PRIVACY POLICY FOR OVERKILL’S THE WALKING DEAD

1. general information

• Starbreeze Publishing AB, company registration number 556779-9654 having its registered address at Regeringsgatan 38, Stockholm, Sweden (“We”). This document contains a policy statement regarding Starbreeze Publishing AB collection, use and processing of Personal Data (“Privacy Policy”). This privacy policy is applicable when signing up for, accessing and playing the game OVERKILL’s The Walking Dead (“Service”).
• All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the Swedish Personal Data Act (1998:204), which implements the EU directive 95/46/EC, and the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.

2. Processed DATA

• We will process the following personal data when accessing, using, giving feedback on and communicating with the Service:
  1. (a) email address;
  2. (b) IP address;
  3. (c) information about your use of the Service;
  4. (d) gameplay data including statistics, progression, level, session time, login, cosmetics;
  5. (e) nickname and/or gamer tag;
  6. (f) technical data, including the URL you are accessing the Service from, your IP address, network and computer performance, hardware settings and components, Starbreeze / OVERKILL software and updates you have installed or use, browser type, language and identifying information and operating system; and
  7. (g) location data.

• We are unable to provide you with the Service unless you provide us with the personal data stated in (a)-(g) above. The processing of the personal data above is necessary to enter into the agreement with us and is necessary to maintain the contractual relationship between you and us.

3. PURPOSES OF PROCESSING

• We will process the personal data set out above for the following purposes:
  1. a) to administrate your account, to enable and provide the Service and integration with third party services, and to provide, personalize and improve your experience with the Service, and to otherwise provide the Service according to the Terms of Service;
  2. b) to send you alerts or messages by email or otherwise, including to provide you with marketing of our and our related parties’ products and services;
  3. c) to inform you about updates of the Service or the terms of use;
  4. d) to improve and develop the Service or new services and products and to analyse your use of the Service;
  5. e) to ensure the technical functioning of the Service and to prevent use of the Service in breach of the terms of use; and
  6. f) to enforce the terms of use, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary.

4. LEGAL GROUND

• Fulfilment of contract. By accepting out Terms of Service we process your personal data to be able to enter into and fulfil the Terms of Service with you.
• Legitimate interest. The processing of your personal data for the purposes of using the Service is conducted on the basis of the legitimate interest of Starbreeze Publishing AB. Our legitimate interest for the processing is that we need to log data when you use the Service to be able to maintain sufficient IT-security, to evade fraud, to protect the Service from cyber threats and to prevent use of the Service in breach of the Terms of Service. We also log data for the maintaining and improvement of our Service and in order to have your feedback and gameplay data. Based on our legitimate interest of direct marketing of our products and services, we will process your personal data to marketing of our and our related parties’ products and services.

5. DISCLOSURE OF PERSONAL DATA

• We may share and disclose your personal data above to Valve, cloud service providers, game analytics services to be able to provide services needed to ensure the Service.

• Our game engine provider, cloud service provider, game analytics providers, VALVE CORPORATION, Skybound Interactive LLC as well as our cloud service and game analytics provides are located outside the EU/EEA and we are therefore applying relevant safeguards for the data transfers to this/these recipients. You can acquire further information regarding the transfer by contacting us.

• When using the Service you may be directed to other websites where the personal data collected is not in our control. The privacy policy of the other website will govern the personal data obtained from you on that website.

6. RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

• We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.

7. RETENTION

• We store your personal data for three (3) years after your last dated use of the Service to perform the Service and market our services to you.

8. CHILDREN

• The Service is not directed to persons under the age of seventeen (17). If you are a parent or guardian of a person under the age of seventeen (17) and you become aware of that the child has provided personal data to us without your consent, please contact [email protected] to exercise your access, rectification, erasure, limiting of processing and objection rights.

9. YOUR RIGHTS

• You have an absolute right to object to the processing of your personal data for direct marketing. Your objection to direct marketing does not affect the lawfulness of the processing based on the legitimate interest before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing.
• You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.
• If the processing is based on the legal ground fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers.

10. CONTACT information

• To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us at the following address: [email protected]com. In your email please state your full name and your username in the Service. The email address you use needs to be the same one as used when registered to the Service. Note that you should sign the request to receive information of the processing of your personal data yourself.
• If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Notice of changes to the Privacy Policy

• If we make changes to this Privacy Policy we will notify you by messaging in the Service and/or through the Steam Forum for the Service. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.