This Playtest Privacy Notice was updated on September 5, 2022.
Table of Contents
INTRODUCTION
HOW & WHEN WE COLLECT YOUR PERSONAL DATA
TYPES OF PERSONAL DATA WE COLLECT
WHY & HOW WE USE YOUR PERSONAL DATA
ARTIFICIAL INTELLIGENCE & MACHINE LEARNING
KEEPING YOUR PERSONAL DATA SECURE
WHO WE SHARE PERSONAL DATA WITH
WHERE YOUR PERSONAL DATA IS PROCESSED
HOW LONG WE HOLD YOUR DATA FOR
YOUR RIGHTS OVER YOUR PERSONAL DATA
DATA PROTECTION OFFICER
CHANGES AND UPDATES TO THIS PLAYTEST PRIVACY NOTICE
ANY QUESTIONS?
INTRODUCTION
Hi. We’re Eidos Interactive Corporation (“we,” “our” or “us”). You probably know us from the entertainment content we develop, publish, distribute, and license, including: DEUX EX® and THIEF®.
This Playtest Privacy Notice applies to you if you are participating in a playtesting session, or if you have applied or registered an account to participate in a playtesting session with us. Please take the time to read this Playtest Privacy Notice, as it explains how we will use your personal data (referred to as “personal information” in some jurisdictions), respect your privacy and protect your information. If you are under the age of 14, you may only share your personal data with us if your parent or legal guardian has reviewed this Playtest Privacy Notice and provided their consent.
Please note that this Playtest Privacy Notice does not apply to your use of our other products and services. For more information on the collection and use of your personal data when you use our other products and services, please review our General Privacy Notice.
HOW & WHEN WE COLLECT YOUR PERSONAL DATA
You give us data when you: apply to be a play tester on our playtest register, update your playtest account or take an online survey during a test.
We collect your data automatically when you: test or otherwise interact with our games in our research facility.
TYPES OF PERSONAL DATA WE COLLECT
Contact details
Your name, address, telephone number, and email address.
Account profile data
Your name, email address, birth date, and city.
Information that identifies you
Your name, birth date, and IP address.
Gaming profile information
Gaming frequency, favorite genres, consoles owned, and other related information depending on the game being tested.
Information on how you played the game being tested
The gaming platform you are using, mobile and hardware identifiers, device event information, language options you choose, subtitles selected, version of the game being played, game scores, game metrics, achievements, rankings, time played, game feature usage, player performance and progression, controller inputs, input patterns, webcam footage (in the test area), eye tracking, timestamp and session duration.
Game test survey information
Any information that you decide to provide to us on the surveys including; competitors you played in the past, expectations regarding our franchises, opinions regarding different aspects of the game you just played (narrative, gameplay, graphics, pacing, difficulty and other similarly related info).
Information recorded at the Playtest research facility
Photographs and/or videos of you, including emotional reactions.
What about sensitive data?
Should you consent, we may record your following biometric data: facial emotion recognition, eye tracking, galvanic skin response and heart rate.
If you have been invited and decided to join our accessibility playtest group, we may collect information related to your accessibility requirements, which you provide to us in related surveys and during gameplay tests you participate in.
WHY & HOW WE USE YOUR PERSONAL DATA
We will only use your personal data for certain specified reasons and only where we have a lawful basis to do so. Below are the reasons we use your personal data:
Registering your account
When you apply to join the Playtest Lab, we will use the details provided on your account registration form to process your application and contact you about playtesting sessions.
Improving and developing our games and services
In-game data collection, analytics and research, cheat detection and prevention, understanding emotional reactions, and heat mapping the use of our games.
ARTIFICIAL INTELLIGENCE & MACHINE LEARNING
We will only use your personal data for artificial intelligence (AI) and machine learning purposes if you have specifically consented to this use. For instance, where you have consented, we may detect your emotions from the webcam feed when you test our game(s) or may use computer vision to detect certain moments during gameplay and analyze input patterns. We may feed the webcam footage into our machine learning model once we have properly identified a specific emotion.
KEEPING YOUR PERSONAL DATA SECURE
We will treat your data with the utmost care and take all reasonable steps to protect it. With that in mind, we have a range of robust policies, processes, and technical measures in place, and maintain physical, technical, and administrative safeguards to protect your personal data.
If you believe your personal data has been breached, please contact us immediately by email at privacynotice@eidosmontreal.com.
WHO WE SHARE PERSONAL DATA WITH
Third parties may process information about your use of our games on our behalf. We provide these trusted third parties only the information they need to perform their specific services for the purposes we specify in our contract with them. If we stop using their services, any of your data held by them will either be securely and permanently deleted or rendered irreversibly anonymous. In all cases, we apply measures to keep your data safe and your privacy protected.
We may share your personal data with third-party IT companies who support our online services and other business systems, as well as fraud detection and prevention companies who help us prevent, detect, and investigate cheating, abuse, fraud, tampering, or other unauthorized use of our games or services.
We may share your information with our affiliate companies within and outside of the United States. In the event some or all of our company will be acquired by another party, we may share your information with the acquiring party.
Under very specific circumstances, we will share your personal data with third parties (including law enforcement bodies) in order to investigate and prevent fraudulent or criminal (or potentially fraudulent or criminal) activity. We may also be required by law to disclose your personal data to the police or to another law enforcement, regulatory, or government body in your country of origin or elsewhere, including upon receiving a legally valid request to do so. We assess these requests on a case-by-case basis, and we take the privacy of our Playtest Lab members into consideration when responding.
WHERE YOUR PERSONAL DATA IS PROCESSED
We are a global organization, so we sometimes need to share your personal data with our other offices or affiliates, or with other third parties and suppliers who may be located in a jurisdiction outside of where your personal data was collected.
When it is necessary for us to transfer your personal data to another country, we will only do so where the transfer is authorized under applicable data protection and privacy laws. Your personal data may be processed by our service providers in Canada and the United-Kingdom.
HOW LONG WE HOLD YOUR DATA FOR
We will only retain your personal data for as long as necessary for the purpose(s) for which the data was collected and for no longer than is necessary after that. We will securely destroy or irreversibly anonymize the information once it is no longer necessary to retain it. We operate a data retention policy and continually review it to ensure we are not holding onto your information for longer than is necessary.
YOUR RIGHTS OVER YOUR PERSONAL DATA
This section describes the various rights you have over your personal data.
Your right of access
You have the right to request copies of your personal data. This right always applies. However, there are some exemptions, which means you may not always receive all the personal data you request.
Your right to rectification
You have the right to request that we rectify information you think is inaccurate or complete information you think is incomplete. This right always applies.
Your right to erasure
You have the right to request that we erase your personal data in certain circumstances.
Your right to restriction of processing
You have the right to request that we restrict the processing of your personal data in certain circumstances.
Your right to object to processing
You have the right to object to us processing your personal data under certain circumstances.
Your right to data portability
You have the right to request that we transfer your personal data to another organisation, or that we provide a copy of it to you.
You are not required to pay any charge for exercising these rights.
To exercise your above rights, or any other rights available to you under applicable law, please email us at privacynotice@eidosmontreal.com
You may also lodge a complaint regarding our use of your personal data. If you have such a complaint, we ask that you please tell us first so we can have a chance to look into your concerns. If you remain unsatisfied, you can contact your local Supervisory Authority, as applicable under privacy laws that apply to you, such as Office of the Privacy Commissioner of Canada on their website at https://www.priv.gc.ca/en/report-a-concern/.
DATA PROTECTION OFFICER
We have appointed a data protection officer for you to contact if you have any questions or concerns about your personal data. Our data protection officer can be contacted by email at: privacynotice@eidosmontreal.com, or by writing to Eidos-Montréal, DPO – Legal Department 400, Boulevard De Maisonneuve Ouest Montréal (Québec) H3A1L4 Canada.
CHANGES AND UPDATES TO THIS PLAYTEST PRIVACY NOTICE
As our games and services change from time to time so may our Playtest Lab, and you should expect this Playtest Privacy Notice to change as well. We reserve the right to amend this Playtest Privacy Notice at any time, for any reason. We will do our best to notify you of any changes. We may also email periodic reminders of this Playtest Privacy Notice.
ANY QUESTIONS?
You made it to the end! We do hope you have enjoyed reading this Playtest Privacy Notice and we commend you on your dedication to understanding how we handle your personal data and your rights to control it. If this Playtest Privacy Notice hasn’t answered all your questions, or if you have any comments or ideas about how we can make this Playtest Privacy Notice even better, please contact us at privacynotice@eidosmontreal.com.
