Privacy Policy

The purpose of this notice

We are committed to protecting your privacy and safeguarding your personal data. Our use of your personal data is subject to the UK General Data Protection Regulation, other relevant UK legislation (together Data Protection Legislation), as well as marketing rules.

In this privacy notice we explain how we will process your personal information obtained through your use of this website and through other interactions with you (e.g. our community events, social media profiles, and crowdfunding projects). It is important that you read this privacy notice, together with any other privacy notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data, and what data protection rights you have.

What does this notice cover: 

• Who we are
• Personal data we collect
• How we collect personal data
• How and why we use personal data
• Who we share personal data with
• International transfers
• How long we keep personal data
• Your rights
• Keeping personal data secure
• Complaints
• How to contact us
• Changes to this privacy notice

Who we are

When we say we, us or our in this privacy notice, we mean Steamforged Games Ltd, a company incorporated and registered in England and Wales with company number 9091884, and whose registered office is at  Steamforged Games Limited, Osprey House, 217-227 Broadway, Salford, M50 2UE, United Kingdom.

For the purposes of the Data Protection Legislation, we are the controller of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.

How to contact us 

If you have any questions about this privacy notice, (including any requests to exercise your legal rights) please contact us by using our website contact form at https://support.steamforged.com/hc/en-us

Personal data we collect

Personal data means information which relates to an identified or an identifiable individual. 

Special categories of data

We do not routinely collect any special categories of personal data about you (meaning information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health, and genetic and biometric data), nor do we collect any data relating to criminal convictions and offences.

Children’s data

We do not provide goods/services directly to children or collect their personal data. If you believe that we have received information relating to or from persons under the age of 18 please contact us at the following link https://steamforged-games.gorgias.help/en-US. If we become aware that a person under the age of 18 has provided us with personal information we will take steps to delete such information. 

Anonymised data

We may also collect, use and share anonymised, aggregated data such as statistical or demographic data for any purpose. Anonymised data may be derived from your personal data but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information on how you use our website to calculate the percentage of users accessing a specific website feature.

How we collect personal data

How and why we use personal data

Under the Data Protection Legislation, we can only use your personal data if we have a proper reason for doing so. For example, because:

• you have given us your consent;
• it is necessary for the performance of a contract; or
• it is necessary for our legitimate interests or those of a third party.

Consent

Generally we do not rely on consent as a legal basis for processing your personal data other than:

• to place cookies on your device;
• to enable to you to take part in our events;
• to send you our newsletters; and
• to send you electronic marketing communication by SMS, email or otherwise (if you are not our existing customer).

Where your permission is required, we will ask you for such consent separately and clearly. You have the right to withdraw consent to marketing at any time by contacting us at https://steamforged-games.gorgias.help/en-US or using the ‘unsubscribe’ link in our marketing emails or responding with the word ‘Stop’ for SMS messages. Even if we are not required to obtain your consent for marketing purposes, you can still opt-out of receiving marketing communications at any time, so you are still in control.

If you submit personal information for publication on our website or another location, we will publish and otherwise use that information in accordance with the permission which you grant to us.

Contract

We will use your personal data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you. For example, if we need to:

• register you as a new customer or administer your account;
• manage our relationship with you (e.g. to respond to your enquires or to notify you about changes to our services);
• process or deliver your order; and
• enable you to partake in a competition or a prize draw.

Legitimate interests

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We rely on our own, and/or or a third party’s legitimate interests, when we process your data for the following purposes:

• to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• to manage our relationship with you;
• to manage payments;
• to deal with your enquiries;
• to ask you to leave a review or complete a survey;
• to send you our updates or other electronic marketing communications by SMS, email or otherwise (when you are our existing customer or have enquired about our products;
• to engage with you though our social media profiles;
• to fund our projects through crowdfunding campaigns run of Kickstarter and Backerkit to which you sign up;
• to run our community events (e.g. conventions);
• to increase our business or promote our brand through delivering relevant website content and advertisements to you and marketing communication;
• to measure or understand the effectiveness of the advertising we provide to you;
• to improve our website, products, services, marketing, and customer relationships and understanding;
• to conduct web analytics; 
• for the prevention and detection of fraud; and
• to interact with you professionally (if you represent our supplier or other business party);
• for the establishment, exercise or defence of legal claims.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or structure of our business.

Marketing

Our marketing emails or SMS messages

We may send you emails or texts for marketing purposes (such as newsletters, event invitations, and new product updates) if you are our existing customer (on the basis of our legitimate interests) or, if you are our prospective customer, when you expressly consent to that (for example, by signing up to our newsletter). 

Profiling

If you are our existing customer, we may use the information we have about you (such as what product you previously bought from us, where you live, how old you are, how you use our website and app) to make predictions on what other products may be of interest to you. We will use that information to make our marketing emails and offers relevant to you. This type of personal data use is called ‘profiling’. We will do that on the basis of our legitimate interests.

Cookies and similar technologies

View a full list of the cookies we use here.

We may also use cookies and similar tracking technologies (for example tracking pixels in our marketing emails and website/app advertisements) and analytics services (such as Google Analytics) to collect information about your use of our website, app, services and your interactions with our marketing emails and advertisements. 

In addition, third party advertising platforms (for example, Facebook) may also use their advertising pixels and other cookies on our website with our permission. Their cookies are used to track visitors across websites in order to deliver adverts more relevant to them and their interests. The advertisers may use information about your visit to our website to target advertising to you on other websites.

We will ask for your consent to the use of non-essential cookies, including third party cookies. You can find further information about the cookies used on our website and the purposes they are used for by reading our Cookies Notice.

Third party advertising

We will only share information with third party advertising providers for the following purposes if you expressly consent to the sharing of your personal data with third parties for advertising purposes on third party platforms. 

With your consent, we may share your name, email address, telephone number, and other information, such as whether you made any purchases with us and how much you spent, for our advertising purposes with social media platforms and other third party advertising providers (for example, Facebook and Google). The third-party advertising provider will use that information to match it against the list of their own users. If the email address or telephone number we give them matches with their list, they will use it to show you our advertisements on their platform.  

The third party advertising providers will also use that information to combine it with the information they hold on you (for example, your interests, likes, advertisements you previously clicked on) and match it with other users of their services who share similar characterises. They will then show our advertisements to those other people. The third-party advertising providers will use your data and the other ‘look like’ users’ data in this way as data controllers on the basis of their terms and policies that govern their users’ use of their services. They will not share any of that information with us. However, if you are one of such ‘look like’ users of the third party advertising provider, and come to our website/app by clicking on our advertisement on that provider’s platform, we will know that you came to us that way. The third-party advertiser may also shared certain statistical information with us (for example, the demographic composition of persons that interacted with our advertisement).

Right to withdraw consent or to object to processing

You can always ask us to stop using your personal information for marketing purposes by:

• changing your marketing preferences within your account on our website or app;
• in case of marketing emails, by using the ‘unsubscribe’ link in our marketing emails; 
• in case of SMS marketing messages, by responding with the word ‘Stop’; or
• in case of cookies, by using the cookie preferences settings on our website.

From time to time, we may ask you to confirm or update your marketing preferences.

Who we share personal data with

We may share your information with third parties for the purposes set out in this notice. For example, we may:

• share your personal data with our suppliers which we use to operate our business (for example, our:
• e-commerce platform provider (e.g. Shopify),
• online inventory and order processing provider, 
• accounting software provider, 
• shipping software provider, 
• payment processing providers (e.g. Sage), 
• carrier services providers, 
• website data analytics providers (e.g. Google Analytics), 
• loyalty programmes and 
• marketing software providers (e.g. Klaviyo, Google Ads). 

We have contracts in place with these providers to ensure that they can only use your personal data to provide services to us and to you;

• disclose your personal data to professional advisers (e.g. lawyers, accountants, auditors or insurers) who provide professional services to us;

• disclose your personal data to certain third parties if specifically requested or agreed with you (e.g. if you ask us to introduce you to a third party);

• disclose and exchange certain information with law enforcement agencies and regulatory bodies to comply with our legal obligations; 

• disclose your personal data to social media providers (e.g. Facebook or LinkedIn) when you sign up or log into our website using your social media account. We may also share your personal data with such social media providers when you use the social media buttons embedded in our website. Please also see the ‘Marketing’ section of this privacy notice for further details of sharing information with social media platforms; and

• share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

International transfers

Transfers of personal data outside the United Kingdom are subject to special rules under the UK Data Protection Legislation. 

If you are based outside the United Kingdom, we may receive and transfer your personal data directly to you in the country where you are based. 

We use cloud-based platforms and tools for the purpose of running our website, selling our products and our marketing activities. The providers of these tools are based either in the EEA, Canada or the US. We also use an online inventory and order processing provider based in Singapore.

Therefore, we may transfer your personal data to providers based in the European Economic Area (EEA). The UK Government has recognised the EEA as providing an appropriate level of protection to the data protection rights of individuals.

We may also transfer your personal data to the following territories outside of the EEA: Canada or the US. Transfers of personal data to commercial organisations based in Canada are deemed by the European Commission to provide an appropriate level of protection.

For transfers of personal data to the US and Singapore, to protect your information, we have entered into the standard contractual data protection provisions (Standard Contractual Clauses) with the third parties in those territories with whom we share your data. The Standard Contractual Clauses are one of the appropriate data transfer safeguards specified in the UK Data Protection Legislation. 

How long we keep personal data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

For example,:

• we are required to keep accounting records for seven years for tax audit purposes;
• if you subscribe to our updates, we will hold your data for that purpose until you unsubscribe or otherwise tell us that you no longer wish to receive such communications; and
• if you are our customer, we will hold your data for the purposes set out in this privacy policy for up to six years after the end of our relationship with you.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Your rights

You have a number of rights in relation to your personal data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge, unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such request).

Under certain circumstances, you have the following data protection rights:

If you would like to exercise any of those rights, please contact us at https://steamforged-games.gorgias.help/en-US. Please let us know what right you want to exercise and the information to which your request relates. 

For further information on your rights, please see the Information Commissioner’s Office Guide to the General Data Protection Regulation.

Keeping personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Complaints

We hope that we can resolve any query or concern you may raise about our use of your information. You may contact us by using the contact methods set out in the How to contact us section of this policy.

The Data Protection Legislation also gives you a right to lodge a complaint with a supervisory authority, in the country where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns or by telephone on: 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance. 

Changes to this privacy policy

This privacy policy was last updated on 21/11/2022.

We may change this privacy notice from time to time, when we do we will publish the new version of the policy on our website. We may also inform you via email or post.