Effective Date: June 28, 2022
1. Who we are
1.1 We are Minakata Dynamics (Minakata, we, our and us), an independent video game developer located north of Tokyo, Japan.
1.2 We are the developer of RAILGRADE, a management sim about using railways to transport resources and power industry on an off-world colony, and operator of the RAILGRADE website available at https://RAILGRADE.com/.
1.3 You can contact us by email with any data privacy queries at privacy(at) (at)minakatadynamics.co.jp.
2. About this policy
2.2 This policy also provides contact details and important information about your data protection rights.
3. What player information do we collect?
The type of information we collect depends on how you interact with the Game. For example, we do not automatically collect personal data by providing the application or through gameplay. But if you link your account to or access it via a third-party service (for example, Steam) we and/or that service will collect information.
In general, the information we collect and generate relating to players may include:
● Personal details you provide to us (including name and email)
● Game profile and analytics information (including basic details, game progress, achievements, and game usage and crash information)
● Game profile ID (a randomly generated identifier)
● Third-party account information (if you link your account to or access it via a service such as Epic Games)
● Other content you create or provide (such as content you share for us to feature on the Site, and communications with player support)
Please note that if we ask you to provide us with information and you choose not to, you may not be able to fully access RAILGRADE and/or some features may not operate as intended.
4. How we use player information
We and our third-party service providers use information relating to players to provide, develop and promote RAILGRADE. More specifically, we use player information to:
● Improve our games (including by providing language, help and instructions)
● Better understand how RAILGRADE is used (including checking crash reports that are shared with us)
● Manage alpha, beta or early access tests (including collecting feedback)
● Provide customer service assistance
● Receive and respond to correspondence
● Administer promotions for RAILGRADE, services, news and events
● Engage with players on third-party social networks (please check the privacy notices of social networks)
● Detect and address security risks
● Detect and address hacking, cheating and other activities that harm the experience of our games
● Detect fraud and other unlawful activity
● Exercise our legal rights and comply with legal obligations
5. Our legal grounds to process player information
● Legitimate interests
We will also use personal data relating to players where necessary for the purposes of legitimate interests pursued by us and organisations we work with.
However, we will only use personal data relating to players for the purposes of legitimate interests where players’ interests, rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with.
Our legitimate interests include for the purpose of providing, developing and promoting RAILGRADE .
We ask for your consent to collect or share your personal data for specific purposes, such as sending players direct marketing or linking a third-party account. Consent may be withdrawn at any time.
● Legal Requirement
We will process your personal data where required by law.
6. Automated decision-making
We do not make any legally significant decisions about individuals based solely on automated decision-making.
7. Sharing player information
We may share or allow third-party services to collect information through the Game or Site. Depending on how you interact with RAILGRADE, common examples might include sharing:
● With platform partners (to facilitate gameplay if you access RAILGRADE through partner game stores; or if you engage with our Discord community);
● With other users or publicly (for example, if your build is featured on our Site);
● With third-party service providers that operate on our behalf (if you submit a crash report);
● When we believe we must in order to comply with the law or to protect you, Minakata, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of our terms or policies, or if necessary to protect others from death or serious harm to body or property);
● With your permission (for example, if you link an Epic Games account).
● We may also share information that does not identify you with third parties, including aggregate or de-identified information.
Third parties that you interact with through RAILGRADE may have different privacy practices than Minakata, so we encourage you to review their privacy policies before sharing your information with them.
RAILGRADE is intended to be enjoyed by general audiences, and is not directed to children. We do not knowingly collect or use any personal data relating to children under the age of 13. If you are a parent or guardian and you believe that we have collected information from your child in a manner not permitted by law through RAILGRADE, we ask that you e-mail us at privacy(at) (at)minakatadynamics.co.jp. If we become aware that a child under 13 has provided us with personal data, we will take steps to remove the child’s information from our records to the extent required by law.
9. International transfers
Minakata is based in Japan, but RAILGRADE is published globally. This means that we may process the information we collect in connection with your use of RAILGRADE in places outside the region where you reside.
When you use RAILGRADE, your information may be transferred to or stored in the United States or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. Where permissible under local law, you’re authorizing us to process your information in any of the locations where we operate by using RAILGRADE.
10. Data retention and security
We generally keep player support information relating to players for a maximum of [one year]. Once we make RAILGRADE unavailable, we will delete all personal data relating to players of the game. We will also delete information relating to a player when we receive a specific request for deletion (see rights section below).
We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing.
11. Your Rights and Choices
11.1 Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you may have the right to access, correct, or delete personal data we have collected about you through RAILGRADE. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw consent.
You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.
Please see the “Contact Us” section below to learn more about reaching out to us with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:
● EEA: https://edpb.europa.eu/about-edpb/board/members_en
● UK: https://ico.org.uk/global/contact-us/
● Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
11.2 California Residents
The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.
You or your authorized agent may make these requests by contacting us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf.
We (or our service providers) collect the following categories of personal information, as described in the CCPA:
● Identifiers (such as name);
● Commercial information (including achievements);
● Internet or electronic network activity (for example, gameplay usage details); and
● Geolocation information.
For details about the information we collect and the categories of sources where we got that information, please see “What player information do we collect?” above. We collect personal information for the business and commercial purposes described in “How we use player information” above.
Minakata does not sell the personal information we collect. We will, however, disclose personal information as described in this policy to the following categories of recipients:
● Business partners (for example, if you use account linking services or multi-player sessions);
● Other users (for example, if you use multi-player settings);
● Service providers (as described in “Sharing player information?” above); and
● Government entities or other third parties in response to a legal request.
11.3 Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant.
11.4 You will not be treated differently or discriminated against for exercising any of your rights.
13. Contact Us
By email: privacy(at) (at)minakatadynamics.co.jp