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PAYDAY 2: Privacy Policy

Last updated: 2022-03-16

 

You must be at least 13 years old to sign-up for and play PAYDAY 2.
We recommend that you use a display name that does not identify you.

 

This privacy policy focuses on how we will process your personal data when you play PAYDAY 2.

 

Who are we?

We are New Starbreeze Publishing AB and our registered office address is at Regeringsgatan 38, Stockholm, Sweden.

We are a controller of your personal data under data protection legislation which means that we are responsible for how the personal data we hold about you is processed.

 

How do we collect personal data?

We collect personal data directly from you. You will provide us with your personal data when you play PAYDAY 2.

You can play PAYDAY 2 via Steam, on Xbox, PlayStation and Nintendo Switch. When you play PAYDAY 2 on these platforms we will receive your personal data from these platforms.

You will also provide us with your personal data when you register for a Starbreeze account and when you use your Starbreeze account to play PAYDAY 2. For more information on how we handle any personal data collected when you create a Starbeeze account please see our Starbreeze account privacy policy.

We may also receive personal data about you as part of our advertising campaigns, for example, via social media platforms such as Facebook.

We may also receive your personal data through social media and other online platforms such as Instagram, Twitter, Reddit and Facebook when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, and when you otherwise provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Facebook.

We may also collect your personal data through Steam, when you communicate with us via a Steam forum. We may also collect your personal data from other individuals who may, for example, mention you in any communications they send to us.

 

What personal data do we collect?

When you log in to play PAYDAY 2 we collect basic log in information such as your Starbreeze Account username, your Steam ID and username or information related to your account with Xbox, PlayStation or Nintendo Switch such as your username or console ID.

We may attach a unique reference ID to you as a player. This unique reference ID will be different to your console ID.

We will also receive gameplay data, which will include information about your progress in PAYDAY 2, choices you make about your character, statistics and session time. We may receive data that relate to you and your device such as your location, IP address, network and computer performance, language, and operating system. We may also receive information relating to your engagement with PAYDAY 2, your preferences or activities on third party platforms or websites as well as any relevant advertising or other analytics identifiers that our system of third party providers may produce about you.

We may also receive information about your hardware such as the CPU, RAM, GRAM, Graphics card, brand, model and operating system.

When you use the chat functionality on PAYDAY 2 we will have access to the chat history for all chats, which will include any personal data about you that is included in your chat history, for example, any comments you make in a chat.

We may also receive any data that is included in any correspondence you have with our team, including on any online forums, or when an individual mentions you in any correspondence they send to us.

We may also collect personal data used to promote our offerings, for example, information regarding demographics, interests and behaviours used to create Facebook Lookalike Audiences or similar audiences on Google Ads.

 

How do we use your personal data?

In accordance with data protection laws, we will only process your personal data if we have a lawful basis for doing so.

In respect of your personal data, these bases are: (i) if it is necessary to provide services to you under the performance of a contract we have with you; (ii) if we are required to do so in accordance with legal obligations; (iii) if you have given your consent; and, (iv) if it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests.

The following is a list of the purposes for which we process your personal data, and the lawful basis on which we carry out such processing.

 

Purpose Lawful Basis
To facilitate you logging in and playing PAYDAY 2 Necessary for the performance of a contract
Account verification Necessary for the performance of a contract
Administering a connection between your Steam or console accounts and PAYDAY 2 Necessary for the performance of a contract
Displaying in-game profiles or display names and leader boards Necessary for the performance of a contract
To make event/content related information available to you Necessary for the performance of a contract
To engage with players and potential players including providing advertising on third-party websites and platforms Legitimate interests of promoting our offerings, including commercial interests in expanding our business
To understand when players have interacted with advertising and been directed to our website Legitimate interests of understanding the success of advertising campaigns
To administer gaming events Legitimate interests of promoting our offerings, including commercial interests in expanding our business
To respond to communications, including player support queries received via online forums such as Steam Legitimate interests of handling player communications
To record and analyse customer communications for training purposes Legitimate interests of improving our customer service
To send you service messages and updates about PAYDAY 2 Necessary for the performance of a contract
To prepare and analyse statistics relating to the use of PAYDAY 2 by you and other users, testing, to investigate complaints, to seek and analyse feedback and to further develop the game Legitimate interests of ensuring PAYDAY 2 is as enjoyable as possible
To analyse statistics that provide us with an understanding of the level of success of our marketing campaigns Legitimate interests of better understanding our marketing campaigns
To share anonymised gameplay data with third-party services to analyse and/or publish Legitimate interests of promoting, expanding and improving our business
To run our everyday operations, e.g. communications between employees in connection with the provision of our services Legitimate interests of running our business
To administer and protect our business and the website including troubleshooting, data analysis and system testing Legitimate interests of running our business, provision of administration and IT services, including network security
To administer a sale or possible sale of the whole of or part of our business or the restructuring of our business Legitimate interests of facilitating any such possible or actual transaction or restructuring

 

We may also process your personal data (a) to comply with a legal obligation we are under; and (b) for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.

In certain circumstances, you may be obliged to provide us with your personal data under a statutory or contractual requirement. This might include, but is not limited to, personal data we require to enter into an agreement with you; for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation. Failure to provide us with personal data required under a statutory or contractual requirement may prevent us from entering into or performing our obligations under a contract with you.

 

Advertising campaign success

In order to understand the success of our advertising campaigns, we use Gamesight to note when individuals interact with our online advertisements. We are then informed of the IP addresses of such individuals. This information is not used for any marketing purpose and is only used by us to better understand the success of our online advertising campaigns.

 

When do we disclose your personal data?

We may disclose your personal data to other parties. We may share your personal data with the following parties:

  • Service providers we use to help us operate our business, including organisations that provide us with technology related services, such as Accelbyte Inc, our platform technology provider, and Amazon Web Services.
  • Contractors we engage to assist us in providing our services.
  • Platforms or consoles you play PAYDAY 2 on such as Steam, Xbox, PlayStation and Nintendo Switch.
  • Marketing campaign partners, such as Gamesight, our performance marketing partner that uses analytics to help us understand where players find out about PAYDAY 2.
  • Social media platforms to promote our offerings, for example, we may share your personal data with Facebook to create Facebook Lookalike Audiences.
  • Search engine marketing platforms that provide us with advertising services, such as Google Ads.
  • Social media and other online platforms such as Instagram, Twitter, Reddit and Facebook which we use to communicate with you or to share photos and text that you share via your profiles on these sites, for example, when you tag Starbreeze on a post that you make and we reshare that post via our profile on a social media site.
    External professional advisors who need to access such information for the purpose of advising us.
  • Law enforcement bodies which may have any reasonable requirement to access your personal data, for example, in order to assist with any investigations, when we bring a claim or defend ourselves against a claim that requires the disclosure of personal data.
  • Potential purchasers of our business or investors in it (including in the event of insolvency).

 

International transfers

When your data is transferred internationally, we are required to ensure you are afforded equivalent protection in respect of your personal data to that provided in the EEA.

Generally, we will put in place appropriate safeguards when making international transfers, for example, by using specific contractual clauses which have been approved by the European Commission together with supplementary measures if we deem it necessary in the circumstances, for example, further contractual commitments or enhanced security.

 

How long do we keep your personal data for?

We will retain your personal data only for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any contractual requirements or other legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the purposes for which we process the personal data, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.

 

Your rights

You have the following rights under data protection legislation. If you have any questions about your rights, or you wish to exercise any of these rights, please email [email protected].

We may require you to provide forms of identity should you wish to exercise one of your rights below.
Access: You are entitled to confirmation that we process your personal data and a copy of such personal data.

Rectification: If the personal data we hold about you is incorrect, you have the right for this to be rectified. You may also update your personal data through your account settings.

Erasure: You can request us to erase your personal data if there is no compelling reason to continue processing.

Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below).

Objection: You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.

You may object to receiving direct marketing at any time.

Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.

Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email [email protected] to withdraw consent for the processing of your personal data.

Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the Information Commissioner’s Office and in Sweden, this is the Swedish Authority for Privacy Protection. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.

Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data.