Influencer Portal Privacy Policy

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand the following:

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy:

This privacy policy covers the information we collect about you when you use our products or services, or otherwise interact with us (for example, by attending our events), unless a different policy is displayed.

We refer to all our games together with our websites as “Services” in this policy.

This policy also explains your rights about how the information we hold on you is used. Your rights include how you can object to certain uses of information about you and how you can access and update certain information about you.

It is important that you read this privacy policy together with any other policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. We keep this privacy policy under regular review and update it to ensure it accurately reflects our data processing practices. Please review this privacy policy regularly to ensure that you are aware of any changes. This privacy policy supplements the other policies and is not intended to override them.

Controller:

Your information is controlled by Frontier Developments PLC. If you have any questions or concerns about how your information is handled, please direct your inquiry to the Data Protection Officer (DPO), which we have appointed to be responsible for facilitating such inquiries.

Frontier Developments PLC,
26 Cambridge Science Park,
Milton Road, Cambridge
United Kingdom, CB4 0FP

E-mail: dataprotection@frontier.co.uk

Customer Support: customersupport.frontier.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues:

Information Commissioner's Office,
Wycliffe House, Water Lane,
Wilmslow,
Cheshire, SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes:

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the portal homepage, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights:

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to

comply with any applicable law, regulation, legal process, or governmental request, including to meet national security requirements,
enforce our agreements, policies, and terms of service,
protect the security or integrity of our products and services,
protect Frontier Developments, our customers, or the public from harm or illegal activities, or
respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows

Identity Data includes but is not limited to first name, last name, username or similar identifier, title, and date of birth. If you have declared a preference, we will also store your preferred pronouns.
Contact Data includes residential address and email address. It also includes your social media display name and social media channels.
Transaction Data includes details about the rate card agreed between us and payments to you from us and that nature of the transactions between us (e.g. sponsored streaming services).
Technical Data Commonly known as online identifiers and includes internet protocol (IP) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI), type of device, your login data, browser type and version, time zone setting and geo location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your login details, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products, and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, news about our products and your communication preferences.

Where Frontier pays you for services you provide to us, your Financial Data, which includes your bank account details, will be collected and processed by us. We will not collect, store or use your Financial data for an purpose other than to pay you for your services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to one of our games). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including, but not limited to:

Direct interactions

You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you create your account on the Influencer Portal. As part of this process and from time to time when you are subscribed to the Influencer Portal you may also subscribe to one or more of our mailing lists.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Information from third parties

We receive information about you from third-party services when you interact with certain Services or information made public by other third-party services.

Information made public by third parties

We receive information about you from information made public by third parties via a website and/or API. The information we collect this way is

Third-party user id
Posts
Reviews

For example, Steam makes all game reviews accessible via an API.

The information we receive depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

For the performance of a contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us. The withdrawal of consent will not affect the lawfulness of any processing that took place before the withdrawal.

Purposes for which we will use your personal data:

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide the Services	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage	Performance
To process a payment to you: (a) Manage payments, fees and charges (b) Obtain consent for marketing activities performed by third parties	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) explicit consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Releasing new content to you (c) Notifying you about: (i) new work opportunities in relation to upcoming and released Frontier Games; (ii) Frontier Events for games and influencers; and (iii) Events the Frontier is attending. (d) Send you items and packs for game launchers	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Transaction (e) Usage (f) Profile Data	(a) Performance of contract (b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (c) Necessary to comply with a legal obligation (d) Necessary for our legitimate interests to detect or prevent unlawful acts
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, and relationships and experiences with you	a) Identity (b) Contact (c) Transaction (d) Technical (e) Profile (f) Usage	Necessary for our legitimate interests (to develop our products/services and grow our business)
To facilitate a duty of care to you	(a) Identity (b) Contact (c) Transaction (d) Profile (e) Usage	Necessary for our legitimate interest (to help you manage aspects of your activities when interacting with our products/services)

To market, promote and/or drive engagement with the Services

We will use your Contact Data and information about how you use the Services to send you newsletters and promotional communications that may be of specific interest to you by sending you an email.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account on the Influencer Portal and checking or unchecking relevant boxes to adjust your email preferences or by following the opt-out links on any marketing message sent to you or contact us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and obtain your consent to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of your personal data

When you join the Influencer Portal, we share certain information about you with other Service users.

Links to Third party sites

The Service may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We strongly recommend that you carefully read the privacy policy of any website you visit.

Sharing with Third Party Service Providers

We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services and this includes but is not limited to shipping merchandise to you, getting you to events and when doing promotions with 3rd parties.

Business Transfers

We may share or transfer information we collect under this privacy policy in the event of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In this case we will attempt to notify you (e.g., email and/or a prominent notice on the Services) if a transaction takes place and outline any choices you may have regarding your information.

6. INTERNATIONAL TRANSFERS

We collect information globally and primarily store that information in Ireland. We transfer, process, and store your information outside of your country of residence, to wherever we or third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

International transfers to third parties

Some of our external third parties are based outside the UK and the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and the EEA.

Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State or the European Commission (as appropriate).
appropriate safeguards are in place in accordance with data protection laws. These safeguards include the use of standard contractual clauses/ data protection clauses approved by the UK Secretary of State or the European Commission (as appropriate) or binding corporate rules.
the transfer is otherwise allowed under data protection laws (including where we have your consent, or the transfer is necessary for the performance of a contract with you).

7. DATA SECURITY

We use data hosting service providers in the United States, Ireland and Singapore to host the information we collect, and we use technical measures to secure your data.

The service provider we use in the United States we use standard contractual clauses. Although we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our system or otherwise in our care, is absolutely safe from intrusion by others.

Any data that we collect via our Services is transferred over an SSL protocol for security during transmission.

Access to the data is limited to trusted employees who require access to perform their roles.

8. Data Retention

How long will you use my personal data for?

How long we keep information we collect depends on the type of information, as described below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account Information

We retain your account information for as long as your account is open. Due to the nature of our Services, if you stop using our Services and do not tell us, your information will remain in case you decide to start using our Services again.

If at any point our Services stop, we will delete all the information we hold relating to the Service that has stopped.

We also retain some of your information that is necessary:

To comply with our legal obligations
To resolve disputes
To enforce our agreements
To support business operations
To continue to develop and improve our Services.

Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our services.

Your use of Services

The information we collect automatically when you use our Services is kept in active storage for varying lengths of time, as follows:

Website logs are not stored in an easy access format.

All this information is archived for the lifetime of the Service.

Marketing information

If you have elected to receive marketing emails from us, we retain information about your marketing preferences until you opt out using the opt out feature in your account settings. We will remove you from our marketing emails should we receive 5 consecutive hard bounces from your account.

9. Your Legal Rights

Under certain applicable laws (including UK and EU data protection laws) and under certain circumstances, you have rights in relation to your personal data. We set out below a brief description of such rights:

To be informed: Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under UK and EU data protection law. This privacy policy and our cookie policy meet this requirement.

Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you subject to certain exemptions.

Request rectification of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we have a legal obligation to erase your personal data. Note, however, that the right to request erasure is not absolute and there are circumstances where we do not need to comply with the request which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data: This enables you to object to processing where we are relying on our legitimate interest (or those of a third party) to process your personal data or where we are processing your personal data for scientific or historical research or statistical purposes. We do not need to stop processing if we can give strong and legitimate reasons to continue processing your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. This is an absolute right but does not automatically mean that we need to erase all of your personal data and in particular, we may put your details on a suppression list to ensure we don't send you direct marketing in the future.

Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in certain scenarios including:

if you want us to establish the data’s accuracy; or
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to personal data you have provided to us which you initially provided consent for us to use or where we used the personal data to perform, or take steps prior to performing, a contract with you and where the processing is automated.

Withdraw consent at any time where we are relying on consent to process your personal data: However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that the above rights are not all absolute and are subject to applicable data protection law and may be subject to conditions and provisions set out in applicable data protection laws. For further information or if you wish to exercise any of the rights set out above, please Contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will inform you of an extension period of up to 2 months. In this case, we will keep you informed on progress.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Explicit consent for external marketing means your personal data will not be disclosed to any third party unless you have given your explicit consent to such disclosure.

11. POLICY UPDATES

Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least annually, and whenever changes to such laws and regulations are made privacy policies and procedures are revised to conform with the requirements of applicable laws and regulations.