007 First Light Privacy Policy

This policy describes how we, IO Interactive A/S, collect and processes personal data, and what rights you have in relation to such data. It applies when you access or use any of the online features of 007 First Light, related customer and technical support and any other service we provide in connection with the game (collectively "IOI services"). By using the IOI services, you acknowledge that your personal data will be processed as described in this policy.

We may update this policy from time to time, so please review it frequently. We will notify you before we make any material changes to this policy and give you the opportunity to review the revised policy before the changes take effect.

 

1. WHO WE ARE

IO Interactive A/S is the data controller for the processing of your personal information. We are a registered company located at Gammel Moent 2-4, 1117 Copenhagen, Denmark. Please see the last section of this document for our contact information.

IO Interactive A/S is the data controller for personal data collected through the 007 First Light game and IOI services. The James Bond character, name, likeness, and related intellectual property used in 007 First Light are owned by Amazon and licensed to IO Interactive by MGM Interactive Inc. Amazon does not control or have access to personal data collected by IO Interactive through the IOI Services, except as aggregated, non-identifiable statistics.

 

2. WHAT INFORMATION WE COLLECT

2.1 Online Connection

Whenever you connect to an online game, certain information will be collected. The same is true for our games, and for this purpose we collect information to establish and maintain your connection to our games. We use this information to operate and maintain the game and online services, monitor performance, troubleshoot technical issues, prioritize bug fixes, optimize performance across device configurations, and scale our online infrastructure appropriately.

 

Technical and Account Information

When you launch, access, or play the game, including when the game connects to our servers, we collect certain technical and account-related information. This includes your platform display name and platform ID, information about your ownership of our products or entitlements (including access to free and paid content), and details regarding the start and end of online sessions. We also generate and collect session identifiers, such as an Application Session ID (which resets when the game exits) and an Online Session ID (which resets when a new server connection is established).

Network and Connection Information

When you connect to our servers, we automatically collect connection data, including your IP address, the platform you use to access the game, and the date and time of your connection.

Information related to server connections is used to assess whether online infrastructure needs to be scaled up or down, as well as to monitor, maintain, and debug online services.

Device and Hardware Information

We collect information about the device and system you use to access our websites or play our games. This may include device type, operating system, device settings, hardware configuration, unique device identifiers, and crash and diagnostic data.

Hardware information is used to prioritize performance optimization for the most commonly used system configurations when developing updates and patches.

The specific information collected may vary depending on your device type, platform, and settings. For more information about what data your device makes available, please consult your device manufacturer's or software provider's policies.

Our legal basis for the processing of this information is GDPR Art. 6 (1) (b) and GDPR Art. 6 (1) (f). We have a legitimate interest in collecting this information to improve the games and user experiences.

All game information is hosted and stored in Microsoft Azure and our server is physically located in the West Europe (Amsterdam) and North Europe (Dublin) data centers. Online connection data is automatically deleted after 7 days. 

 

2.2 Player Profile

When you connect to the online game server, we create a profile that is personal to you. This profile is used to track your progression over time, create leaderboard statistics, unlock entitlements, and populate menus with progression information.

The information collected for the purposes of this profile includes platform ID, display name, creation date, progression and unlocks, intel, player level, inventory, XP, challenges, and features unlocks, profile statistics, profile game settings, played content, location and language based on platform settings.

Upon authentication, we collect information about the entitlements associated with your account, including access to free and paid content.

Depending on the policies of your platform, we are collecting information about your friend list and owned content associated with your platform.

 

Our legal basis for the processing of this information is GDPR Art. 6 (1) (b).

All game information is hosted and stored in Microsoft Azure and our server is physically located in the West Europe (Amsterdam) and North Europe (Dublin) data centers. We retain player profile information until you request deletion of your information.

 

2.3 Game Log Information

When you play our games, we collect gameplay data to understand how the game is used and to improve both the base game and live content. This includes identifying overly difficult areas, sections where players get stuck or disoriented (such as camera issues), underused features, and other gameplay balancing needs. Additionally, we use behavioral data to evaluate player engagement with live content. This helps inform patches, future content development, and broader commercial and marketing planning.

Gameplay and Usage Data

When you play the game, we collect information about your gameplay activity and interactions with the game's features. This includes Application Session ID, Online Session ID, platform ID and gameplay statistics, progression data (such as unlocked items, XP and intel), gameplay events and player actions (such as completing missions, failing checkpoints, player deaths), changes in game state (such as being detected by an enemy or entering a restricted area), the content you access and play, country (based on IP address), hardware settings and game configuration settings (such as subtitle, accessibility and graphics settings).

This data may be used to generate player activity statistics for your profile such as total playtime or player style (collectively, "Gameplay Activity"). This data may also be aggregated to create anonymous usage metrics, such as the number of new or active players per day or how levels and challenges are completed.

Our legal basis for the processing of this information is GDPR Art. 6 (1) (b) and GDPR Art. 6 (1) (f). We have a legitimate interest in collecting this information to improve the game and user experience.

All game information is hosted and stored in Microsoft Azure and our server is physically located in the West Europe (Amsterdam) and North Europe (Dublin) data centers. Gameplay Activity is stored until you request deletion of your information. Gameplay Activity is stored until you request deletion of your information, and other game log information is deleted after 30 days.

 

2.4 Anti-Fraud

We have implemented anti-piracy software to maintain the integrity and security of the game environment, detect unauthorized third-party software, and protect from abuse, fraud, and exploitation. For this purpose we process platform user ID, IP address, activation date, country (based on IP address), and hardware identifiers.

Our legal basis for the processing of this information is GDPR Art. 6 (1) (b) and Art. 6 (1) (f). We have a legitimate interest in collecting this information to ensure a safe gaming environment and prevent fraud. 

All game information is hosted and stored in Microsoft Azure and our server is physically located in the West Europe (Amsterdam) and North Europe (Dublin) data centers. Anti-piracy software is provided by Denuvo Software Solutions GmbH.   We process your information only for as long as needed in order to fulfill the purpose, or until you request to have your information deleted, whichever comes first.

 

2.5 Crash Reports

If you play the game and it breaks, we will make a crash report about the problem. This report includes the game scene and camera position, server version, system info (for example, client version, OS version, amount of memory), game settings, stack trace, module list and the platform ID.

Our legal basis for the processing of this information is GDPR Art. 6 (1) (b) and Art. 6 (1) (f). We have a legitimate interest in collecting this information in order to identify and resolve issues you may encounter while using the game.

All crash information is hosted and stored in Microsoft Azure and our server is physically located in the West Europe (Amsterdam) and North Europe (Dublin) data centers.  Crash reports are deleted after 30 days. 

 

2.6 Support

If you contact us for customer support in relation to any of our games, we will process certain personal information to investigate and resolve your request. We process this information to respond to your inquiry, verify your identity and account ownership, troubleshoot and resolve technical or account-related issues, and improve our games and support services.

For this purpose, we process your username, email address, account ID and the records of communications between you and our support team. Depending on the information you include in a ticket, this may include description of the issue, attachments, screenshots, or video recordings, profile and gameplay information relevant to your request (e.g., entitlement status, progression data, transaction history, session logs), and technical and diagnostic information relevant to your request (e.g., device information, crash logs, IP address, timestamps, error reports).

Our legal basis for the processing of this information is GDPR Art. 6 (1) (b).

Customer support services are carried out by TransPerfect Denmark ApS. Support-related data is retained only for as long as necessary to provide customer support services, resolve disputes, prevent fraud, and comply with applicable legal and regulatory obligations.

 

2.7 IOI Account

When we come up with new ideas or develop new products, we want you to be the first to hear about them. We therefore want to give you the option to create an IOI Account so we can have a direct form of communication. Please visit https://www.ioi.dk/ioi-account for more information on an IOI Account.

For the purposes of customizing our communication to you and delivering targeted advertising, we request your e-mail address, name, country, and marketing mailing preferences. If you provide us with consent to provide you with marketing material, you accept that we communicate directly with you.

Additionally, we want to offer you a hub for tracking your ownership of our games. We therefore provide you with the option to connect your preferred platform account with your IOI Account. This gives us access to the account identifiers and your registered products.

If you already have an IOI Account, your player profile and game log data will automatically be linked to your account, and we may use player profile data and game log data to grant rewards when you have completed specific in-game achievements, to enable cross-game rewards, and to personalize marketing communications.

Our legal basis for the processing of this information is GDPR Art. 6 (1) (a) and (f). We have a legitimate interest in collecting this information to improve games and user experiences, to grant rewards, and to improve marketing communications.

If you sign up to our newsletter, we share your e-mail address and name with our newsletter provider, Moosend Ltd. We may share your information with advertising partners who help us customize and target our marketing efforts, such as reducing the number of ads shown to you if you are already subscribed to our newsletter. We process your personal data for as long as you maintain an IOI Account or until you request its deletion, whichever occurs first.

 

3. SHARING YOUR INFORMATION

Some IOI services require that we share information with (i) our subsidiaries and affiliates, (ii) third-party vendors for the performance of services such as website management, hosting and e-mail communications, (iii) advertising partners for the purpose of personalized and targeted marketing, (iv) with parties with whom it might be necessary to complete a financial or corporate transaction, such as a merger, or (v) for legal reasons. Please be assured that we always provide our partners with only the minimum information necessary.

 

4. STORAGE AND SECURITY

The protection and integrity of your information is important to us. As such, we ensure that your information is stored on servers compliant with the latest security best-practices and which are located in the European Union.

 

5. TRANSFER

If your information is transferred outside of the European Union, we use the Standard Contractual Clauses, as approved by the European Commission, to protect your information.

 

6. YOUR CHOICES ABOUT YOUR INFORMATION

With some specific limitations or conditions, you have the following rights:

You have the right to access your information, and you may request to have it deleted (GDPR Art. 15 and 17). If you wish to do either, please visit https://ioi.dk/legal/privacy  to delete or access any game- and IOI Account-related information or contact us at [email protected] for any other access or deletion enquiry. Please see section 7 for more details on deletion.

For technical reasons, you will not have the option to request correction of your information. Please contact us at [email protected] should you have any compelling reasons for a rectification.

You have the right to have the processing of your information restricted (GDPR Art. 18).

You have the right to receive your information in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible (GDPR Art. 20).

You have the right to object to the processing of your information, after which we will no longer process your information, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You may also object to processing by requesting to have your information deleted. Please be aware that all your information will be deleted, and you will be required to play in offline mode. Should you resume online play, your data will be collected again as outlined in this policy. If the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the processing carried out before you withdrew your consent (GDPR Art. 21).

Unless otherwise stated in the above, you can take steps to exercise these rights by contacting us at [email protected].

 

7. INFORMATION RETENTION AND DELETION

Unless otherwise specified in this policy, we store your information only for as long as needed, in order to fulfil the purposes outlined in this policy or until you request to have your information deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and relevant legal or operational retention needs.

When you request to have your information deleted, we delete everything associated with you, including your online progress in any of our games. Please note that your information will be deleted in its entirety and that it will not be possible for us to distinguish between information collected by our games. Consequently, it is not possible to request information deleted from one game while retaining information from another. We will not be able to restore any deleted information. The user-generated content that you have created may not be deleted, but you will not be associated with that content anymore.

 

8. MANDATORY INFORMATION

The information we collect when you connect and play our games is mandatory if you want to play our games in online mode. Please note that you can choose to opt out of our collection of information by updating your privacy settings in our menus or by requesting to have your information deleted. The consequence of not providing the information is that you will be forced to play our games in offline mode. If you reject this privacy policy or request to have your information deleted and then, at a later stage, want to enable online mode, please click the 'go online' button and accept this privacy policy.

 

9. INFORMATION ABOUT CHILDREN

As our games require you to be of a mature age, we do not knowingly collect any information from children under 16. If you become aware that a child has provided us with information without parental consent, please contact us at [email protected]. If we become aware that a child under 16 has provided us with information without parental consent, we will take steps to remove the information.

 

10. HOW TO CONTACT US

Should you have any questions or comments, you are welcome to direct them to [email protected] or in writing by post to IO Interactive A/S, Gammel Moent 2-4, 1117 Copenhagen, Denmark, Att.: Legal. You also have the right to lodge a complaint with a data protection supervisory authority, such as The Danish Data Protection Agency.