directly at privacy@ninjatheory.com.

Competitions

From time to time we may run competitions or free prize draws through this website or our social media pages. When entering any of our competitions or prize draws, you will be asked to provide your name, email address and postal address. If you win, we will send the prize to the address entered and notify you by email. When you enter a competition or prize draw, you may also be asked if you want to be included in our newsletter list to receive notice of promotions, specials and new additions to the Website. If you wish to be included in these mailing you should indicate your consent by ticking the relevant box to accept.

Typically you must be 16 years old and over in order to participate in our competitions and free prize draws.

You may unsubscribe from these mailings by following the unsubscribe instructions in any email received.

What we will not do with your data

Except as set out in this notice, we will not share or sell your personal information with any third parties, unless required to by law.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. We cannot therefore be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Our Games

There is a distinction between the games that we publish ourselves (Dexed, Hellblade) and the games that we develop for a publisher (DMC: Devil May Cry, Heavenly Sword).

Games that we develop for a publisher will be covered by the publishers own privacy policy (usually available from their website, which will be listed in the documentation supplied with the game).

Games that we publish ourselves will be covered by this policy and an additional in-game policy.

Our games may make use of 3rd party analytics tools in order to analyse how people play or third parties which provide a range of services such as performing matching in multiplayer games or matching you with the servers that will give you the fastest connection speed to the game. The data we receive from these analytics platforms does not allow us to identify you personally.  Further information on these may be found in the in-game terms and conditions and privacy policy.

Careers

When you apply for a vacancy advertised on our website, or make a speculative application – or if you inquire about one of our internship roles then we will store personal details (including any CV that you may send us).  While we won’t pass this information to any third party, it may be stored on external systems. It is in our legitimate interest to collect and process your personal data for the purpose of registering and processing your application.

A copy of our candidate privacy policy may be found here Candidate Privacy notice May 2018.

The Ninja Store

We work with a third party provider to deliver the Ninja Store to you.  The Ninja Store (store.ninjatheory.com) is powered by Shopify who are responsible for taking your order and completing the transaction.  In order to provide you with transaction services Shopify will collect your name, email address, shipping and billing address, payment details, company name (if applicable), phone number, IP address and device data.

They need this information to provide you and us with their services which include supporting and processing orders, authentication, and processing payments. Shopify will also use this information to improve their services more generally. You can access Shopify’s Privacy Policy here https://www.shopify.com/legal/privacy

Your information is collected when you use or access the Ninja Store, place an order or sign up for an account on the Ninja Store.

We are responsible for despatch of your order, and will receive your name, shipping address, contact number and email in order to send you your goods and in case we need to contact you about your order.  We will not receive any payment card data.

Your personal data received by us from the Ninja Store will be kept by us only for as long as is required by us to despatch your order and for a period of 6 years thereafter in case we need to manage any problems with your order.

Notes for Parents

This website is aimed at users over the age of 13. We strongly advise parents to instruct their children never to divulge personal information (real name, address, date of birth or telephone number) to anyone whilst they are online without first speaking to a parent. Ninja Theory are committed to never knowingly storing the personal information of anyone aged 13 or under without parental consent. If you believe that your child is participating in an activity that collects personal information and you or another parent/guardian haven’t been sent a notice seeking your consent, please contact us at privacy@ninjatheory.com. We will not use your email address provided for parental consent purposes to send you marketing communications or newsletters, unless you have expressly opted in to receive these.

If you are a child aged under 13 you should ask a parent or guardian to read this privacy policy for you and to contact us (via privacy@ninjatheory.com) if they would like any further information or guidance.

Children under the age of 13 who wish to make contact with us directly via one of the email addresses listed on this website should do so through their parent or guardian. We reserve the right to delete communications from people we consider in our absolute discretion to be below this age.  If we do respond to a question or request from a child, we will delete their information immediately after responding to them.

Suppliers, Business Partners and Press Contacts

This policy also applies to our suppliers and business partners as well as members of the press with whom we communicate from time to time about our company and games. When you provide us with your personal data we will only process your personal data where it is necessary for the following purposes:

• Performance of the contract between us or where we necessary to facilitate discussions between us prior to contract;
• Communications related to the business relationship between us;
• Credit worthiness and/or credit control purposes;
• Payment and transaction records;
• Maintaining an up to date database of our suppliers and business partners; and
• Contract management and record keeping;

We believe that these uses are in our legitimate interest for the purposes of performing, maintaining and keeping appropriate records of the contracts and communications between us.

If you no longer wish to receive communications from us you may opt out by contacting us at privacy@ninjatheory.com

Where we store your personal data

All information you provide to us is stored on secure servers which are accessible only to those who have a specific need to have access to that data.  We are committed to securing all data held by us with appropriate technical and organisational measures to prevent unauthorised disclosure of personal data.

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 to our site; any transmission is at your own risk. Once we have received your information, we and our third party suppliers will use strict procedures and security features to try to prevent unauthorised access.

How long your data are kept

All data which you provide to us through the website will only be used by us for the purposes of providing the website, the Ninja Store, email marketing you may subscribe to and any communications you enter into with us.

Your personal data will be stored only for the period necessary for the specified processing purposes. After such period has elapsed, your personal data may be kept in a form which no longer permits identification (anonymisation), or solely for statistical purposes with appropriate technical and organisational security measures.

Where possible, analytics data will be anonymised and stored to form part of our ongoing performance of the website and the services linked to it.

Your rights

We will only use your personal data for the purposes set out in this privacy policy and other services for which you give your consent for us to process your personal data (for example email newsletters).

You can exercise your right to prevent further processing of your personal data by contacting us at the address below.

At any time you have the right to:

• request access to, deletion of or correction of, your personal data by contacting us at the address below; or
• request restriction of processing which you are concerned with;
• object to processing of your personal data; and
• ‘data portability’ which is the right to both request your personal data to be transferred to another person and/or to receive copies of your personal data in a structured, commonly used format. To do this you will need to contact at the address below and provide us with such details as we will need to effect this transfer.

Please address your requests to either:

privacy@ninjatheory.com

or

Data Protection, Ninja Theory Limited, Suite 20, Building 5, Westbrook Centre, Milton Road, Cambridge CB4 1YG.

In order to safeguard your personal data from unauthorised access, if you choose to exercise your rights above you may be asked to confirm your identity to us before we will release your personal data.

Please note that we are entitled to charge a small fee in order to respond to your request to meet our costs in providing you with details of the information we hold about you.

If you feel that we have not complied with our responsibility to you and your personal data, you may complain to the relevant information supervisory authority. In the UK you should contact the Office of the Information Commissioner.