Website Privacy Policy

Kinetic Games Privacy Notice

We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal data. It also explains your rights in relation to your personal data and how to contact us or the relevant data protection authority in the event you have a complaint.

This privacy notice is in a layered format so you can click through to the specific areas set out below which you would like to know more about.

It is important that you read this privacy notice, together with any other privacy notice 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 personal data. This privacy notice supplements the other notices and is not intended to override them.

  • Key terms
  • Who we are
  • Personal data we collect and use
  • How your personal data is collected
  • How and why we use your personal data
  • What we use your personal data for
  • Who we share your personal data with
  • How long your personal data will be kept
  • Transferring your personal data outside of the UK/EEA
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this privacy notice
  • How to contact us
  • Do you need extra help?

Key Terms

The following are some key terms used in this privacy notice and an explanation of what those key terms mean:

we, us, our

means Kinetic Games Limited (a company registered in England and Wales under company number: 12966685)

distributors

means Valve Corporation (Steam), HTC Corporation, Sony Corporation (for Playstation), Microsoft (for X-box) and Unity

games

means Phasmophobia and any other game developed by us

personal data

means any information relating to an identified or identifiable individual

Who we are

We are Kinetic Games Limited, a video games developer and publisher; for more information see https://kineticgames.co.uk/.

If you play our games, we will collect and use certain personal data about you. When we do so we are responsible for your personal data and are subject to:

  1. for UK players, the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
  2. for players based in the European Economic Area (EEA), the EU General Data Protection Regulation (EU GDPR).
  3. for other individuals, we will be subject to the UK GDPR when collecting and using personal data about you as we are a UK organisation together with any relevant data protection laws which protect your personal data in the country in which you reside (Equivalent DP Laws). Where Equivalent DP Laws apply to you, references in this privacy notice to the UK GDPR and the EU GDPR and transfers of personal data outside of the UK or the EU / EEA shall be to the nearest equivalent provision in the Equivalent DP Laws.

Our games are not intended for children and we do not knowingly collect data relating to children.

Personal data we collect and use

The type of personal data we collect depends on our relationship with you and the method by which we collect the personal data. The table below sets out the personal data we may collect about you:

Type

Personal data collected

identity personal data

Name
Title
Job title
Gender or pronouns, if you choose to give this to us

contact personal data

Email address

Steam account data

This includes your Steam ID and display name
Other details necessary to confirm you are authorised to play our games

HTC account data

Your infinityTag (ID for HTC Vive users) and display name
Other details necessary to confirm you are authorised to play our games

Sony account data

Playstation ID and display name
Other details necessary to confirm you are authorised to play our games

Microsoft account data

Xbox ID and display name
Other details necessary to confirm you are authorised to play our games

Unity account data

ID
Other details necessary to confirm you are authorised to play our games

Discord user details

Discord username
ID
Profile picture

IP address

username/alias

game data

Details of your in-game progress

reporting data

Account identity/username/alias of individual making report
Account identity/username/alias of individual being reported
Confirmation of whether individual being reported has been previously banned
Reason for making report
Date and time of report

other personal data

Personal data we ask for or that you volunteer to us when you use in-game voice chat, when you provide feedback or bug reports, when you communicate with us by email or via Discord or information from social media accounts when interacting with us via a personal profile (such as YouTube, X, Instagram, Facebook, TikTok and Threads)

We collect and use this personal data for the purposes described in the section: ‘How and why we use your personal data’.

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 the data about how you use our games to calculate player average session times. 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 notice.

If you do not provide personal data

We require you to provide certain personal data to enable your use of our games and related online services. If you do not provide your personal data when asked, you may not be able to access our online services, we may not be able to resolve your problem if you request support, and the functionality of our games may be impaired.

How your personal data is collected

We may collect personal data:

  • from you;
  • from our distributors (e.g. your user ID);
  • from your device;
  • via our reporting system; and
  • from an employee or representative of the organisation you represent.

How and why we use your personal data

Under the UK GDPR and the EU GDPR, we can only use your personal data if we have a proper reason (i.e., a lawful basis) for doing so, for example:

  • to comply with our legal obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

What we use your personal data for

The table below explains what we use your personal data for, how we use it, our lawful basis for doing so, and the categories of personal data we use.

What we use your personal data for

Our purpose for using your personal data

Lawful basis (UK/EU GDPR)

What personal data we may use

For players – to provide our games to you and enable you to interact with other players

We collect your personal data and share it with our trusted partners so that you can play our games and we share your username with other players so that you can interact with other players when playing our games. We will store your personal data on our IT systems and destroy it in accordance with our data retention and other business policies.

Necessary for your and our legitimate interests (Article 6(1)(f))

Steam account data (if applicable)
HTC account data (if applicable)
Sony account data (if applicable)
Microsoft account data (if applicable)
Unity account data
IP address
username/alias
game data
other personal data

For players - to verify your purchase of our game

We use your user ID to verify your purchase of our games via one of our distributors. We will store your personal data on our IT systems and destroy it in accordance with our data retention and other business policies.

Necessary for your and our legitimate interests (Article 6(1)(f))

Steam account data
HTC account data
Sony account data
Microsoft account data

For players - to provide a fair gaming experience to all players

We collect personal data via channels such as the in-game reporting journal and use it to assess game behaviour in accordance with our code of conduct (https://www.kineticgames.co.uk/code-of-conduct) and where appropriate, impose a ban on a player.

Necessary for your and our legitimate interests (Article 6(1)(f))

Steam account data (if applicable)
HTC account data (if applicable)
Sony account data (if applicable)
Microsoft account data (if applicable)
Unity account data
IP address
username/alias
game data
reporting data
other personal data

For players - to enable you to enjoy the benefit of the full functionality of our games

We collect your personal data and use it to ensure you have access to the full functionality of our games.

Necessary for our legitimate interests (Article 6(1)(f))

Steam account data (if applicable)
HTC account data (if applicable)
Sony account data (if applicable)
Microsoft account data (if applicable)
Unity account data
IP address
username/alias
game data
other personal data

For players - to ensure there is a cloud back up of your in-game progress

We collect your in-game related personal data and store it in the cloud. We will destroy your personal data in accordance with our data retention and other business policies.

Necessary for our legitimate interests (Article 6(1)(f))

Steam account data (if applicable)
HTC account data (if applicable)
Sony account data (if applicable)
Microsoft account data (if applicable)
Unity account data
IP address
username/alias
game data
other personal data

For players – to enable you to provide feedback, make an enquiry, request support and submit bug reports and for us to troubleshoot any identified issues, send you updates about the game, provide support and correspond with you

We collect your personal data via email, Discord, or social media and use it to record your feedback, deal with your enquiry, analyse and process your bug reports, resolve technical issues, provide support and updates, and correspond with you.

Necessary for your and our legitimate interests (Article 6(1)(f))

identity personal data
contact personal data
Steam account data (if applicable)
HTC account data (if applicable)
Sony account data (if applicable)
Microsoft account data (if applicable)
Unity account details
Discord user details
IP address
username/alias
game data
other personal data

For individuals who represent distributors, suppliers and other third parties with whom we have contracts – to correspond with you

We collect your personal data and use it to correspond with you about the contract involving the organisation you represent.

Necessary for the legitimate interests of the organisation you represent and our legitimate interests (Article 6(1)(f))

identity data
contact data
other personal data

For audits, enquiries or investigations by regulatory bodies or law enforcement agencies

We will extract your personal data from our IT systems and disclose it as required by law or further to a court order.

Necessary for compliance with a legal obligation (Article 6(1)(c))

Potentially any personal data

To ensure our business policies are adhered to (e.g. security policies)

We will check our use of your personal data against our business policies.

Necessary for our legitimate interests (Article 6(1)(f))

Potentially any personal data

To prevent unauthorised access and modifications to our systems

We will put in place reasonable and appropriate security measures to protect the integrity of our systems that hold your personal data.

Necessary for compliance with a legal obligation (Article 6(1)(c))
Necessary for our legitimate interests (Article 6(1)(f))

Potentially any personal data

To enforce or apply terms and conditions or any other agreements relating to our games

We will review your personal data held in our IT systems and, if appropriate, use it to take enforcement action, including legal proceedings.

Necessary for our legitimate interests (Article 6(1)(f))

Potentially any personal data

To deal with complaints or legal claims against us

We will review your personal data in our IT systems and may collect other information relevant to the complaint/legal claim. We will review any information collected and assess the merits of any complaint or legal claim.

Necessary for our legitimate interests (Article 6(1)(f))

Potentially any personal data

To provide personal data to other third parties that have or may acquire control or ownership of our business or part of our business ...

We will extract your personal data from our IT systems and disclose it as necessary in connection with a corporate transaction or restructuring.

Necessary for your and our legitimate interests (Article 6(1)(f))

Potentially any personal data

Where possible information will be anonymised during a transaction and until completion of the transaction but this may not always be possible

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Who we share your personal data with

Depending on the circumstances, we may share your personal data with:

Category of recipient

Further details

Use by recipient

Personal data that may be shared

Other players

For enabling interaction between players when playing our games

username

Third party service provider

Exit Games

For enabling you to use our online services and play our games with other players

Steam account data (if applicable)
HTC account data (if applicable)
Sony account data (if applicable)
Microsoft account data (if applicable)
IP address
username/alias
game data
other personal data

Third party service provider

Unity Gaming Services

For storage to the cloud of your in-game progress
To assist with game functionality

Device hardware ID
Steam account data
HTC account data
Sony account data
Microsoft account data
IP address
game data

Third party service provider

Unity Gaming Services (Vivox)

For hosting of in-game voice chat and voice servers (multiplayer functionality)

IP address
game data
other personal data

External IT service providers

Email service provider

For providing an email service to us

External bot providers (listed on our Discord server)

Discord bot service provider, Discord bot data storage provider and third party bot providers we use to help us moderate and reply to posts submitted on our Discord server

For providing the Discord service to us

identity personal data
contact personal data
Discord user details
username/alias
game data
other personal data

Law enforcement/regulatory agencies

e.g. the Information Commissioner’s Office

For their investigations

Potentially any personal data

Our insurers, brokers and professional advisers

Professional advisers e.g. solicitors, barristers, IT specialists

For assisting, advising and representing us as necessary

Potentially any personal data

Other parties that have or may acquire control or ownership of our business or part of our business

Potentially any personal data

Where possible information will be anonymised during a transaction and until completion of the transaction but this may not always be possible

We do not sell your information to third parties.

We only allow our service providers (who are processors of your personal data) to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on those service providers to ensure they can only use your personal data to provide services to us. Other recipients, such as our professional advisers who are controllers of your personal data due to the nature of the services they provide, are bound by confidentiality obligations.

How long your personal data will be kept

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including:

  • to respond to any questions, complaints or claims made by you/the company you represent;
  • to bring or defend legal claims;
  • to show that we treated you fairly; and
  • to keep records required by law to comply with our legal and regulatory obligations.

We will not retain your data for longer than necessary for the purposes set out in this privacy notice.

We have set out below some further information about our retention periods:

  • IP address: For no longer than your use of the online service for that session.
  • Steam/HTC/Sony/Microsoft account data, username/alias, and game data – where there is an error during your use of our online services: Exit Games will retain your data for no longer than four weeks for the purposes of improving our online services.
  • Voice communications: Until transmission to other players is complete.
  • Personal data held on Discord server: Until you delete a message.
  • Reporting data (if you make a report or a report is made about you): We retain reporting data for two years from the date of the report. If you are banned from multiplayer then we will retain reporting data indefinitely in order to protect other players.

Transferring your personal data outside of the UK / EEA

Your personal data may be transferred outside of the UK or the EEA (depending on where you are based) to:

  • the USA in order for Exit Games to provide their services;
  • the location of the relevant server you choose to play our game on (e.g. the USA, Europe) in order for Exit Games to provide their services;
  • our other third party service providers including Unity Gaming Services; and
  • enable us to provide our services to you and for you to connect with other players using our online services who are based throughout the world.

We will ensure the transfer complies with the UK GDPR and EU GDPR by ensuring that for example:

  • the country to which the personal data is being transferred is subject to an adequacy decision/regulation (Article 45);
  • the transfer is necessary for the performance of a contract between you and us (Article 49);
  • the transfer is necessary to establish, exercise or defend legal claims (Article 49);
  • there are appropriate safeguards in place (e.g. approved data protection contractual terms); or
  • you have provided explicit consent to the proposed transfer (Article 49).

Please contact us (see below: ‘How to contact us’) if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK/EEA.

Your rights

You have the following rights, which you can exercise free of charge. Your rights will differ depending on our lawful basis for processing your personal data:

Right

Description

Access

The right to be provided with a copy of your personal data.

Rectification

The right to require us to correct any mistakes in your personal data.

Erasure (right to be forgotten)

In certain situations, the right to require us to delete your personal data.

Restriction of processing

In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data while we verify it.

Data portability

In certain situations, the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party.

To object

The right to object in certain situations to our continued processing of your personal data (e.g. for legitimate interests), unless there are compelling legitimate grounds for the processing to continue.

To withdraw consent

If you have provided us with consent to use your personal data you have a right to withdraw that consent easily at any time. To do this, please email us (see below: ‘How to contact us’). Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

We do not use personal data for automated decision making.

For further information on each of the above rights, including the circumstances in which they apply, please contact us or, if you are based in the UK, see the Guidance from the UK Information Commissioner’s Office on individuals’ rights under the GDPR.

If you would like to exercise any of the above rights, please email us (see below: ‘How to contact us’) and provide:

  • enough information to identify you (e.g. your name or username);
  • proof of your identity and address, if we ask for it; and
  • information about what right you want to exercise and the personal data to which your request relates.

Keeping your personal data secure

We have put in place reasonable and appropriate security measures to endeavor to prevent personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

In order for us to provide our online services to you, we use and link to services owned and operated by our distributors. Our distributors may also gather personal data about you in accordance with their own separate privacy notices. For privacy information relating to our distributors, please consult their privacy notices as appropriate.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your personal data. If you want to complain about how we have used your personal data, please email us (see below: ‘How to contact us’). However, if we are not able to resolve your complaint to your satisfaction, you can complain to the UK’s Information Commissioner’s Office (ICO) if you are based in the UK or the supervisory authority in the country or territory where you work, normally live, or where any alleged infringement of data protection laws occurred.

Further information about how to make a complaint to the ICO can be found on the ICO website.

Changes to this privacy notice

We may change this privacy notice from time to time and when we do so, we will put the updated version on our website. If any changes are likely to have an adverse impact on your rights under the UK GDPR and EU GDPR, we will use reasonable endeavours to notify you of the changes in advance.

How to contact us

If you have any queries about this privacy notice or how we use your personal data, you can contact us by sending an email to: [email protected]

Do you need extra help?

If you would like this privacy notice in another format (for example, large print), please contact us (see above: ‘How to contact us’).

Version history

February 3rd 2025
Version 3

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