GRIT AND VALOR – 1949 Privacy Notice
Version 3
Date of Issue: 26 March 2025
Introduction
Who are we?
We are Aonic AB (Publ), a public limited liability company incorporated in Sweden with the registered address at Västra Trädgårdsgatan 15 111 53 Stockholm, Sweden, and registration number 559335-7527, and registration number 559335-7527 (“Megabit”, “we” or “us”), and we are a video games publisher.
Where we decide the means or purpose of processing your personal data, we are the “controller".
If you have any questions about this notice including how to exercise your rights, please contact us at dataprotection@megabit-publishing.com.
What is this Privacy Notice about?
This notice explains how Megabit collects and processes personal data, as a controller, relating to users (individually referred to as a “User” and collectively referred to as “Users”) of Grit and Valor – 1949 (“Game”) and any services provided by Megabit in connection with the Game (“Services”). “You” and “your” shall refer to any User.
Please note, the Game, the Services and this Privacy Notice may refer to websites or services not operated by Megabit. You should refer to the privacy notices on those websites and services to understand how they process personal data.
Updates to this Privacy Notice:
Megabit may make updates to this Privacy Notice from time to time (for example because our services have changed or because of changes in the law) so do check back in on a regular basis. In some circumstances, we may also appropriately notify Users of any updates. The date this Privacy Notice was last updated can be found at the beginning of this Privacy Notice.
What data do we collect and for what purpose?
We collect some personal data directly from Users relating to the use of the Game and Services, and in some cases, from third parties (such as operators of certain third-party services that we use). The data we collect from and about Users varies depending on what is required for the Game and the Services. Where we collect and use personal data, we do so only where we have a lawful reason to use that data for a particular purpose.
The following are the main purposes for the collection and processing of Users’ personal data by Megabit:
Gameplay
We may collect information about Users such as your name, Steam or User ID, email address, IP address, and details about the device you use to play the Game in order to fulfil our contract with you and provide you with the Game and Services.
Payment
Where we offer in-game purchases, we may collect payment information such as your payment card number, expiry date, name and billing address. We do this in order to carry out the contract for the payment for the in-game purchase.
Steam Licences and Achievements
We may collect details about you directly, from Steam or via our game to verify your licence and to record your in-game achievements. We do this to fulfil our contractual obligations and as it is in our legitimate interest to ensure that your licence is valid and to provide you with the optimal version of the Game and Services
Marketing
We will send marketing to you with consent, to provide news and updates on the Game by email.
Where you have previously expressed an interest in our games or services (and not opted-out of marketing) we will use your name and email address to send you updates because it is in our legitimate interests to promote our other products and services we think you might be interested in.
You can withdraw your consent to marketing at any time by contacting us at dataprotection@megabit-publishing.com or, where relevant, by following the unsubscribe link in any marketing communication you receive from us.
Customer Support
We will collect your name, Steam or User ID, email address and any other personal information provided when you contact Megabit for support regarding the Game and/or Services. We do this as it is in our legitimate interest to ensure that we can appropriately respond to your query.
Gameplay Analytics
To improve, test, and monitor the quality and delivery of the Game and Services, and the Game's marketing efforts and to identify and correct any problems in the Game (such as bugs or problems preventing access to or full performance of the Services), the following data will be collected:
- IP address;
- Unique installation-specific ID;
- User ID;
- IDFV;
- gameplay settings when playing the Game and how a User plays the Game;
- in-game achievements and events;
- how long for and when the Game is played (including total game time and total session times); and
country of the device in which they are playing the Game.
Megabit processes this data where Users have consented to do so when prompted on first start-up/boot-up of the Game. Consent can be withdrawn at any time, by using the settings within the Game or by contacting us.
Competitions and Promotions
Where Megabit runs competitions and prize promotions in connection with the Game, Megabit may collect social media handles and account names as well as any winner’s personal data (such as name, telephone number, email address and residential address (if required for delivery of any physical prize)) as necessary for the performance of any obligations tied to that activity. We do this in our legitimate interest to run the competition and promotion activities effectively and to award prizes to the winner(s).
Where we process your data on the basis of consent, this consent can be withdrawn at any time, by using the settings within the Game where applicable or by contacting us.
How long do we keep your personal data for?
Megabit shall only store and retain the data for as long as necessary for the purposes outlined above and until it is no longer required for by Megabit.
As a general principle, we will retain gameplay analytics data necessary until the Game is discontinued or no longer supported.
We may need to keep personal data for longer if required by law, if we are required to keep such data, we will ensure that it is secure, and your rights set out below can still be exercised where possible.
In some circumstances, we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve and monitor the use of our games and services.
Who do we share your personal data with?
Megabit may share or disclose your personal data with third parties as set out below:
- Affiliates and group members: We may disclose your personal data to other members of our corporate group or affiliates (such as to the developer of the Game, Milky Tea Limited) in order to assist us to develop and improve the Game, conduct analytics and market the Game. We share your personal data in this way as it is in our legitimate interest to improve and market the Game. Our group and affiliate companies are subject to this Privacy Notice when they use your personal data.
- Service Providers: We may engage vendors, agents, service providers, and others to provide services to us or to You on our behalf. In providing their services, they may access, receive, maintain or otherwise process personal data (or anonymised data) on our behalf. We share this personal data so that the service providers can assist us in the performance of our contract with you to provide the Game and our Services. Our contracts with these service providers do not permit use of your personal data for their own marketing and other purposes.
- Steam and other gaming marketplaces: We provide details about you to Steam and other gaming marketplaces (if relevant) to enable us to verify that the licence of the game that you have purchased is valid, and to enable us to provide our Game and Service to you. We do this in order to fulfil our contractual obligations and as it is in our legitimate interest to improve and market the Game and our Service.
- Law enforcement, tax or government authorities or tribunals: We may disclose personal data to meet requests from regulatory, prosecuting, law enforcement, tax or government authorities or tribunals. We may make these disclosures to meet legal obligations or to exercise our legal rights, or to prevent crime and fraud.
- Investments, mergers, acquisitions or disposals: If Megabit is undergoing investment, merger, acquisition or sale of our organisation or assets, personal data may be shared as required in the pursuit of the legitimate interests of us, our shareholders, customers and other parties to such a transaction, unless such disclosure is not necessary or those interests are outweighed by prejudicial impacts upon you.
For the avoidance of doubt, Megabit does not sell your personal data to third parties.
Data Transfers
Where we use data processors outside the UK and European Economic Area and transfer personal data to a country which does not provide an adequate level of protection, we ensure the personal data receives additional protection as required by law. To keep this notice short and easy to understand we haven’t set out specific circumstances. For more information about the measures we use, please contact us at: dataprotection@megabit-publishing.com.
Your Rights
Depending on where you live, you may have various other rights under applicable data protection laws, including the right to:
- access your personal data (also known as a “subject access request”);
- correct incomplete or inaccurate data we hold about you;
- ask us to erase the personal data we hold about you;
- ask us to restrict our handling of your personal data;
- ask us to transfer your personal data to a third party;
- object to how we are using your personal data; and
- withdraw your consent to us handling your personal data.
If you would like to exercise any of the above rights, they may reach out to Megabit via the contact email listed in the ‘How to contact us’ section of this notice.
Data protection law can be complicated, and these rights may not always be available to you all of the time.
You also have the right to lodge a complaint. If we can’t resolve your issue, you can also get in touch with the Information Commissioner's Office, the supervisory authority for data protection issues in the UK. If you are based outside of the UK but in the EU, you can find your relevant supervisory authority here.
How to contact us
If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: dataprotection@megabit-publishing.com.
When making a request related to your data subject rights (such as when withdrawing consent or a deletion request) please include the nature of the request in the subject line of the email in order to enable us to act promptly on the request.