Privacy Policy January 1, 2021

Privacy Policy


This policy describes the personal information we, IO Interactive A/S, collect, how we use this information, and what rights you have. It applies to all our games and products, websites, social media channels, customer and technical support and any other service we provide (collectively “IOI services”).

Accessing or using any of the online features of the IOI services implies your acceptance of this policy. This means that you consent to how we collect, use, and process your personal information. If you do not consent to this policy, you should not use any online features of the IOI services.

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. Your continued use of the online features of the IOI services will signify your acceptance of these changes.

  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.

  1. WHAT INFORMATION WE COLLECT

2.1 WHEN YOU CONNECT TO OUR GAMES

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. This information includes:

Connection Information. When you connect to our games, our servers automatically collect some information. This information includes your Internet Protocol address, your chosen platform with which you access this game, the date and time of your request and information about your ownership of this game.

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

Device Information. We may collect information about the device you are using to access our websites or play our games, including what type of device it is, what operating system you are using, your device settings, unique device identifiers and crash data.

Whether we collect some or all this information depends on what type of device you are using and its settings. Please check the policies of your device manufacturer or software provider to learn more about what information your device makes available to us.

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

2.2. WHEN YOU PLAY OUR GAMES

A big aspect of our games is the online component where you can compete with other players. We want this experience to be fair and want to ensure that you won’t be subjected to playing against any cheaters. Furthermore, we want to provide comparable results for you, such as scoring and features associated with playstyle. For this purpose, we collect information such as:

Game Log Information. When you play our games, we collect information about how you use this game, which includes your game session information, gameplay events, gameplay statistics, if you have unlocked progression items, and scores.

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

Profile Information. We create a permanent profile that is personal to you. This profile is used to track your progression over time, expose statistics and populate menus with progression information. The information collected for the purposes of this profile includes current progression on different systems, such as location mastery tracks and challenges, items and features unlocks, profile statistics, profile game settings, played content including completed and failed elusive targets, content created by you such as contracts, and contracts moderation reports.

Depending on the policies of your platform, we collect information about your friend list and owned content associated with your platform. Please check the policies of your device manufacturer or software provider to learn more about what information your device makes available to us.

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

Usage Statistics Information. We are always striving to improve our games. To do so, we collect information about how you use this game; this is for the purposes of business intelligence, content improvement and content commendation. This collected information includes your connection information with the Internet Protocol address and game identifiers, the content that you have played, your performance information such as score and progression events, and your selected gameplay events such as target kills or your deaths.

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

Service Monitoring. We constantly monitor our games to offer the best availability possible. For this purpose, we temporarily store operational information that can be related to you. This information includes HTTP request information containing your Internet Protocol address, timing, identifiers, latency and response code and internal server errors triggered by your requests. We also might use the previously described usage statistics information or the profile information to investigate and resolve customer issues and service monitoring alerts.

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

2.3. WHEN YOU ACCESS OUR WEBSITES

We use cookies to enhance your experience on our websites, to evaluate the use of individual elements on our websites and to support the marketing of our services. A “cookie” is a small text file that is stored on your computer or mobile device when you visit a website.

By using our websites, you accept that we and our third parties use the following cookies:

Essential Cookies. These cookies are strictly necessary for the operation of our website.

Performance Cookies. To track and report website activity, we use a Google Analytics cookie with a retention period of 26 months.

Functional Cookies. We may use functionality cookies to remember your settings and to provide an enhanced experience for you when using our website.

Third-Party Cookies. To provide ads that are relevant to your interests, we use advertising cookies that are used when you share information via social media sharing buttons or “like” buttons on our sites or apps, or when you link your account or engage with our content on or through a social media sites. These cookies have a retention period of 180 days.

You may stop accepting cookies from IOI services at any time through the settings in your browser or on your mobile device.

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

2.4. WHEN YOU CREATE AN 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 customising our communication to you and delivering targeted advertising, we request information such as your e-mail address, real name, date of birth, gender, country and your 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.

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

2.5 ANY OTHER INTERACTION WITH US

If you interact with us through any other IOI services, such as our support or social media channels, or by sending us an application for a job, or by otherwise interacting with us, we may process information such as your name, e-mail address and other information that you voluntarily provide to us during such an interaction.

You may revoke such consent at any time by contacting us at [email protected].

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

  1. SHARING OF 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 personalised 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.

  1. 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.

  1. 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.

  1. 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 5 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 object to the processing of your information and 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).

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. You may withdraw your consent by requesting to have your information deleted, 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. Please be aware that all your information will be deleted and you will be forced to play in offline mode until you accept this privacy policy (GDPR Art. 21).

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

  1. INFORMATION RETENTION AND DELETION

Retention. 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.

Game Information Deletion. 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 any more.

  1. 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.

  1. 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.

  1. 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.

Last Updated: January 2021