Effective: February 18, 2021
1. About us
SuperAwesome Trading Limited (referred to herein as “SuperAwesome,” “us”, “our” or “we”) is a private limited company incorporated in England (Company Number: 03885555), having its registered office at: 2-4 Packhorse Road, Gerrards Cross Buckinghamshire, England SL9 7QE .
Rukkaz is our safe social video service where users can watch, subscribe, comment, heart and post image reactions to videos.
Rukkaz is designed to be a safe and moderated environment suitable for young people of all ages. All video content is uploaded by our specially selected content creators. Content posted by users is moderated through technology and/or human monitoring. Our community managers proactively foster a healthy, positive environment inside Rukkaz. There are no private channels or chat in Rukkaz.
Our contact details
SuperAwesome works hard to ensure that the processing of personal data is carried out fairly and lawfully. If you have any questions, need information or require assistance, contact us in the UK at:
Attn: Chief Privacy Officer
SuperAwesome Trading Limited
2-4 Packhorse Road,
Gerrards Cross Buckinghamshire,
Alternatively, if you are located inside the EEA, contact our representative in the EEA at:
Attn: SuperAwesome GDPR Representative
Mason Hayes and Curran Professional Services Limited
South Bank House,
By using Rukkaz, you confirm that you have read and understood this policy.
These terms relate to Rukkaz and its users:
- “Creator” – one of a small subset of selected End Users whose personal data, including photographs of their faces, is visible to other End Users and to the public. Creators’ personal data is visible on Rukkaz only because we have entered into a separate agreement with them to permit us to share their data and (if they are under the age of digital consent) their Parent has contractually agreed to their personal data being used on Rukkaz in this way.
- “End User” – a person (who may be a child) who uses or is in the process of signing up to use Rukkaz.
- “GWM” – a games experience accessible through Rukkaz, in which a private instance of a third party game is provided by SuperAwesome, and within which Creators can play such third party game, and End Users have the opportunity to observe and participate in such game.
- “Parent” – the parent or legal guardian of an End User.
- “Prospect” – an individual who submits their interest in becoming a Creator through the website located at www.rukkaz.com (and any local language versions)
- “Rukkaz” – all our operated Rukkaz experiences including the website located at www.rukkaz.com (and any local language versions), the mobile application named “Rukkaz”, and all other Rukkaz-powered or branded online services, features or experiences.
- “User” – all Rukkaz users; i.e., End Users, Parents, Prospects, and Creators.
These terms relate to Users’ data and how Rukkaz interacts with it:
- “data” – information about a User, both technical and personal
- “technical data” – data observed from a User’s device. For example:
- user agent data
- operating system (OS)
- internet protocol (IP) address
- “personal data” – defined in the GDPR as follows:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;”
- date of birth
- email address
- IP address
Note that some data elements are both “technical data” and “personal data”; for example, IP address.
- “to process”/“processing” – the GDPR definition is as follows: “Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;”
3. General information about how we process Users’ data
How do we safeguard children’s privacy?
End Users, Prospects, and Creators are likely to be children, where a “child” is a person below the age of digital consent (i.e. 13 in the UK and the U.S. and between 13 and 16 in the EEA, depending on each Member State’s implementation of GDPR’s article 8).
We safeguard children’s privacy in the following ways:
- For Users who have profiles and content (including comments), such profiles and content are moderated and monitored so that we can offer a safe and appropriate environment for all Users.
Our right to process Users’ data
Where Users’ data is processed in Rukkaz, we are (under the GDPRs) the data controller responsible for the processing of that data.
We only process Users’ data when we have a legal basis to do so, in any of the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with a Prospect, Creator or their Parent where applicable.
- Where it is necessary for our legitimate interests (or those of a third party) and Users’ interests and fundamental rights do not override those interests
- Where we need to comply with a legal obligation
Note that we may process a User’s data for more than one lawful basis, depending on the specific purpose for which we are using their data. For more information, contact us at firstname.lastname@example.org.
When we refer to our “legitimate interests”, we mean the interest of our company in conducting and managing our business to enable us to give Users the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact (both positive and negative) on Users and Users’ rights before we process their personal data for our legitimate interests. We do not process a User’s data for activities where our interests are overridden by the impact on the User (unless we have their consent or are otherwise required or permitted to by law).
For further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, contact us at email@example.com.
Special category data
We do not seek to process any special categories of personal data (as defined in the GDPRs) about Users; for example, data about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric data, and criminal convictions or offences.
Change of purpose
We will only process a User’s data for the purposes for which we originally intended, unless we reasonably consider that we need to process it for another reason and that reason is compatible with the original purpose.
For an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
We may process a User’s data without their knowledge or consent, in compliance with the rules in Our right to process Users’ data, where this is required or permitted by law.
We collect, use and share aggregated Users’ data such as statistical or demographic data to improve Rukkaz. Aggregated data will not directly or indirectly reveal the identity of a User.
For example, we may aggregate usage data to calculate the percentage of Users accessing Rukkaz after they have downloaded the application.
We do not send marketing materials to Users. From time to time Users may receive service updates; these are communicated as a message or post within the Rukkaz app or website.
- Google Analytics is an analytics service provided by Google Inc. to assist us in understanding how the Rukkaz.com website is used. Google will collect information such as the number of times a page is viewed, and how the website is found (the referring website). The information is aggregated to create a generalized picture of the usage of the website, and is never individually identifiable.
4. What do we do with End Users’ data?
Note that the data described here is collected from all End Users; i.e. Creators as well as non-Creators. Creators are a subset of End Users.
What End Users’ data do we process?
We may collect, use, store and disclose the following data from End Users:
- End User Data. This is the data used by an End User to access or use Rukkaz. We process it when an End User signs up to use Rukkaz or where an End User registers interest in participating in a GWM. It includes:
- A publicly-visible username (moderated to remove personal data), password, and system-generated user ID. This username is randomly generated when an End User installs the Rukkaz app for the first time, but an End User may change this to a free-text username of their choice.
An End User may also choose to create an additional Rukkaz account using “switch account” and in doing so create a free-text username. All free-text usernames are first checked for personal information in real time and also by human moderation.
- A Gamer ID. End Users who participate in a GWM need to provide their username for the applicable game so that they may access the GWM private instance. This username is the name that the End User would have created in the process of setting up an account to play the applicable game.
- GWM Play. Where End Users participate in a GWM, we may record, or require a Creator to record, the gameplay during a GWM. This recording may capture Gamer ID, and information that is shared in any text only public chat feature that may be made available in the game (“GWM Video”). Such chat will be moderated to remove personal information.
- End-User or Parent email address. If the End User or their Parent has a service query (e.g. a password recovery request) or an End User switches their account, then we may collect the End User’s or their Parent’s email address to enable us to provide a response to the current or a future service request.
- A publicly-visible username (moderated to remove personal data), password, and system-generated user ID. This username is randomly generated when an End User installs the Rukkaz app for the first time, but an End User may change this to a free-text username of their choice.
- End User Support Data. This is the data provided by an End User for the purpose of requesting support. End Users may provide us with personal data by communicating directly with us; e.g. by emailing us. When an End User contacts us, we ask them for their Parent’s contact details (typically email address) so we can provide support to the Parent. When we have responded to the inquiry, we delete the End User’s and Parent’s contact details.
- Technical Data. This is the data collected from devices of End Users when they use Rukkaz. While an End User interacts with Rukkaz, we collect data about their equipment, browsing actions and usage patterns on Rukkaz. We collect this data by using server logs and other similar technologies. The data includes:
- Internet protocol (IP) address, login data, browser type and version, time zone, country, language, and browser plug-in types and versions.
- Timestamp, ID of content item (i.e. the video), app version.
- SuperAwesome-generated device ID, device model and manufacturer, device-on-wifi flag (true/false), device platform (iOS/Android), device user-agent string, device type, operating system name and version, country, or region (e.g., US State).
- End User Content. This is end User-generated content shared within the Rukkaz community, and End User interaction data. All such content is moderated to remove any potential personal data and to ensure age-appropriateness. We process this data when an End User creates their profile, and comments on or otherwise interacts with content on Rukkaz. It may include a profile picture or avatar, profile description, comments an End User makes, channels an End User follows, favourite channels, and number of likes given.
How do we process End Users’ data?
- We use some of the data described above to derive aggregated information about End Users such as the number and frequency of visits to Rukkaz and the length of their stays.
- We collect End Users’ device IP addresses solely for the internal support of Rukkaz, such as system administration, and in case requested by law enforcement. We encrypt the IP address and adopt and implement appropriate and reasonable security practices regarding access to it. We delete the IP address after 10 days, unless we are required to keep it for legal reasons.
- We moderate End User-generated content automatically and, in some cases, by human review in order to remove any potential personal data and ensure age-appropriateness. We share user-generated content in order to complete this moderation process.
What is our legal basis for processing End Users’ data?
The following describes the ways we may process End Users’ data, the legal bases we rely on to do so, and what our legitimate interests are, where appropriate.
- End User Data
- Purpose of processing data: To facilitate access to Rukkaz and use of its features.
- Lawful basis for processing data: Legitimate interests to provide access to and experience Rukkaz, and or/additionally consent in respect of Gamer ID and GWM Play.
- End User Support Data
- Purpose of processing data: To provide End Users with a satisfactory support experience.
- Lawful basis for processing data: Legitimate interests to provide customer support functions to End Users.
- Technical Data
- Purpose of processing data: To use data analytics to improve user experiences.
- Lawful basis for processing data: Legitimate interests to operate, maintain and improve Rukkaz.
- End User Content
- Purpose of processing data: To enable the Rukkaz experience for End Users.
- Lawful basis for processing data: Legitimate interests to enable the End User experience.
5. What do we do with Prospect-specific data?
What Prospect-specific data do we process?
Rukkaz may collect, use, store and disclose the following types of Prospect data:
- Prospect Information. This is limited information about the Prospect consisting of: first name, email, online handle, and url. We process this data when a Prospect registers their interest in becoming a Creator on the website www.rukkaz.com. For Prospects under the age of digital consent, without parental consent, we collect only a Parent’s email address and a url.
How do we process Prospect- specific data?
- We process Prospect Information solely to respond to their registered interest in becoming a Creator, and the Prospect Information enables us to determine their suitability in becoming a Creator
- We do not collect Prospect personal data from Prospects under 18 years old without first obtaining verifiable consent from a parent or guardian.
What is our legal basis for processing Prospect-specific data?
The following describes the ways Rukkaz may process Prospect Information, the legal bases we rely on to do so, and what our legitimate interests are, where appropriate:
- Purpose of processing data: To enable us to determine if the Prospect is suitable for becoming a Creator.
- Lawful basis for processing data: Legitimate interests, to enable us to respond to a Prospect’s registration of interest in becoming a Creator and to enable us to make a proper assessment of their suitability and respond to their registration of interest.
6. What do we do with Creator-specific data?
What Creator-specific data do we process?
Rukkaz may collect, use, store and disclose the following types of Creators’ data in addition to the data described in 4. What do we do with End Users’ data?:
- Creator Content. This is creator-generated content, excluding Creator Video Content (defined below), that is shared with the Rukkaz community, and Creator interaction data. All such Creator-generated content is moderated to ensure age-appropriateness, and except for personal information of the Creator which is permitted to be disclosed under agreement with SuperAwesome, all such Creator-generated content is additionally moderated to remove any potential personal information.
We process this data when a Creator creates a channel profile, creates text comments, or otherwise interacts with content. It may include a profile picture or avatar, cover image, profile description, any hearts, comments or shares, users the Creator follows, followers, and top friends. Thus it may include data that can personally identify the Creator subject to the special agreement between Rukkaz and Creators.
- Creator Video Content. This is creator-generated video content shared with the Rukkaz community including any GWM Video. All such Creator-generated content is moderated to ensure age-appropriateness. We process this data when a Creator uploads video content. It includes audio-visual media.
How do we process Creators’ data?
- We process Creator Content as described in How we process End Users’ data, with the exception of the removal of personal data, which in the case of Creators is permitted to be disclosed under agreement with SuperAwesome.
- We moderate Creators Video Content automatically and, in some cases, by human review in order to ensure age-appropriateness.
What is our legal basis for processing Creator-specific data?
The following describes the ways Rukkaz may process Creator Content and Creator Video Content, the legal bases we rely on to do so, and what our legitimate interests are, where appropriate:
- Purpose of processing data: To enable the Creator to engage with other Users and contribute to the Rukkaz experience.
- Lawful basis for processing data: Consent. Additionally, contract, to enable us to fulfill our contractual obligations to our Creators or where applicable to Parents on behalf of Creators, to enable them to use the Rukkaz environment to build their public profile.
7. What do we do with Parents’ Data?
- Except in the case of Prospects, Creators, and End Users who require parental permission to, respectively, complete their application, operate as a Creator, or participate in a GWM, Rukkaz does not directly collect or use Parent’s data.
- Parents or their children who are End Users may provide the Parent’s contact details when registering interest in a GWM, making a customer service enquiry, filling in forms or by corresponding with us by post, phone, email, or otherwise.
8. How do we share Users’ data?
Sharing Users’ data with third-party providers
Rukkaz uses a small number of third-party service providers to help us provide the service to Users. Some of these providers may process Users’ data on our behalf.
We enter into contractual arrangements with our service providers to ensure that they are only processing data in a lawful manner.
The data we share with third-party service providers to help us operate Rukkaz are:
Sharing Users’ data within SuperAwesome
Sharing Users’ data for other reasons
We may disclose a User’s data for any of the following reasons:
- in the good faith belief that we are required to do so by law
- if doing so is reasonably necessary to comply with legal process
- to permit us to pursue available remedies, including commencing or responding to any claims
- to enforce the terms and conditions of Rukkaz
- to protect the rights, property, or personal safety of SuperAwesome or the public
- to prevent other illegal activity
- for risk management purposes
9. How do we transfer Users’ data internationally?
We may transfer Users’ data in the following ways:
- We share Users’ data within the SuperAwesome group of companies. This involves transferring Users’ data outside the European Economic Area (EEA).
- Some of our third-party data processors are based outside the EEA so their processing of Users’ data may involve a transfer of data outside the UK and EEA.
Whenever we authorise a transfer of your personal data outside of the UK and EEA, we ensure a similar degree of protection is afforded to it by using specific contracting frameworks approved by the UK Government and European Commission which give personal data the same protection it has in the UK and the EEA.
If you require further data on the specific mechanism used by us when transferring your personal data out of the UK and EEA, please contact us at email@example.com.
10. How do we secure Users’ data?
SuperAwesome values your trust and strives to maintain adequate security measures for all areas of our business and our services. Because Rukkaz is a service that operates digitally, SuperAwesome is continuously reviewing and improving its security measures to prevent data breaches and security incidents.
- We have put in place appropriate security measures to prevent Users’ data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- We limit access to Users’ data to those employees, agents, contractors and other third parties strictly on a “need to know” basis. They only process Users’ data on our instructions and are subject to a duty of confidentiality.
- We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. How long do we retain Users’ data?
We only retain Users’ data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain a User’s data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with the User.
To determine the appropriate retention period for personal data, we consider:
- the amount, nature and sensitivity of the personal data
- the potential risk of harm from unauthorised use or disclosure of Users’ personal data
- the purposes for which we process Users’ personal data and whether we can achieve those purposes through other means
- any applicable legal, regulatory, tax or accounting requirements
12. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For example you may have rights to:
- Review/access/delete/restrict the collection of your child’s personal data. Under COPPA, a Parent has certain rights over how we handle the personal data of a User who is their child. This includes the right for a Parent to review, access, or delete the personal data that has been collected by us from that User, and to refuse at any time to permit the collection from that User of such personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons of which you will be notified, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.
- Withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
If you are a California resident, please refer to the California residents section for more information on your legal rights.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Do Not Track disclosure
Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, Rukkaz does not support and does not act on DNT signal headers that we may receive.
13. Location-specific rules
Depending on where you are resident, specific rules apply:
UK and EEA
f you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Information Commissioner’s Office (www.ico.org.uk) which is the regulator responsible for data protection in the United Kingdom.
Alternatively, if you are located outside of the United Kingdom, you may contact your local data protection authority. You can find contact details here.
If you are a resident of the United States and believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at firstname.lastname@example.org or by using their online contact form at: https://www.esrb.org/privacy/contact.
For the purposes of this section, “Personal Information” has the meaning assigned to it under the California Consumer Privacy Act of 2018, (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations (CCPA).
The CCPA provides specific rights to individuals who reside in California including the right to know, delete and opt out of certain data collection activities.
In the past 12 months, SuperAwesome, or its third parties, have collected the following categories of Personal Information using the categories enumerated in the CCPA:
- IP address and device ID
- Name, email address or telephone number of people who contacted SuperAwesome with an inquiry
We use and share this Personal Information as disclosed in section 4. In the preceding twelve months, we have not sold any California resident’s Personal Information.
Right to know and access
If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
- The specific pieces of Personal Information we have collected about you during the last 12 months
- The categories of Personal Information we collected, sold or disclosed for a business purpose about you within the last 12 months
- The categories of sources from which the Personal Information was collected
- The purposes for which the information was collected or sold
- The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared
Right to delete
If you are a California resident, you may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please email us at email@example.com or please use this webform.
Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. If we need additional information to verify your identity, we will contact you to request that information.
Right to be free from discrimination
We will not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
Exercising your rights
To submit a verifiable request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above. If you would like to designate an authorised agent to make a request on your behalf, please be sure the agent is able to:
- demonstrate you have provided written permission for the agent to submit the request on your behalf
- provide proof of his or her own identity
If the agent does not satisfy both these requirements, we will deny the request.
California residents “Shine the Light” law
We do not share your personal data with any unaffiliated third parties for their own marketing purposes.