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PAYDAY 2: Privacy Policy

  1. GENERAL INFORMATION
    New Starbreeze Publishing AB, company registration number 559194-5471 having its registered address at Regeringsgatan 38, Stockholm, Sweden (“We”). This document contains a policy statement regarding New Starbreeze Publishing AB collection, use and processing of Personal Data (“Privacy Policy”). This privacy policy is applicable when you interact with and play the game PAYDAY™ 2 using the software product, its forum, and websites (collectively the “Software Product”). By downloading the Software Product, or by registering to the Software Product in a platform provider’s systems, you accept this Privacy Policy.

    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 registering for, signing up to, using, giving feedback and communicating with the Software Product:
    1. Software Product game engine identifier tag;
    2. information about your use of the Software Product;
    3. gameplay data such as statistics, progression, level, session time, login, cosmetics;
    4. technical data, which may include your IP address, unique device ID, network and computer performance, language, and operating system;
    5. location data; and
    6. information about your hardware in terms of CPU, RAM, GRAM, Graphics card, brand, model and operating system.
    We are unable to provide you with the Software Product unless you provide us with the personal data 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. administrate your logged in sessions to enable and provide the Software Product and integration with third party services, and to provide and improve your experience with the Software Product, and to otherwise provide the Software Product according to the Terms of Service (https://www.starbreeze.com/payday2/terms-of-service.pdf);
    2. to improve and develop the Software Product or new services and products and to analyze your use of the Software Product;
    3. to ensure the technical functioning of the Software Product and to prevent use of the Software Product in breach of the Terms of Service;
    4. to enforce the Terms of Service, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary; and
    5. to fulfil requirements by law.
  4. LEGAL GROUND
    Fulfilment of contract. By agreeing to this Privacy Policy we process your personal data so that you can use the Software Product.

    Legitimate interest. The processing of your personal data for the purposes of using the Software Product is conducted on the basis of the legitimate interest of New Starbreeze Publishing AB. Our legitimate interest for the processing is that we need to log data when you use the Software Product to be able to maintain sufficient IT-security, to evade fraud and to protect the Software Product from cyber threats. We also log data for the maintaining and improvement of our Software Product and in order to have your feedback and gameplay data.
  5. DISCLOSURE OF PERSONAL DATA
    We may share and disclose your personal data above to forum service providers, cloud service providers, game publishers, service providers hosting the Website and game analytics services to be able to provide services needed to ensure the Software Product.
    Domain name service provider USA EU Model Clauses
    Cloud service provider USA EU Model Clauses
    Game analytics provider USA EU Model Clauses
    Distributed streaming platform provider USA EU Model Clauses
    Game engine provider  USA EU Model Clauses
    Our domain name service provider, game engine provider, distributed streaming platform provider, cloud service provider and game analytics providers 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 Software Product 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. COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES
    We collect information by using technology such as cookies, pixels and tags (on your browser or device).
  8. RETENTION
    We store your personal data for three (3) years after your latest use of the Software Product to perform the Software Product.
  9. CHILDREN
    The Software Product are not directed to persons under the age of eighteen (18). No parental consent is needed as there is no one under the age of eighteen (18) that is allowed to use the Software Product.
  10. YOUR RIGHTS
    You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent 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 once (1) every calendar year. 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 grounds consent or 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.
  11. 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: dpo@starbreeze.com. In your email please state your full name, your user name and nick name in the Software Product. The email address you use needs to be the same one as used when registered to the Software Product. 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.
  12. NOTICE OF CHANGES TO THE PRIVACY POLICY
    If we make changes to this Privacy Policy we will notify you by in the closed forum for the Software Product. 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.