Fatshark AB (“Fatshark” or “we”) provides software to our customers (“you”) in the shape of interactive entertainment (“games”). We value and take pride in collecting and processing your personal data with a high level of integrity and security. In this policy, Fatshark explains why and how we collect and process personal data, and how you can contact us to ask about your data and invoke your rights.
“Personal data” is information related to an identified or identifiable natural person. An “identifiable person” is someone who can be identified, either directly, for example through a personal identity number, or indirectly, through use of the data in conjunction with other information in the possession of the data controller. Certain special categories of personal data, including racial or ethnic origin, trade union membership, sexuality, physical or mental health conditions, and religious beliefs, are considered sensitive data. Such data require higher protection and safeguards.
“Processing personal data” includes any operation or set of operations performed on personal data, whether or not by automatic means. So, processing includes disclosure by transmission, structuring, amending, storing and many other activities performed on personal data.
“Controller” is the natural or legal person who determines the purposes and means of the processing of their personal data. The controller is entitled to engage other parties to process personal data on its behalf.
Our games may require or offer online or multiplayer functionality, which in essence means that we provide server-side services for matchmaking, progression, anti-cheat, in-game chat/VOIP, etc. We also use playtesting survey data to analyse our games and playtesting responses to improve our games. We are also monitoring technical performance and issues such as crashes that players experience when playing our games.
Outside of our actual games we communicate with potential and actual customers and community members over email, forums and social media, and send you details of our latest products, updates and promotions. We also provide customer service and communicate with you in order to solve issues you may experience in using our games.
We do not use your data for any other purpose.
In order to provide server-side services and improve our games we process certain personal data, including but not limited to SteamID, PSN ID, Gamertag/Xbox ID, IP address, location data, and VOIP and chat data, information about your gaming hardware, crash and software error reports, and your activities within the games. We may store such information or such information may be included in databases owned and maintained by affiliates or service providers. Fatshark may use such information and pool it with other information to track, for example, total number of crashes or active players.
For communication with you outside of the game we collect with your consent your email address and possibly your name, to use in targeted advertisement and to send out newsletters or similar activities. In our forums you may register with name, username and password. If you participate in a contest or other activity, we will with your consent collect certain personal data. You have the right to withdraw your consent to receiving newsletters and other direct advertisement at any time, so called “opt-out”. The opt-out can be made directly through the link in the newsletter you received or by sending us a message indicating “Privacy” as the topic using the webform at the top of this page.
We may use third party website analytic tools such as Google Analytics on our websites that employ cookies to collect certain information concerning your use of our websites. You can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen.
You may also see our games advertised in other applications or websites. Advertising platforms, which include Twitter, Reddit, Instagram, Facebook and other services may collect information for optimising advertising campaigns.
Fatshark is the controller of the personal data collected. We will keep your data safe and not sell your data to third parties. We give you the right to access and delete your data, and to provide you with ways to unsubscribe to marketing materials you get from us.
Fatshark uses anonymised or aggregated data to the extent possible. We retain personal data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymise it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
Fatshark may also use your data collected through our games to help us improve the content and functionality of the games, to better understand our users and trends in usage, and to enhance the user experience. We also use the data to update our games, to maintain security, to enforce our end user license agreements and comply with applicable law.
We may use information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us by sending us a message indicating “Privacy” as the topic using the webform at the top of this page.
We take reasonable steps to protect the information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. However, no internet or email transmission is ever fully secure or error free. In particular, email may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the internet.
Any business partner organisation, subcontractor, subsidiary or group entity engaged by or affiliated with Fatshark that will process personal data under the authority, and on behalf, of Fatshark must enter into a separate agreement with Fatshark. Pursuant to this agreement, the subcontractor agrees to comply with instructions from the relevant data controller and applicable data protection legislation.
Fatshark strives to process data within the European Union (“EU”) and European Economic Area (“EEA”) when possible. However, some of our business partner organisations, subcontractors and subsidiaries are situated outside EU/EEA. Sharing data to such collaborators, for example Google and Facebook, means that personal data may be transferred to a third country outside the EU/EEA area.
The transfer will take place in accordance with current privacy protection legislation, including the GDPR, in order to maintain an appropriate level of protection in the processing of personal data. This means that there is either a decision by the European Commission that there is an adequate level of protection for the country in question, or that appropriate safeguards have been provided. Such measures may be that the receiving party acts under legally binding standard contractual clauses or company regulations.
However, since the GDPR does not apply in the third country, the transfer may entail an increased risk in terms of privacy with regard to, among other things, the possibility for authorities in the third country to gain access to your personal data and for your opportunities to exercise control over personal data.
You can unsubscribe from certain emails by clicking the “unsubscribe” link they contain.
You can opt out from certain cookie-related processing by following the instructions above in “What personal data Fatshark collect and process”.
Individuals have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. You may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways.
How can I access the personal data you have about me?
If you would like to submit a data access request, you can do so by sending us a message indicating “Privacy” as the topic using the webform at the top of this page. We will then start the process and provide you with your personal data that Fatshark has on you within 30 days.
How do I correct, update, amend, or delete the personal data you have about me?
You can request that we correct, update, amend, or delete certain personal data from us directly. Please send us a message indicating “Privacy” as the topic using the webform at the top of this page with an explanation of what data subject right you are seeking to exercise.
How do I object or restrict the manner in which Fatshark processes my personal data?
You have a right to ask us to stop using or limit our use of your personal data in certain circumstances. For example, if we have no lawful basis to keep using your data, or if you think your personal data is inaccurate. You also have the right to opt out of all of our processing of their personal data for direct marketing purposes by clicking the “unsubscribe” link in any of our marketing emails.
In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
For your protection, we may take steps to verify identity before responding to your request.