Privacy Policy

1. INTRODUCTION

With this information text ("Privacy Policy"), Embark Studios AB ("Embark"/"we") intend to fulfill our transparency obligations under the General Data Protection Regulation (the “GDPR”). An important aspect of this obligation is to inform individuals of how we process their personal data.

Your integrity is important to us. This Privacy Policy describes what personal data we process when you visit our website, express an interest in participating in our playtests, and if you chose to send an application to us.

2. CONTROLLER

Controller
Embark Studios AB
Corporate identification number: 559172-3019

Address: 
Kungsträdgårdsgatan 16
111 47 Stockholm
Sweden

Email
privacy@support.embark-studios.com

3. WHAT CATEGORIES OF PERSONAL DATA WILL WE PROCESS?

Visitors of our website

When you visit our website, we will not collect or process any of your personal data. For information on any use of cookies on the website, please see our cookie settings.

Candidates

If you chose to apply for an open position or submit a general open application we process the following personal data about you:

  • Contact information such as name, address, e-mail address and phone number

  • Information included in your CV and/or personal letter such as age, photo, qualifications and references

  • Notes from interviews and reference contacts

Sign up for Embark ID

When you register for Embark ID, or log in using another platform, we process the following personal data about you: 

  • Name

  • Email address

  • Embark ID (created upon your registration or download of our games from another platform)

  • Your chosen display name

  • Personal data shared by any connected third party platform, subject to such platform's privacy settings and the information you receive when you link the accounts (to the extent you choose to connect any third party platform to your account)

Signing up for playtesting

When you sign up for playtesting, we process the following personal data about you:

  • Name and contact information such as e-mail address or other communication handles (e.g. Discord username and platform IDs)

  • Demographic information such as age and country

  • Information about your player preferences and prior player experience 

  • Technical and practical information such as the kind of equipment you have available

We use different processes to sign up for playtesting. If you sign up by joining the Embark Playtesting Discord server we will initially only collect your Discord username. You will provide the additional information listed above by interacting with the Discord server, via surveys leading up to playtest sessions and/or via account verification.

The types of data processed in playtests will differ and we will share more information with you prior to the relevant test.

Subscribing to our newsletters and joining our initiatives

When you subscribe to our newsletters we process your email address.

If you choose to join marketing events or other initiatives such as creator programs, we process your personal data in accordance with the information we provide to you during signup or enrollment.

Communicating with us or requesting support

If you choose to communicate with us or request support (through available support channels) we process your email address and IDs related to third party platforms used by you.

4. ACCESS

When you submit an application or register with Embark, Embark collects your personal data directly from you. The processing of personal data is necessary for us to be able to evaluate the application, enter into an agreement with the relevant candidate(s), and register an account or add you to our playtesting register.

5. FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS PERSONAL DATA?

Candidates

We process your personal data in order to be able to evaluate and register you as a candidate, book potential interviews and manage contacts with you. 

The legal basis for processing is that the processing is necessary in order to enter into a potential agreement with the candidate(s) and Embark’s legitimate interest. Embark’s legitimate interests is to manage the recruitment process and evaluate the candidates that have shown an interest in Embark. Such process is also in the interest of the candidates.

Embark ID

We process personal data about you in order to register an Embark account upon your request. We also want to ensure that we can identify you in the Embark games and environment when you log in using another platform and/or chose to download an Embark game directly from another platform.

The processing of personal data carried out by Embark is that the processing is necessary to act on a request from you (namely to register and create an Embark account). 

The processing may also be based on Embark’s legitimate interest (when logging in or downloading a game from another platform), where processing is necessary to satisfy Embark’s legitimate business interest of providing the game to you upon your request. 

Signing up for playtesting

When you’ve expressed interest in participating in our playtesting program, we need to be able to contact you about relevant playtesting opportunities and to confirm your participation in playtests. This enables us to make necessary arrangements with you once a playtest will be performed. 

The key purpose of our playtests is to make sure we are listening to a diverse group of players as we develop our games. This principle also applies to how we invite participants to feedback on our games. By providing us with information about your play habits, player history and the type of games you enjoy, you help us to inform you of playtesting opportunities that match your player preferences. 

The processing of personal data carried out by Embark is based on legitimate interest. This applies to the selection of testers for our playtests where we are interested in your player preferences, your demographics and player history to match with the intended target group of the playtest. The purpose is to set up the playtest in accordance with the current interest and needs of Embark, where processing is necessary to satisfy Embark’s legitimate business interests of developing games and service offerings. 

Should you ever want to leave our playtesting program and opt-out from future contacts, you can do so at any time by emailing playtesting@embark-studios.com to have your data removed from our records.

Subscribing to our newsletters and joining our initiatives

We process your email address in order to provide you with news and updates about our games. We carry out this processing in response to your request to receive the newsletter.

If you want to deregister from our newsletter and opt out of future communications, you can do so at any time by simply clicking the unsubscribe link in our newsletter or by emailing privacy@support.embark-studios.com to have your data removed from our records.

We process your personal data as provided by you when you join marketing events or other initiatives such as creator programs in order to communicate with you and to enable your participation. We carry out this processing in response to your request to join the relevant initiative.

Communicating with us or requesting support

We process your personal data in order to respond to your communication and manage the support matters as requested by you.

The processing is based on Embark’s legitimate interest, where processing is necessary to satisfy Embark’s legitimate business interests of communicating with you, managing our IT environment and providing the game to you upon your request (when support is requested in a game context).

6. FOR HOW LONG DO WE KEEP PERSONAL DATA?

We will process the personal data only as long as necessary for the purposes set out above. If you chose to send an application to us, we will keep your personal data for two (2) years from the end of the application process in order to comply with relevant employment and anti-discrimination legislation.

7. WHO CAN WE SHARE PERSONAL DATA WITH?

Embark suppliers

In order for us to be able to fulfill our commitments, we transfer personal data to suppliers of Embark, in particular our service providers of various IT-services. The suppliers that Embark discloses personal data to will only process the personal data for the purposes mentioned in this Privacy Policy. Embark has entered into data processing agreements with its suppliers that meet the requirements of applicable data protection legislation.

For the recruitment process Embark is currently using Teamtailor, a recruitment platform, LinkedIn Recruiter and RefApp, a reference management application. Your personal data will be transmitted to and stored by these suppliers. As mentioned, Embark and the suppliers have entered into a data processing agreement, ensuring that your data is only being processed according to the information above.

For the Embark ID and account registration and signing up for playtesting Embark is currently using AWS, an email management solution used to send you verification emails and/or invitations to playtesting and similar communication. We also utilize Mailchimp for similar purposes. For registration to playtesting, Embark is also using Alchemer which is a tool generating the playtesting form. As mentioned, Embark and the suppliers have entered into a data processing agreement, ensuring that your data is only being processed on behalf of Embark and according to the information above.

Where applicable, we share data in order to fulfill your connection request. For example, Twitch will be able to read your email and email verification status. Third party platform providers will process your personal data as data controllers in accordance with their respective privacy policies and notices. Please also refer to the detailed information you receive when you choose to connect any third party platform to your Embark account. 

Embark may cooperate with third parties for the management of marketing events and other initiatives such as creator programs.

For the management of support requests Embark is currently using Keywords to allow you to send a support request and forward it to Embark. As mentioned, Embark and the suppliers have entered into a data processing agreement, ensuring that your data is only being processed on behalf of Embark and according to the information above.

For the avoidance of doubt, Embark will not sell your personal data, use it to market any products not distributed by Embark or communicate with you in a manner that is contrary to your preferences as communicated by you.

8. TRANSFERS TO THIRD COUNTRIES

Embark always seeks to process personal data within the EU/EEA but in the event of a transfer of personal data outside the EU/EEA, Embark will observe applicable data protection legislation regarding transfers to third countries. Embark will only transfer personal data to a country outside the EU/EEA provided that (i) the third country ensures an adequate level of protection of personal data under a decision issued by the EU Commission, (ii) Embark ensures that appropriate safeguards and security measures are in place according to applicable data protection legislation; or (iii) if any other exception exists under applicable data protection legislation.

9. RIGHTS

According to the GDPR you have the right to request:

  • A confirmation from Embark about how we process personal data, and in such case request access to the personal data in the form of an extract from the register

  • Correction of incorrect or incomplete personal data

  • Deletion of your personal data in some cases, e.g. if your personal data is no longer necessary for the purposes for which they were collected

  • Objection to processing that relies on legitimate interests

  • Restriction of the processing of your personal data meaning that you request Embark to limit its processing of your personal data under certain circumstances

  • Receipt and transfer of personal data to another controller in some cases (data portability)

You also have the right to lodge complaints regarding the processing to a supervisory authority within the EU. When requesting access to your personal data, please contact Embark at email: privacy@support.embark-studios.com

Updated on 2023-10-26