THE FRONTRUNNER PROGRAM PRIVACY NOTICE

Last updated: 2025-04-24

Welcome to the Frontrunner Program by Avalanche Studios Group. This privacy notice explains how we will process your personal data under the program.

THE PERSONAL DATA WE COLLECT AND USE
When you when you apply to, or participate in, the program, we collect and store:

Contact and identity Information - Name, email, country of residence, discord user_id and steam user_id.
Playing habits and preferences - Game preferences, motivation for participating in playsets, hobbies, game motivations and interests, purchasing behaviors and country of residence.
Game telemetry - In-game activity (player behavior), stability reporting, time, session tracking, IP address.
Hardware information - Operating system, cpu, gpu, RAM and screen resolution.
Player feedback - Feedback and play experience and satisfaction.

HOW WE USE YOUR PERSONAL DATA AND OUR LEGAL BASIS

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
In relation to the personal data that we hold about you, you have the right to:

Right of Access – You have the right to request information concerning if we process your personal data and if we do, you have the right to know what kind of personal data;
Right of Rectification – You have the right request that we correct and rectify any inaccurate or incomplete personal data concerning you.
Right to Erasure – You have the right to request that we delete your personal data. Note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights and comply with technical and legal requirements and constraints related to the security and operation of our properties;
Right to Restriction of Processing – You have the right to request that we temporarily or permanently cease processing of some or all of your personal data;
Right to Data Portability – You have the right to receive a copy of your personal data for the purpose of transferring them to another service provider;
Right to not be the subject of Automated Decision Making – You have the right not to be subject to a decision based solely on automated processing. Including profiling, which produces legal effects on you or otherwise significantly affect you (but we do not use automated decision making);
Right to Withdraw Consent – You may at any time withdraw your consent to the processing of any personal data based on your consent, without it affecting the lawfulness of any processing done before you withdrew your consent; and
Right to Object – You have the right to object to our processing of your personal data for a certain purpose or to object to your personal data being used for direct marketing.

If you wish to exercise any of the above rights regarding your personal data as mentioned above, please contact us at [email protected].

If you have concerns regarding the processing of your personal data, we hope you can work with us to solve them. However, you can also contact the Swedish Data Protection Authority or your local Data Protection Authority. The Swedish Data Protection Authority can be reached through the following address:

Phone: +46 (0)8 6576100

Mail: Integritetsskyddsmyndigheten, Box 8114, SE-10420 Stockholm, Sweden

Email: [email protected]

SHARING YOUR PERSONAL DATA
We share your personal data with third parties as described below:

To other members of Avalanche Studios Group which supports the development and publishing of the games and provides support and services related to the program.
To third party service providers who have been appointed as data processors to perform functions and services on our behalf and who will be provided only with the necessary data to perform those services on our behalf, but who are not authorized to use such data for any other purposes (e.g. web hosting services, information technology systems, customer relationship management, game telemetry collection etc).
To our advisors in the event of a claim or dispute.
If we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a request from a law enforcement authority or other government official; and
To a buyer or another entity that takes over our business.

Some recipients are located in countries outside the EU/European Economic Area (EEA). As in some cases these countries have a lower level of protection than that within the EU/EEA, when transferring personal data to countries outside of the EU/EEA we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data.

DATA RETENTION AND DELETION

Personal data used for the contractual relationship between us will normally be saved for as long as the agreement is valid and thereafter for a maximum of 10 years due to statutes of limitations.
The information about you that you provide when signing up to the Frontrunner program is kept for as long as you remain a participant in the program. You may at any time reach out to us and opt-out from further participation.
We keep game telemetry, hardware information and player feedback for as long as it is relevant to the development of the game, normally until the end of the prototype or the commercial release of the game, after which point the data is either deleted or anonymized.

Other personal data is only saved as long as it is necessary to fulfill the respective purpose of our processing.

Information that has been anonymized may be kept indefinitely since it no longer contains personal data.

SECURITY
We care about privacy and security. To that end, we have implemented technical and organizational measures to ensure that your personal data is collected, processed, and stored securely. For instance, we have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data. On top of this, we enforce contractual measures by way of non-disclosure agreements, data processing agreements, and other contractual clauses designed to keep your personal data safe in accordance with the GDPR legal framework.

However, there is no such thing as perfect security. Complete online or offline security can never be guaranteed by anyone, so you should always exercise reasonable care when sharing your information online.

CHANGES TO THIS PRIVACY NOTICE
We may update this privacy notice from time to time in response to changing legal, regulatory or operational requirements. If that update requires a notice or consent in accordance with applicable law, you will be notified or given the opportunity to give your consent.

HOW TO CONTACT US
Avalanche Studios Group AB and Fatalist Development AB are jointly responsible for the personal data processed under this privacy notice. Our business offices are at Västgötagatan 5, 118 27, Stockholm, Sweden.

If you have any questions about this privacy notice or the information we hold about you, please contact us at [email protected].

Avalanche Studios Group AB and Fatalist Development AB have appointed a data protection officer. If you wish to contact the data protection officer specifically, enter this on the subject line of your email to [email protected].