ABOUT US AND THIS NOTICE

Our registered users (“Users”) can choose to share their gaming profiles, engage with the Community network, exchange knowledge and gaming achievements, post and view relevant content. Also, content on some of our services is available to non-members (“Visitors”).

Green Man Gaming Limited will be the controller of your personal data provided to, or collected by or for, our Services.

This Privacy Notice explains when we collect data about you, what we collect, why we collect it, who we share it with, where it is processed, how we handle it and what your choices and legal rights are.

For further information about our Privacy Notice or our processing of data about you, please contact our Customer Service team:
https://greenmangaming.zendesk.com/hc/en-us

Or escalate your query to:
dataprotection@greenmangaming.com

Green Man Gaming Limited of c/o Nyman Libson Paul LLP, 124 Finchley Road, London, United Kingdom, NW3 5JS is incorporated in England and Wales under the company number 05271628.

DATA COLLECTION

This section explains what data we collect about you and the sources of this information. We may combine data we receive from any of these sources. For example, we may process singularly or collectively information we have collected from you, your visits to our website, your Steam or Playfire gameplay history if you have shared it with us, etc., for the purposes explained in this Privacy Notice.

Data You Provide

You may provide us with certain information directly, including:

1. Account information: When you create an account for Green Man Gaming, we ask you to provide information such as your username, email address or telephone number, date of birth and password to create the account. You can also add a profile picture, and other details about you to your account profile and set various account settings account settings (including social privacy controls)
2. Payment information: If you wish to purchase games or credit for your account wallet or make any other payments via Green Man Gaming using a payment method, we will ask you to provide certain data such as your billing address and payment details
3. User Content: Some Green Man Gaming products and services will allow you to upload to our servers: messages, comments, forum posts, game levels, videos, images and other information
4. Customer Services: If you contact us for assistance we may ask you to provide information about you (such as your name and contact details) and the nature of your query, and you may choose to send further communications about your query
5. Other: We may ask you to provide information if you participate in market research surveys, feedback requests, beta and other user testing research, competitions, promotions or events or agree to receive marketing information from us

Please make sure that any personal details which you provide are accurate and current as we will send important information relating to your account using the contact information you provide (including account security and data protection notices). Let us know if there are any changes. You can check and update the information you have provided to us any time via Green Man Gaming Account Profile Settings.

Green Man Gaming Website

Each time you sign in to Green Man Gaming and access our online services, we may automatically:

1. access and store information about your use of Green Man Gaming features and services on your device; and
2. log your activity on our Green Man Gaming servers.

For example, we may receive device and account identifiers, such as Green Man Gaming Account and details of what content, promotions and other information your devices request and receive from our servers (such as store content, gameplay activity and want lists) and when you receive and interact with them, what content and games you add to your 'basket' and what you purchase.

Accessing Green Man Gaming on your devices

Each time you use a Green Man Gaming app or sign in to your Green Man Gaming account on your devices (such as a mobile or PC), we may automatically access and store information about your use of that device and app.

The data that we access from and store on your devices may include:

1. Device identifiers such as your laptop/desktop ID, mobile device IDs, cookie IDs
2. Network identifiers such as your IP and MAC address
3. Account authentication tokens that avoid you having to log in repeatedly
4. Content and client downloaded to your device for the online services that you access
5. Account creation IP address and store that against a country. If you travel out of your home country, we present you with Green Guard security check.
6. Achievements, scores and rankings achieved online and offline
7. Some device type and setting details and error reporting
8. Information about which features and services you are accessing from your Green Man Gaming device or app and when (such as Steam or Twitch if applicable)
9. Information about the device(s) you are using and how you have configured them.

Game Tracking

By linking your Steam account with your Green Man Gaming account you grant us access to your Steam game library and your Steam game play data.

Websites, Marketing and Advertising

Each time you visit our website or receive and interact with our marketing communications and advertising on our and third party websites and services, we may automatically log your activity on web, advertising and marketing servers managed by us or by a third party on our behalf

For example, we may receive:

1. Online identifiers usually stored in cookies on your device
2. Other tracking data, such as tracking pixels and browser configuration details (e.g. browser type, list of installed plugins and list of installed fonts)
3. If you sign into your account, account identifiers such as Green Man Gaming Online Account
4. Information about the content, marketing communications and advertisements you view and interact with (for example, if you click on a banner on Green Man Gaming.com about Stormworks: Build and Rescue, open a marketing email about Green Man Gaming VR or click on one of our adverts on a social network about Green Man Gaming)

Please see the Green Man Gaming Cookie Policy for more details on our use of cookies and how to control them when accessing our websites.

Third Party Partners

We may receive limited information about you from third party partners, including from:

1. Our financial and anti-fraud service providers processing your account sign in and purchase transactions, including fraud risk scores
2. Other online service providers, our security service providers, government agencies, law enforcement and public security sources, including IP addresses and details of suspected unlawful or fraudulent activity and security risk scores
3. Third party partners providing games and apps via Green Man Gaming, including information about accounts, IP addresses and devices reasonably suspected of breaching our or our third party partners terms of service or of being involved in fraudulent or malicious activity
4. Other third parties where permitted under notices and choices that they or we have provided to you (for example, we may receive information from a Green Man Gaming partner that you visit if you've agreed that the provider of that service can send us information about your activity, such as Facebook)

First Party Platforms

The below information relates to customers who purchase Green Man Gaming’s published titles on first party platforms, including Valve, Microsoft, Sony, Nintendo, Epic Games and others, across all applicable hardware and subscription based services. These companies collect and use information under their own privacy notices.

Green Man Gaming may receive limited personal information about you from first party platforms, including:

1. Device, number of associated accounts, region
   
2. Player telemetry, including collective and average playtime, crash/bug reports and other insights into community behaviour
   

LEGAL BASES WE RELY ON

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

1. Your consent.
   We can collect and process your data with your consent in specific situations, i.e. when you tick a box to receive email newsletter. You are able to remove your consent at any time by changing your preferences. Where consent isn't provided, Google fills their data collection gaps with conversion modelling and behavioural modelling.
   
2. We have a contractual obligation.
   In certain circumstances, we need your personal data to comply with our contractual obligations, i.e. if you order a game from us, we’ll collect your name email address/ phone number and payment details to deliver your purchase,
   
3. We have a legal obligation.
   If the law requires us to, we may need to collect and process your data and we can pass on details of people involved in fraud or other criminal activity affecting Green Man Gaming to law enforcement.
4. We have a legitimate interest.
   In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, and which does not materially impact your rights, freedom, or interests. For example, we will use your purchase history to send you or make available personalised offers. We will also send you direct marketing emails when you shop with us and do not choose to opt out - this is often called a 'soft opt in'. We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand. We may contact you regarding market research. With your consent, or when you shop with us and do not choose to opt out from receiving our emails ('soft opt in') we will use your personal data, preferences, and details of your transactions to keep you informed by email, web, text and through our contact centre about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
   

Data Use

This section explains how we may use the data we collect about you. We may use data combined from any of the sources explained in the 'Data Collection' section of this Privacy Notice. For example, we may process together information we have collected from you, your visits to our website, your Steam or Playfire gameplay history, etc., for the purposes explained in this Privacy Notice.

Services

We (and affiliates and third parties operating on our behalf in accordance with our instructions) may use your information to operate Green Man Gaming and to provide the services you have requested - for example, in order to maintain your account, process your purchases and/or complete anti-fraud checks.

We may personalise the services we provide to you based on the combined data we have collected about you (for instance, we may use your IP address to display content relevant for your area or we may recommend or to help you discover new games or social media that you are entitled to play and watch using information about your past activity).

Development

We use the data we collect to understand, improve and enhance our existing products and services and your experiences using them, and to help develop new ones. For example, we may use the data to optimise user interfaces, for bug and error fixing, apps and websites.

Moderation and Safety

We cannot monitor the whole of Green Man Gaming and make no commitment to do so. However, we reserve the right in our sole discretion to monitor and record your online activity and communication throughout Green Man Gaming and to remove and/or delete any content. We may use the combined data we collect (including information such as the content of your voice, video (Twitch video posting), and text communications, the time and location of your activities, and your Green Man Gaming Online Account, registered account details and IP address) to detect breaches and enforce our Green Man Gaming terms of service and any other terms of service you have agreed to and any rules or codes of conduct applying to your use of Green Man Gaming. Enforcement action that we may take can include suspending or banning accounts and/or devices.

Legal and Compliance

We may use the combined data we collect for auditing, compliance and legal purposes (for example, making or defending claims or activities that are required by law).

Marketing and Advertising

We might target and personalise our marketing communications, purchase recommendations and adverts that we display on our and third party websites and services based on the combined data we have collected about you (e.g. to avoid displaying content you've already purchased from our store).

You may notice this personalisation when you visit Green Man Gaming (via website or app), when we send you marketing communications or when you visit our and third party websites (such as social network sites) that show purchase recommendations or adverts from us (for example, you might see an advert for a game similar to one you have played recently or a product that you have recently viewed on Green Man Gaming).

You can choose if you would like to receive marketing communications from us relating to Green Man Gaming and our products and services. If you later decide not to receive marketing emails from us, you can turn off marketing communications:

1. Via Preference Centre Settings in your Green Man Gaming Account Settings area
2. By following the instructions and/or the link "unsubscribe" attached to our marketing emails

We will aim to process your request as soon as reasonably practicable and in any event, within 2 working days. Note that we will still send you important emails about your account even if you opt-out of marketing emails.

If you choose not to allow us to store and access cookies that are not strictly necessary for the provision of our websites, this will also limit when we can recognise your visits to our websites and target and personalise the advertising and commercial purchase recommendations displayed on those websites. Please see the Green Man Gaming Cookie Policy for more details on our use of cookies and how to control them when accessing our websites.

Data Sharing and Transfers

This section explains how we may share the combined data we collect with third party vendors and partners that provide services to us or provide games and apps on Green Man Gaming that you use.

Services

We may share the combined data we collect with third party vendors and selected partners that provide services to us or provide games and apps on Green Man Gaming that you use. For example, we may share your payment details to banks and other financial and anti-fraud organisations in order to complete your purchase, obtain payment and carry out credit and anti-fraud checks.

Advertisements and Ad Serving Technology

We also use third party providers of adverts. Examples of third party providers we may use from time to time are Meta, Google, Twitter, Impact.

Third party ad providers may collect information as a result of ad serving through the Website and/or the App. These entities may collect and use data for this purpose including software, applications, hardware, browser information, internet and online usage information. This data may be used and disclosed in accordance with our and the privacy notice of the company providing the ad serving technologies. The advertising companies who deliver ads for us may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy notices.

Third-Party Research Companies

We may share, on a commercial basis, anonymised customer data with third-party research companies when you browse/login/purchase on Green Man Gaming (for example, making a purchase on our store). In order to comply with various privacy laws (CCPA, Nevada Privacy laws, GDPR, etc), you have the right to withdraw permission for Green Man Gaming to share any data (even anonymised) with third-party research companies for commercial reasons. To opt-out of data sharing for commercial activities please click here and log-in to your account and send us a message with your details.

Other Users

When you create an account for Green Man Gaming, certain information will form part of your public profile and we will make it accessible to all accounts on Green Man Gaming.

This includes:

1. Your Green Man Gaming Username
2. "About Me" statement, avatar, game reviews you write and the games you have added to your Green Man Gaming Wish List.
3. When you create a Green Man Gaming account, your profile will be set for 'Public' view but you can choose whether to keep your profile public or change it to private through your profile settings ('Settings' tab in 'My profile').

Please be aware that anyone who can see your information will be able to share it with others, for example by sharing a gameplay video that you feature in. Some devices allow users to record, stream and upload online activities such as gameplay and therefore may be distributed outside Green Man Gaming without your knowledge, which means that you and we have no control over it.

You are responsible for any content you share on forums, communities, chat and messaging features and this content will be accessible to others.

We recommend you consider carefully with whom you share your information. Avoid sharing your contact information with others.

Security and Fraud

We may share limited information about you with third party partners, including:

1. Our financial and anti-fraud service providers processing your account sign in and purchase transactions, including fraud risk scores
2. Other online service providers, our security service providers, government agencies, law enforcement and public security sources, including IP addresses and details of suspected unlawful or fraudulent activity and security risk scores

Legal and Corporate

We may share the combined data we collect:

1. To defend legal claims or exercise legal rights
2. With our service providers processing data on our behalf
3. With our professional advisors dealing with, for example, legal, tax, audit or accounting matters
4. During negotiations for and following conclusion of a sale of all or part of our business

Government Authorities

We may share your information with police and other government authorities if we believe that it is reasonably necessary to comply with a law, regulation, or legal process, to detect, protect and enforce the safety of any person, their property or their rights, to address fraud and security and report criminal activity.

International Transfers

Your information may be processed, stored, and transferred outside your country of residence, beyond the European Economic Area (EEA), and the UK, where we are located for the purposes set out in this Privacy Notice, such as the United States. Data protection laws in these countries may not offer the same level of protection as in your country, the UK, or the EEA, and you may have fewer legal rights in relation to your information. We ensure there are adequate safeguards in place when transferring your data outside your country, the UK, and the EEA, including by relying on the EU-US Data Privacy Framework and the UK Extension to the EU-US Data Privacy Framework, new EU Standard Contractual Clauses (SCC), International Data Transfer Addendum (UK GDPR Addendum), or other lawful mechanisms or otherwise that the transfer only occurs where permitted by applicable law.

Data Handling and Your Choices

Storage

We keep the data that we collect about you for as long as necessary for the purposes set out in this Privacy Notice. In general, we will retain information that is associated with your account or device until you close your account. Even following account closure, please be aware that the data that we collect about you may still be retained for legal, fraud and accounting reasons.

Security

Access to your Green Man Gaming account is restricted through the password that you set. Please keep the password for your account safe and do not disclose it to anyone else. Consider ensuring automatic account log in setting is disabled and the setting requiring a password to be entered before completing purchases is enabled, particularly if your Green Man Gaming device is shared with others. You should contact Green Man Gaming Help and Support immediately if you become aware of any unauthorised use of your account or other security breach.

Children's Data

You must be at least 16 years old to create an account for Green Man Gaming. However, if you are a parent or guardian, you may create accounts (or confirm the creation of an account initiated by your child) for your children aged up to 15 to access Green Man Gaming and its services. If you do so, we will process your child's data in accordance with this Privacy Notice.

Your Choices and Rights

If you are a user of our services, you can access, correct, and modify some of the personal information that you have provided to us via Green Man Gaming Account Settings.

You also have the right to request a copy, rectification, erasure or blocking of your personal information and to object to our processing of your personal information in certain situations. You can exercise these rights by contacting us via the information in the About Us and Complaints section of this Privacy Notice.

You can close your account for Green Man Gaming by contacting Green Man Gaming Help & Support. Please be advised that account changes can take up to 1 month.

Note that this will not affect any alternative accounts that you might have; you will need to close those accounts separately.

Complaints

If you have a concern about our information rights practises, please get in contact with us first so we can try to resolve your query using the details in the 'About Us and this Notice' section of this Privacy Notice.

If however you feel we have not dealt with your concern and that we are failing to meet our legal obligations, you can report this to your local data protection regulator, or Data Protection Commission (“DPC”) in Irelandhttps://www.dataprotection.ie/ or the Information Commissioner's Office ("ICO") in the United Kingdom. More information on reporting a concern to the ICO can be found at https://ico.org.uk/ .

UPDATES AND CHANGES TO THIS PRIVACY NOTICE

We may make alterations to this Privacy Notice from time to time and these variations shall become effective immediately upon being accessible fromhere or on the Effective Date.

We will use our reasonable efforts to notify you of any such changes, which will not apply to any earlier use of the Service or purchases of Games through the Service.

Your continued use of our Services will be deemed acceptance of the updated or amended Privacy Notice and these variations shall become effective immediately upon being accessible. If you do not agree to the changes, you should cease using the Service. If there is any conflict between this Privacy Notice and any terms or specific local terms appearing elsewhere on the Service then this notice shall prevail.

Version 1.0 (August 2024)

Effective Date on May 25th, 2018