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".
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 (Closed Beta) (“Beta”) and any services provided by Megabit in connection with the Beta (“Services”). “You” and “your” shall refer to any User.
Please note, the Beta, 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 Beta 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 Beta and the Services. The following are the main purposes for the collection and processing of Users’ personal data by Megabit:
- to process applications to participate in the Closed Beta and for Megabit to distribute the keys to enable Users to access the Beta;
- to contact Users to notify them of the commencement of the Beta and to provide updates on the Beta;
- with consent, to provide news and marketing updates on Grit and Valor – 1949 by email;
- to assist Users who contact Megabit for support regarding the Beta and/or Services; and
- with consent, we will process certain anonymous and aggregated data from Users to understand:
- how Users are playing the Beta to improve, test and monitor the quality and delivery of the Beta; and
- to identify and correct any problems in the Beta (such as bugs or problems preventing progression).
All data collected and processed for the above purposes is done under one of the following legal bases:
- Contract: where it is necessary, Megabit will use personal data in order to perform a contract with the User and ensure we are able to complete any related obligations under the contract with our Users.
- Legitimate interest: personal data may be needed for Megabit’s business purposes, as balanced against the potential impact on a User’s privacy rights. This includes common purposes, such as to communicate with a User and respond to their requests, to ensure the smooth operation of the Beta and Services along with working on improvements for the Beta.
- Legal: Megabit processes personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement officials or in accordance with the relevant regulatory frameworks.
- Consent: for the processing of some data, Megabit will be relying on the consent from the User, such as analytics. Consent can be withdrawn at any time, either in the Beta or by contacting us via one of the contact emails listed in the Contact section of this notice.
Information you provide to Megabit:
As part of the registration process for the Beta, Users are required to provide the following personal data to Megabit:
- email address;
- name;
- Discord ID; and
- Country of Residence.
Megabit shall use User’s email addresses to provide updates on the Beta. Where a User consents to receive email news and marketing updates relating to the full release of Grit and Valor – 1949 when registering for the Beta or during the Beta, Megabit will use the email address provided by the User to provide such updates. Consent can be withdrawn at any time by unsubscribing from the updates.
Where a User contacts Megabit’s support email address in relation to the Beta, a User may provide the following personal data to Megabit:
- Steam ID;
- name;
- email address; and
- any other personal data provided by the User to Megabit (for example, their telephone number to be contacted by).
Please note any missing or incorrect data may not enable Megabit to fully assist with a support request.
Where Megabit runs competitions and prize promotions in connection with the Beta, 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.
Gameplay Analytics:
To improve, test and monitor the quality and delivery of the Beta and Services and to identify and correct any problems in the Beta (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 Beta and how a User plays the Beta;
- in-game achievements and events;
- how long for and when the Beta is played (including total game time and total session times); and
- country of the device in which they are playing the Beta.
Megabit processes this data where Users have consented to do so when prompted on first start-up/boot-up of the Beta. Consent can be withdrawn at any time on the Preferences menu in the Beta.
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 Grit and Valor – 1949 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.
Data storage, transfers and disclosures
Megabit may share or disclose your personal data with third parties as set forth below, in accordance with the purposes set out in the notice and the relevant legal basis:
- Affiliates and group members: We may disclose your personal data to other members of our corporate group (such as to the developer of the Beta, Milky Tea Limited) in order to carry out the processing set forth in this Privacy Notice. For example, for purposes of assisting us to develop and improve the Beta, conduct analytics and market Grit and Valor - 1949. Our subsidiary or 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, such as Mailchimp. In providing their services, they may access, receive, maintain or otherwise process personal data or your anonymised data on our behalf. Our contracts with these service providers do not permit use of your personal data for their own marketing and other purposes.
- 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 or disclose to meet obligations or to exercise our legal rights, or to prevent crime and fraud.
- Investments, mergers, acquisitions or disposals: If involved in an 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.
Where we use data processors outside the UK and European Economic Area, and (or otherwise) transfer personal data to a country which does not provide an adequate level of protection, we use contracts approved by the European Commission or UK authorities which give personal data the same protection it has in Europe / the UK. For more information drop us a line using the contact details at the start of this notice.
Your Rights
A User has several rights regarding how your personal data is processed. Below are the rights a User can exercise:
- ask us to send a copy of your personal data to you or someone else;
- ask us to restrict, stop processing, or delete your personal data;
- object to Megabit’s processing of your personal data;
- object to use of your personal data for direct marketing purposes; and
- ask us to correct inaccuracies in your personal data.
If a User 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.
Please note, we may not be able to action certain requests due to:
- the legal basis we are relying on to process your personal data;
- it would interfere with another User’s own privacy rights;
- it needs to be retained to satisfy certain legal requirements or obligations or for security purposes; or
- otherwise, there are valid grounds under data protection laws to allow us to do so.
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.
If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns (or if you live outside of the UK, you can submit a complaint to the supervisory authority in your country).