This privacy policy explains how we process your personal data when you play “Dark Pictures Switchback VR” (the “Game”). If you have any questions or comments about this privacy policy, please let us know by email to contact@supermassivegames.com.

The Game is operated by Supermassive Games Limited (“we”, “us”, “our”). Where we decide the purpose or means for the processing of the personal data that you provide when playing the Game, we are the “data controller” for the purposes of the GDPR, UK GDPR and UK Data Protection Act 2018.

How we use your personal data. We will use your personal data in the following way:

• the Game collects game play and device information for analytics purposes that allow us to analyse and improve functionality of the Game. The data points collected consist of (together, the “Analytics Data”):
  • information relating to how you play the Game, including progress made, achievements attained, actions taken, features you use, and in-Game events (along with details of when each of these events occur);
  • information relating to our store page on PlayStation™ Network (the “PlayStation™Store”) (including whether you have pressed the PlayStation™Store’s page button, whether you have visited the Store and whether you are playing the Game in “trial mode”);
  • information relating to your in-Game settings (including your sound pre-set settings, language settings, subtitle settings and whether you use the accessibility menu); and
  • information relating to your PlayStation®VR2 (“PSVR2”) headset settings (including your PSVR2 blinking settings, PSVR2 haptics settings, PSVR2 eye tracking settings, your country, the Game version that you are playing and your hardware specifications);
• the analytics will be conducted by PlayFab Inc. The Analytics Data will be shared with PlayFab Inc, and they will use it in connection with our Game and PlayFab’s services. PlayFab offers a backend development platform and is owned by Microsoft. Its services are subject to Microsoft privacy statement;
• the Game collects your name, email address, a record that you are playing the Game, the platform that you are using to play the Game (i.e. the PSVR2) and the bug or issue that you have encountered in relation to the Game, for the purpose of evaluating, investigating into and remedying any reported bugs and issues (together, the “Game Bugs Data”);
• when collecting Game Bugs Data, we use Zendesk, Inc.’s platform, which enables you to notify us of your bug or issue by completing an in-Game form. You can access Zendesk, Inc.’s privacy notice here Privacy Policy - Zendesk UK; and
• the Game collects your [username], score and leaderboard rank (“Leaderboard Data”) for the purpose of maintaining a leaderboard for the Game. The Leaderboard Data will be made publicly available via our social media channels.

Our legal basis. We rely on your consent to process the Analytics Data. Providing consent for the purpose set out above is optional, and you may play the Game without loss of features even if you do not consent to this use. If you provide your consent, you can opt-out at any time through the in-game settings. We also process Game Bugs Data and Leaderboard Data for the purpose of our legitimate interests (being to improve the Game, to improve the quality of service being provided to our users, and to promote the success of the Game, our business and our services), and such interests are not overridden by your interests or fundamental rights and freedoms.

Data sharing. In addition to the above, we may permit access to your personal data to a limited number of our personnel and suppliers insofar as it is reasonably necessary for the purposes set out in this privacy policy, provided that they do not make independent use of the data. We only permit them to process your personal data for the specified purpose and in accordance with our instructions.

Your rights in relation to personal data. You have the following rights over the way we process personal data relating to you, and we aim to comply without undue delay in response to any requests by you:

• for a copy of data we are processing about you (“access”) and have inaccuracies corrected (“rectification”);
• to delete your personal data (“erasure”);
• for a machine readable copy of your personal data, which you can use with another service provider (“portability”). Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer;
• to restrict or stop processing your data; and
• to make a complaint to a data protection regulator.

Please send your requests to contact@supermassivegames.com. Please note the Analytics Data may be held as pseudonymous data, meaning that an individual is not identifiable from the data itself but can be identified by referring to other information held separately. Where we can demonstrate that we are not in a position to identify individuals from the Analytics Data, the rights of access, rectification, erasure and portability do not apply.

Security. We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data.

International data transfers. Your personal data may be sent to and stored in the United States of America. Where we transfer your information outside of the UK and/or EEA, we will have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission or the Information Commissioner’s Office to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know.

Retention. We will hold your personal data on our systems for as long as is necessary for the relevant purpose. 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 requirements.