Privacy Policy

1. Who we are

ARCONI LTD ("ARCONI", "we", "us", or "our") is the controller responsible for personal data covered by this policy. We are registered in England and Wales under company number 16982238. Our registered office is 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

For privacy questions or requests, contact [email protected].

2. How this policy works

This policy applies to every ARCONI product or service that links to it (the "Services"). It is designed to cover Services with different features, business models, and platforms without suggesting that every Service processes every category of data described below.

Each Service may provide a Service Notice in the game, app, website, store listing, consent screen, or settings. That notice identifies the data and third-party technologies actually used by that Service, important retention periods, age information, and available controls. The Service Notice forms part of this policy and takes priority for that Service if there is a conflict.

We also provide concise, just-in-time explanations where appropriate—for example, before enabling personalised advertising, voice chat, location, camera, contacts, or notifications. A third-party platform or service may process data for its own purposes under its own privacy policy.

3. Personal data we may process

Identity, account, and profile

• Name, display name, account ID, email address, avatar, country, language, age or date of birth, and authentication information.
• Linked platform, storefront, console, social, or identity-provider accounts and the identifiers they make available.
• Parental-consent or age-assurance status where required. We do not retain identity documents longer than necessary unless a Service Notice says otherwise.

Gameplay and service activity

• Progress, saves, achievements, rankings, statistics, inventories, characters, settings, matchmaking, sessions, replays, and interactions with game systems.
• Virtual currencies, items, entitlements, rewards, gifts, trades, auctions, marketplace activity, and fraud or transaction history.
• Guilds, teams, friends, blocks, presence, competitions, playtests, and community participation.

Purchases and commerce

• Products, subscriptions, prices, currency, purchase dates, receipts, refund status, and platform transaction identifiers.
• Payment card or bank details are generally collected by the platform or payment provider rather than ARCONI. If we process payment details directly, the relevant checkout notice will say so.

Communications and user content

• Chat, direct messages, voice communications, posts, names, images, recordings, maps, creations, reviews, reports, support requests, survey answers, and competition entries.
• Moderation decisions, appeals, safety reports, and evidence reasonably needed to investigate conduct.

Device, network, and technical data

• Device type, operating system, browser, app version, language, IP address, approximate location derived from IP, network status, and time zone.
• Cookie, installation, advertising, analytics, platform, and push-notification identifiers where permitted.
• Crash reports, diagnostics, performance, security events, anti-cheat signals, logs, and the date and time of requests.

Potentially sensitive features

A Service may request access to features such as precise location, camera, microphone, photos, contacts, or biometric-enabled platform functions. We only use them for the purpose explained at the point of access and with any permission or consent required by law. A Service does not process these categories merely because they are listed here.

4. Where data comes from

We collect data directly from you, automatically when you use a Service, and from sources such as:

• console, mobile, PC, cloud-gaming, and storefront platforms;
• authentication, social, payment, advertising, analytics, hosting, anti-cheat, and customer-support providers;
• other players, moderators, rights holders, safety organisations, and lawful authorities; and
• public sources where reasonably necessary to protect the Services, investigate fraud, or enforce rights.

The data available to us depends on the Service, your settings, and the relevant third party's rules.

5. Why we use personal data

Where we rely on legitimate interests, we assess the necessity of the processing and its impact on your rights. We do not rely on that basis where your interests or fundamental rights override ours. Where we rely on consent, you may withdraw it at any time without affecting earlier processing.

6. Cookies, SDKs, analytics, and advertising

Services may use cookies, local storage, pixels, APIs, and software development kits (SDKs) for essential operation, preferences, analytics, attribution, fraud prevention, crash reporting, social features, and advertising.

Advertising may be contextual or, where permitted and selected, personalised using information such as advertising identifiers, approximate location, and activity. We request consent for non-essential storage, access, or personalised advertising where required. The relevant consent screen or Service Notice identifies material partners and choices.

You may be able to change choices through the Service, consent screen, browser, device, or platform settings. Resetting an advertising identifier or disabling a technology does not necessarily stop all advertising; it may make ads less personalised. Strictly necessary technologies cannot always be disabled without affecting the Service.

7. When we disclose personal data

We may disclose data to:

• vendors that host, secure, analyse, advertise, moderate, support, process payments, deliver messages, or otherwise operate the Services for us;
• platforms, storefronts, identity providers, payment providers, social features, marketplaces, and trading systems you choose to use;
• other players and the public where a feature is inherently social or public, such as profiles, chat, rankings, creations, trades, and tournaments;
• professional advisers, auditors, insurers, and transaction partners under appropriate duties of confidentiality;
• rights holders, safety organisations, regulators, courts, law enforcement, or others where required by law or reasonably necessary to protect rights and safety; and
• a buyer, investor, or successor in a merger, financing, reorganisation, or sale, subject to appropriate safeguards.

We may share aggregated or de-identified information that does not reasonably identify you. We do not sell personal data for money. Some laws define "sale", "sharing", or targeted advertising more broadly; where applicable, the Service Notice or privacy controls explain how to opt out.

8. International transfers

ARCONI and its providers may process data in countries other than where you live. Where transfer restrictions apply, we use a recognised mechanism such as adequacy regulations or decisions, the UK International Data Transfer Agreement or Addendum, European Commission Standard Contractual Clauses, or another lawful safeguard. Contact us for information about safeguards relevant to your data.

9. Retention and deletion

We keep personal data only as long as reasonably necessary for the purposes described here. Criteria include whether an account or Service is active, the type and sensitivity of the data, user expectations, legal and platform requirements, limitation periods, and the need to prevent fraud, protect players, resolve disputes, and maintain financial records.

Local data may remain until you use an available deletion control, clear app data, or uninstall. Account and gameplay records may remain while an account is active. Chat, trades, moderation, safety, anti-cheat, support, payment, transaction, backup, and legal records may be retained after deletion for a limited period where necessary. We delete or anonymise data when no longer needed. A Service Notice provides material fixed periods where available.

Closing an ARCONI account does not automatically delete data controlled independently by a platform, storefront, payment provider, or social service. Use that provider's controls as well.

10. Children and younger players

The intended age and audience for each Service are identified in its store listing or Service Notice. If children are likely to access a Service, we consider their best interests, provide age-appropriate information and settings, minimise data use, and seek parental authorisation where required.

We do not knowingly use a child's personal data for personalised advertising where prohibited. Parents or guardians who believe a child has provided data contrary to an age requirement should contact us. We will investigate and take appropriate action.

11. Profiling and automated systems

We may use automated systems to support matchmaking, recommendations, content moderation, fraud detection, anti-cheat, advertising, and Service personalisation. These systems may produce flags or recommendations reviewed by people or trigger proportionate in-Service actions.

We do not make solely automated decisions that produce legal or similarly significant effects unless the relevant Service Notice explains the logic, significance, safeguards, and rights available to you.

12. Security

We use technical and organisational measures designed for the nature of the data and the risks involved, including access controls, secure development practices, monitoring, and protections in transit or at rest where appropriate. No system is completely secure. Use unique credentials, protect your devices and accounts, and contact us if you suspect unauthorised access.

13. Your privacy rights

Depending on your location and the circumstances, you may have rights to access, correct, delete, or receive a copy of personal data; restrict or object to processing; withdraw consent; opt out of targeted advertising, sale, or sharing; and appeal a decision about your request. Rights vary according to the data, legal basis, and local law.

Your right to object: where we rely on legitimate interests, you may object to our processing. You may object to direct marketing at any time.

Email [email protected] to exercise a right. Identify the relevant Service and account or platform ID. We may ask for information reasonably necessary to verify your identity and authority. Where local law permits, an authorised agent may act for you. We will not discriminate against you for exercising a privacy right.

You may complain to the UK Information Commissioner's Office at ico.org.uk/make-a-complaint or to your local data-protection authority. We would appreciate the opportunity to address your concern first.

14. Changes to this policy

We may update this policy as Services, technology, or legal requirements change. We will post the new version and update the date above. Where required, we will give additional notice before a material change takes effect. We will not apply a materially different purpose to previously collected data without the notice or consent required by law.

15. Contact us