THE FRONTRUNNER PROGRAM PRIVACY NOTICE

Last updated: 2025-02-09 Version 2.0

INTRODUCTION

Welcome to the Frontrunner Program by Avalanche Studios Group. This Frontrunner Privacy Notice ("Privacy Notice") explains how we handle your personal data in connection with the Frontrunner Program and applies to individuals who create a Frontrunner Account and/or participate in the Frontrunner Program.

For the purposes of this Privacy Notice, Avalanche Studios Group AB is the data controller for the processing of your personal data. Our company information is:

Avalanche Studios Group AB 556675-1748 Box 11238 SE-10061 Stockholm, Sweden

YOUR DATA, YOUR RIGHTS

Under data protection laws, including the European General Data Protection Regulation, you have certain rights over the processing of your personal data.

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 to 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 in certain situations, including when needed to comply with our legal obligations, resolve disputes or prevent fraud.
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 affects you.
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.
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, please contact us at gdpr@avalanchestudios.se.

If you have any questions about your privacy, your rights, or how to exercise them, please contact us using the information provided to you in the "How to contact us" section of this Privacy Notice.

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 decide to contact the Swedish Data Protection Authority or your local data protection authority. The contact details to the Swedish Data Protection Authority and other national data protection authorities in the EU can be found here.

OUR PROCESSING OF PERSONAL DATA

This section details i) whom we process personal data about, ii) the sources for personal data, iii) the specific categories of personal data we process, and iv) the legal basis and purposes for which we use it.

3.1 Whom we process personal data about

We process personal data regarding individuals who create an account for, and participate in, the Frontrunner Program and who access and use the Frontrunner Platform.

3.2 Sources of personal data

We collect personal data about you from the following sources.

Directly from you. Information that you provide to us when you create an account, access the Frontrunner platform and otherwise participate in the Frontrunner Program.
Information that is automatically collected. When you access and use the Frontrunner Platform or our prototypes, the platform or the prototype automatically collects information about you and your device.

3.3 Categories of personal data that we process

We process the following categories of personal data about you.

Account information. Information that you provide when creating an account on the Frontrunner platform, including name, email, country of residence, Discord user name, Discord avatar, Discord banner, Steam id, and Steam account information based on your Steam privacy settings.
Playing habits and preferences. Information that you provide when creating your account and/or when you participate in surveys, including game preferences, motivation for participating in playtests, hobbies, game motivations and interests, purchasing behaviors and country of residence.
Game telemetry. Information collected automatically from your use of the prototypes, including in-game activity (player behavior), stability reporting, time, session tracking and IP address.
Technical and usage data. Information collected automatically about you or your device when visiting our website or platform, via cookies or otherwise, including IP address, online navigation data, browser type, language preferences, pixel data, cookies data, web beacon data, computer ID, user ID, domain name, log files, software and hardware inventory, and software usage pattern tracking information.
Player feedback. Information that you provide to us in relation to a playtest, including feedback and play experience and satisfaction.

3.4 How we use your data and legal basis

This table outlines the purposes of processing your personal data and the legal basis for doing so.

Purpose of the processing	Categories of personal data	Legal basis
Verifying your identity, administering the playtest and communicating with you	Account information	Performance of a contract, Art. 6(1)(b) GDPR
Providing the platform to you	Account information; Technical and usage data	Performance of a contract, Art. 6(1)(b) GDPR
Assessing suitability for specific playtests	Account information; Playing habits and preferences	Legitimate interest, Art. 6(1)(f) GDPR (to ensure a diverse group of playtesters with the correct profile)
Maintaining a database of playtesters for future playtest sessions	Account information; Playing habits and preferences	Consent, Art. 6(1)(a) GDPR (Being part of our database of potential playtesters for future sessions which is the purpose of signing up to the program)
Understanding player experience/preferences, developing and improving our product and services, validating technical stability, and understanding audience desires	Game telemetry; Player feedback; Playing habits and preferences; Technical and usage data	Legitimate interest, Art. 6(1)(f) GDPR (to improve our games and services, ensure stability, and deliver polished products which also benefits you who are a user of our games and services)
Anonymizing data for statistics and reports	All categories described above	Legitimate interest, Art. 6(1)(f) GDPR (by anonymizing certain information we are using as little personal data about you as possible and we can continue to use the information for the purpose of improving our products and services after your personal data needs to be deleted)
Complying with applicable laws, regulations, legal processes, or government requests	All categories of personal data described above (depending on the nature of the legal obligation)	Legal obligation, Art. 6(1)(c) GDPR (including to respond to law enforcement requests)
Resolving legal claims	All categories of personal data described above (depending on the nature of the legal claim)	Legitimate interest, Art. 6(1)(f) GDPR (to protect our legal rights and business interests)

When you sign up for a Frontrunner Account, you need to provide information about your date of birth. We process this information on the basis of compliance with legal obligation, Art. 6(1)(c) GDPR (to verify your age and ensure compliance with age restrictions).

COOKIES

We use cookies and similar technologies on the Frontrunner website/platform. For more detailed information on how cookies are used, please read our cookie notice.

AUTOMATED DECISION MAKING

We do not use any form of automated decision making or profiling that produces legal or other similarly significant effects concerning you in connection with the Frontrunner Program.

We share your personal data in the following ways.

Affiliated companies. To affiliated companies in Avalanche Studios Group that provide services on our behalf or for developing and improving our products and services.
Third-party service providers. To vendors and partners who provide services on our behalf. These include Pragma Inc., which is our data processor for personal data processed in connection with the Frontrunner Platform.
Mandatory disclosures. To authorities, unions, and other entities in order to comply with applicable laws, regulations, legal processes, or government requests.
Legal claims. To auditors, insurers, and legal counsel for the purpose of dispute resolution or litigation.
Business successors. To potential or actual buyers (and their agents) in the event of a merger, acquisition, or sale.

DATA RETENTION AND DELETION

We apply the following retention periods for personal data we process about you.

Account information and any related information about Playing habits and preferences are 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. You can delete your Frontrunner account yourself by logging in to your account. The exception to this is any account information that is used to govern the contractual relationship (playtest agreement) between us, which may be kept for as long as the agreement is valid and thereafter for a maximum of 10 years due to statutes of limitations.

We keep Game telemetry, Technical and usage data 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.

INTERNATIONAL DATA TRANSFERS

We transfer and share your information to third parties (including service providers operating on our behalf) which are located in countries outside the EU and/or the EEA which may not have the same level of data protection laws as those in the country where you are located. When transferring personal data outside the EU/EEA, we prioritize engaging suppliers located in countries that benefit from an adequacy decision by the European Commission, ensuring your data remains protected to EU standards.

Our main service provider in relation to the Frontrunner Program, Pragma Inc., is located in the United States but is not certified under the EU-U.S. Data Privacy Framework. Transfers to Pragma Inc. are subject to the EU Commission-approved standard contractual clauses (and supplementary technical and organizational measures). These clauses are designed to offer sufficient safeguards with respect to the protection of your privacy and fundamental rights. Other transfers to countries outside the EU/EEA that are not subject to an adequacy decision will also only occur if we have entered into EU Commission-approved standard contractual clauses (and implemented supplementary technical and organizational measures) with the receiving entity.

KEEPING YOUR DATA SAFE

We care about privacy and security. To that end, we have implemented the appropriate technical and organizational measures to ensure that your personal data is collected, processed, and stored as securely as possible. For instance, we have implemented various policies including 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.

HOW TO CONTACT US

If you have any questions, complaints, or comments regarding how we process your personal data or about this Privacy Notice, please contact us at:

Avalanche Studios Group AB Box 11238 SE-10061 Stockholm, Sweden gdpr@avalanchestudios.se

We have appointed a data protection officer. If you wish to contact our data protection officer specifically, then clearly state this on the subject line of your email to gdpr@avalanchestudios.se.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time to reflect changes in the Frontrunner Program, processes, legal requirements, or operational practices.

The latest version will always be available on our website. If we make material changes that significantly affect your rights or how we process your personal data, we will notify you directly (for example, by email).

We encourage you to review this page periodically to stay informed about how we process your personal data. The date at the top of this Privacy Notice indicates when it was last updated.

The Frontrunner Program Privacy Notice