INSIGNIA PRIVACY POLICY

Insignia Team (also referred to in this document as “we”, “our”, or “us”) isn’t an incorporated organisation. As such, ‘Insignia Team’ refers to the current development team, led as of the time of writing by Mr Luke Usher (a British citizen), considered collectively.
Throughout this document, where we refer to our ‘services’ in general, this should be read to include the services we provide for the Microsoft Xbox console and any associated websites (such as the Insignia website and game-specific web services).
We’re committed to protecting and respecting your privacy; if you have any questions about how we handle your personal information, please send an email to [email protected].

INFORMATION WE HOLD ABOUT YOU

We aim to collect the minimum amount of information necessary to provide high quality services. The exact data we hold varies depending on which of our services you use, but includes:
- Information you submit through our websites or services, for example:
- When you sign up for an Insignia Account, we collect your email address, chosen display name (a “Gamertag”), and provided location.
- Any content you post to our Services (including our websites), such as leaderboard information and storage attachments for inter-user messages.
- The IP address you use to access our services.
- Information on the console(s) you use to access the Service, such as your Xbox’s serial number and per-device identifiers.
- Statistical information about how you use our services.
- Information from any social networks or other accounts that you connect to our services, where needed to provide our Service, or where you ask us to display this on a profile page for you.

HOW WE USE YOUR INFORMATION

We use your information to provide our services to you and our other users. In particular, we use it to:
- Enable you to use our services.
- Help us manage your account and to fix problems you’re having.
- Detect and fix bugs in our services.
- Display content you choose to share with other users.
- Analyse and improve the services we give you and other users.

We may also use your information to exercise what’s known as our legitimate interests. This is when we use data for a reason which is in your or our interest and which doesn’t involve overriding your privacy rights; an example of this would be communicating important maintenance information using the email you provided during sign-up or providing security updates if ever necessary.

Finally, with your permission, in future, we may use the information you provide to:
- Market and communicate our services, where we think these will be of interest to you, by email.

WHO WE SHARE YOUR INFORMATION WITH

We may share your information with the following:
- The Insignia Team (comprised of our developers and administrators), as well as a limited subset with the Moderation Team, where necessary to perform their duties.
- Other users of our services, where this use is a key part of our Service and/or when you give permission for this to happen.
- For example, we may show your submitted statistics to other users on the Insignia service, as well as on the Insignia website.
- Any organisation which supports any of our services you use when they need it to offer those services, for example:
- Specific game service providers, if not hosted by the Insignia Team, such as Sylverant and Schthack (our Phantasy Star Online service providers).
- Analytics and cyber security service providers.
- Anyone who you give us explicit permission to share it with.
- We’ll also share your information where this is necessary to comply with the law, including reasonable requests from the authorities, or to protect the rights, property, or safety of us, our users, or others.
- In the event that our services are sold or transferred to another person or organisation (a ‘third party’), your data will be transferred to that third party as part of the transfer and will fall under their privacy policy.

HOW LONG WE KEEP YOUR INFORMATION

Generally, we will hold your data for as long as you’re using our services. However, we may store some of your data for longer if we need to in order to exercise our legitimate interests, as explained above, such as protecting our services and users from abuse, spam and security threats, and/or if the law says we have to.

HOW WE KEEP YOUR INFORMATION SECURE

We are committed to ensuring that your information stays secure. To prevent anyone from gaining unauthorised access, we’ve put in place suitable procedures and policies to keep your data safe.
In particular, when creating an Insignia Account (and whenever you might reset the password for your existing Insignia Account), we will always ensure that any password you enter is securely hashed, salted, and stored in accordance with industry-standard security guidelines and best practices. This means that even if someone were able to bypass our robust security measures to steal information from our databases, it would be virtually impossible for them to work out your original password from the data that we store.

WHERE WE STORE YOUR DATA

We use various external service providers to help provide our own services.
The majority of our services are hosted by DigitalOcean, LLC, on servers located in the United Kingdom. We also use content delivery network (CDN) services provided by Cloudflare, Inc. to keep everything running quickly and smoothly.
We might transfer and store the data we collect from you somewhere outside the European Economic Area (‘EEA’), and people who work with us or our suppliers outside the EEA might also process your data, but this will only happen if:
- We’ve agreed standard data protection clauses with the company; and/or,
- The European Commission says that the country in question offers adequate data protection.

CHILDREN'S PRIVACY

We don’t knowingly collect or ask for any information from anyone under the age of 13 without the consent of their parent or guardian, nor do we knowingly allow them to register, as our services and content aren’t aimed at children under the age of 13.
If we learn that we have collected data from someone under the age of 13 without the consent of their parent or legal guardian, we’ll delete that information as soon as possible. If you believe we might have received any data from or about a child under 13, please contact us as soon as possible by emailing [email protected]

YOUR RIGHTS

You have a right to:
- Access the personal data we hold about you, or get a copy of it.
- Ask us to correct inaccurate data.
- Ask us to delete, ‘block’ or suppress your data, though, for legal reasons; we might not always be able to do this completely.
- Object to us using your data for direct marketing, and in certain circumstances, for our legitimate interests, for research, and for statistical reasons.
- Withdraw any consent you’ve previously given us to use your data.
If you’d like to exercise (make use of) any of these rights, please get in touch with us by emailing [email protected].

How to complain

If you have a complaint or you otherwise have any concerns or queries about our use of your personal information, please get in touch with us by emailing [email protected], and we’ll do our best to help.