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PNEUMA END USER LICENSE AGREEMENT
PLEASE READ THESE TERMS CAREFULLY
This end user licence agreement (EULA) is a legal agreement between you (you) and Gravity Grid Studios Limited, (us or we) regarding your use of our computer game software and includes any applicable updates, “patches” and modifications applied or activities carried out by us to support, maintain and otherwise run the game as a service (the Game).
We license use of the Game to you on the terms of this EULA. We do not sell the Game to you and this EULA confers no title or ownership to the Game or any copy thereof. We remain the owner of the Game at all times.
OPERATING SYSTEM REQUIREMENTS: This Game requires a device that meets or exceeds certain requirements in order to play. We recommend a PC with at least the following:
Intel Core i5-4590 / AMD Ryzen 5 2600 CPU;
NVIDIA RTX 2060 / AMD Radeon RX 5700 GPU;
8GB RAM;
Windows 10;
an Internet connection with a minimum download/upload speed of 10Mbps/6Mbps; and
a microphone, to use some features of the game such as voice recognition, voice play-back and multiplayer online voice chat, but there may be other requirements that need to be met in order to play the Game. We therefore do not warrant that you will be able to play the Game if these recommended minimum requirements are met.
AGREED TERMS
1 GRANT AND SCOPE OF LICENCE
1.1 In consideration of you agreeing to abide by the terms of this EULA, we hereby grant to you a limited, indefinite, non-exclusive and non-transferable licence to use the Game on the terms of this EULA.
1.2 You may:
1.2.1 install and use the Game for your personal purposes only; and
1.2.2 receive and use any free supplementary software code or update of the Game incorporating “patches” and corrections of errors as may be provided by us from time to time (but see clause 1.3).
1.3 We may update or require you to update the Game, provided that the Game shall substantially match the description of it that we provided to you before you bought it.
2 RESTRICTIONS
2.1 Except as expressly set out in this EULA or as permitted by any local law, you undertake:
2.1.1 not to copy the Game, except where such copying is incidental to normal use of the Game or where it is necessary for the purpose of back-up or operational security;
2.1.2 not to rent, lease, sub-licence, loan, translate, merge, adapt, vary, alter or modify, the whole or any part of the Game nor permit the Game or any part of it to be combined with, or become incorporated in, any other programs;
2.1.3 not to disassemble, de-compile, reverse engineer or create derivative works based on the whole or any part of the Game nor attempt to do any such things, except to the extent that (by virtue of sections 50B and 296A of the Copyright, Designs and Patents Act 1988) such actions cannot be prohibited because they are necessary to decompile the Game to obtain the information necessary to create an independent program that can be operated with the Game or with another program (Permitted Objective), and provided that the information obtained by you during such activities:
(a) is used only for the Permitted Objective;
(b) is not disclosed or communicated without our prior written consent to any third party to whom it is not necessary to disclose or communicate it in order to achieve the Permitted Objective; and
(c) is not used to create any software that is substantially similar in its expression to the Game;
2.1.4 to keep all copies of the Game secure and to maintain accurate and up-to-date records of the number and locations of all copies of the Game;
2.1.5 to include our copyright notice on all entire and partial copies of the Game in any form;
2.1.6 not to provide, or otherwise make available, the Game in any form, in whole or in part (including, but not limited to, program listings, object and source program listings, object code and source code) to any person without prior written consent from us;
2.1.7 to comply with all applicable technology control or export laws and regulations;
2.1.8 not to create, use, offer, advertise, make available and/or distribute any code, data, method or device:
(i) that influences and/or facilitates gameplay and thereby gives you and/or any other user an advantage over other players not using such means;
(ii) that accesses or modifies the Game in a manner not authorised by us; or
(iii) that can be used in connection with the Game, and/or any component or feature of it which changes and/or facilitates the way the game is played and/or imitates or copies data or functionality in the Game;
2.1.9 not to make improper use of our support services;
2.1.10 not to disrupt, or overload whether directly or indirectly servers used to support the Game or launch or participate in any type of attack, or otherwise attempt to disrupt the use and operation of the Game including but not exclusively by denial of service attacks;
2.1.11 not to sell, charge others for the right to use, or transfer any in-game content or Third-Party Account (as defined below) in connection with the Game;
2.1.12 not to access, intercept, or otherwise collect information without or consent by any means: (a) from or through support services we may provide for the Game, (b) that is in transit from or to the Game, or (c) that is contained in network traffic used by the Game to store information about content related to the Game.
2.2 You agree not to do any of the following whilst using the Game:
2.2.1 anything that contravenes our Code of Conduct or our gaming content guidelines.
2.2.2 attempt to, or harass, abuse, or harm, or advocate or incite harassment, abuse or harm of another person;
2.2.3 act in any way (including by transmitting or causing to be transmitted any communication) that would objectively be considered to be of an inappropriate nature including in a manner that is disruptive, unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, hateful, racially, sexually, or ethnically objectionable;
2.2.4 impersonate any person or entity, including but not limited to other users of the Game;
2.2.5 disrupt the normal functionality of the Game, or otherwise act in a manner that negatively affects other users of the Game;
2.2.6 except in accordance with and to the extent permitted by our Guidelines, post or transmit any advertising, promotional materials, or anything similar;
2.2.7 violate any applicable law while using or accessing the Game;
2.2.8 transmit unauthorised communications, including junk mail, chain letters, spam and any materials that promote malware, spyware and downloadable items;
2.2.9 make available any material or information that infringes any copyright, trademark, patent, trade secret, right of privacy, right of publicity, or other right of any person or entity or impersonates any other person; or
2.2.10 invade the privacy or violate or infringe any right of any person or entity, including by soliciting, collecting, harvesting or posting anyone's private information, including personally identifiable information (whether in text, image or video form), identification documents, or financial information through the Game.
3 INTELLECTUAL PROPERTY RIGHTS
3.1 You acknowledge that all intellectual property rights and all similar or equivalent rights or forms of protection, which subsist or will subsist now or in the future, in any part of the world (IPR) in the Game belong to us, that rights in the Game are licensed (not sold) to you, and that you have no IPR in, or to, the Game other than the right to use the Game in accordance with the terms of this EULA.
3.2 You acknowledge that you have no right to have access to the Game in source code form other than as expressly provided in this EULA.
4 UPDATES TO THE EULA AND OUR PRIVACY POLICY
4.1 We reserve the right, at our discretion, to change, modify, add or remove portions of this EULA and/or our privacy policy at any time by posting the updated EULA and/or our privacy policy on our website or by providing you with digital access to the amended EULA and/or our privacy policy through the Game or other means.
4.2 If you do not agree to any term of this EULA (or any updated version of such as adopted), you may terminate the EULA immediately without notice, and you must stop using the Game immediately.
4.3 The terms of any updated EULA shall automatically become effective after 30 days if they are posted on our website or Steam. By using the Game after the updated EULA becomes effective, or otherwise indicating your acceptance of the updated EULA, you agree to be bound by the terms of the updated EULA.
5 GAME UPDATES
5.1 From time to time we may provide updates and other modifications to the Game that must be installed for you to be able to continue to play the Game properly or at all. We may update or modify the Game for such purpose. You hereby grant us the right to deploy and apply such updates and modifications.
5.2 To help us provide you with the best gameplay experience possible, we may collect data relating to how you play the game, including what actions you take or selections you make, how long you play for and the performance of our online systems when you connect. This data is anonymised and is only kept for a reasonable period for analysis purposes. For further details, please see our privacy policy.
6 USER ACCOUNTS
6.1 In order to use the Game and for us to provide software features relating to the Game so that it operates correctly, you may be required to have and maintain a valid and active user account with an online service, such as a third-party gaming platform (Third-Party Account). If you do not maintain such an account, then certain features of the Game may not operate or may cease to function properly, either in whole or in part. You are responsible for all use and the security of your Third-Party Account that you use to access and use the Game.
6.2 This EULA is subject to the additional terms and conditions of or required by any applicable Third-Party Account and you shall comply with any applicable Third-Party Account terms and conditions. We are not responsible or liable to you for any credit card or other charges or fees related to your purchase transactions in respect of the Game made via a Third-Party Account. All such transactions are administered by the Third-Party Account.
7 USER COMMUNICATIONS
7.1 We may provide chat or other communication features as part of the Game and the support services for the Game (Communication Features). The Communication Features must always be used in compliance with our Code of Conduct. You also undertake that in using any Communication Features you will comply with your obligations set out in section 2 (Restrictions) above.
7.2 We are not responsible for communications made by you or other users via the Communication Features.
7.3 We are not responsible for and do not endorse the opinions, advice and/or recommendations displayed, sent or made by you in the Game, including in-game lobby communications. Such communications are the sole responsibility of the user in question.
8 HEALTH AND SAFETY CONSIDERATIONS
READ THE INFORMATION IN THIS SECTION CAREFULLY BEFORE PLAYING.
8.1 The Game allows for immersive gameplay. Please pay attention to the following health and safety considerations and guidance as well as all instructions for use and warnings issued by the manufacturer(s) of your PC equipment.
8.2 Failing to follow applicable health and safety considerations, guidance and instructions could cause damage to property, personal injury to you or others, or death.
8.3 Certain people can experience various physiological effects when playing an immersive game, including:
8.3.1 loss of spatial awareness
8.3.2 nausea
8.3.3 dizziness
8.3.4 disorientation.
Other short-term effects following game use may include:
8.3.5 eye strain and trouble focusing
8.3.6 impaired hand-eye coordination
8.3.7 reduced depth perception
8.3.8 decreased reaction time
8.3.9 loss of balance.
Stop playing if you do not feel well or if you experience any of the above effects. Such effects can continue for some hours after use.
8.4 If you suffer from epilepsy, a heart condition, are pregnant or if you have any other pre-existing medical condition, you should obtain professional medical advice before playing the Game.
8.5 Photosensitivity Notice: This game features flashing lights, intense visual effects, and rapid patterns. A small percentage of individuals may experience seizures or disorientation when exposed to certain visual stimuli in video games, even without a prior history of epilepsy. If you experience dizziness, altered vision, or any discomfort, please discontinue playing immediately and consult a medical professional.
9 OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU
9.1 We are responsible to you for foreseeable loss and damage caused by us. If we fail to comply with these terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking this EULA or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time this EULA was made, both we and you knew it might happen.
9.2 We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors or for fraud or fraudulent misrepresentation.
9.3 We will not be liable for damage that you could have avoided by following our advice to apply an update offered to you free of charge or for damage that was caused by you overclocking your hardware, failing to follow the manufacturer’s instructions (including PC), failing to correctly follow installation instructions, failing to restrict settings (PC, in-game or otherwise) to those that are reasonable for the hardware being used to run the Game or failing to have in place the recommended minimum system requirements advised by us.
9.4 We are not liable for business losses. The Game is for domestic and private use only. If you use the Game for any commercial, business or resale purpose we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
9.5 You acknowledge that the Game has not been developed to meet your individual requirements, and that it is therefore your responsibility to ensure that the facilities and functions of the Game meet your requirements.
10 TERMINATION, SUSPENSION AND RESTRICTIONS ON USE
10.1 We may terminate this EULA immediately by written notice to you if you commit a material or persistent breach of this EULA which you fail to remedy (if remediable) within 14 days after the service of written notice requiring you to do so.
10.2 Upon termination for any reason:
10.2.1 all rights granted to you under this EULA shall cease;
10.2.2 you must cease all activities authorised by this EULA; and
10.2.3 you must immediately delete or remove the Game from all computer equipment in your possession and immediately destroy or return to us (at our option) all copies of the Game then in your possession, custody or control and, in the case of destruction, certify to us that you have done so.
10.3 We reserve the right to stop offering and/or supporting the Game or stop any service that supports or maintains the Game at any time, either permanently or temporarily. In such event, we shall not be required to provide any refund, benefit, compensation or alternative service to you in connection with the affected or discontinued elements of the Game and/or any supporting service.
10.4 We may immediately suspend, ban you from using, or otherwise restrict your licence to use the Game or certain features and functionalities of the Game (including multiplayer and online play functionalities) if you use the Game or any part of it in breach of the law, or any of the terms of: this EULA any applicable Third-Party Account, our Code of Conduct or our Guidelines. Please refer to the Code of Conduct section for more information on our policy on suspension and bans.
10.5 When you are using the Game, the Game may monitor your hardware RAM for unauthorised third party programs prohibited by clause 2 that interact with the Game. In the event that the Game detects such an unauthorised third party program, information may be communicated back to us, including the name of your User Account, your internet protocol (IP) address, details about the unauthorised third party program detected, and the time and date that the unauthorised third party program was detected, along with the hardware specifications and performance characteristics of your hardware, with or without additional notice to you. If the Game detects the use of an unauthorised third party program, this EULA and your access to the Game may be terminated with or without additional notice to you.
11 INTERNATIONAL USE
Although the Game may be accessible worldwide, we do not warrant that the Game may be lawfully used in your location, or that the content is not prohibited by applicable local laws. Users who choose to access the Game do so at their own risk and are responsible for compliance with any applicable local laws.
12 COMMUNICATIONS BETWEEN US
12.1 If you wish to contact us in writing, or if any condition in this EULA requires you to give us notice in writing, you can send this to us by email at info.gravitygridstudios@gmail.com
12.2 If we have to contact you or give you notice in writing, we will do so by email.
13 FEEDBACK
If you provide us with any feedback, suggestions or comments regarding the Game (Feedback), you hereby grant us a non-exclusive, royalty-free, irrevocable, perpetual licence to use such Feedback for any purpose in our discretion as we see fit and without any obligation to you. If any such rights may not be licensed under applicable law (such as moral and other personal rights), you hereby waive and agree not to assert all such rights.
14 DATA PROTECTION
14.1 Under data protection legislation, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data and how to exercise them. This information is provided in our Privacy Policy and it is important that you read our Privacy Policy.
14.2 By accessing or using the Game you accept and agree to be bound by this EULA and consent to the collection, use and storage of your information as outlined in our privacy policy.
15 OTHER IMPORTANT TERMS
15.1 Some features of the Game may require an internet connection, which you are responsible for providing at your expense. You are responsible for all costs and fees charged by your internet service provider related to the use of the Game.
15.2 We may at any time assign, transfer, subcontract or delegate any of our rights or obligations under this EULA. You may not assign, transfer, subcontract or delegate any of your rights and obligations under this EULA.
15.3 This EULA does not give rise to any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of this EULA.
15.4 Each of the clauses of this EULA operates separately. If any court of competent jurisdiction or competent authority decides that any provision of this EULA is invalid, illegal or unenforceable, that provision or part-provision shall, to the extent required, be deemed to be deleted, and the remaining provisions of this EULA will remain in full force and effect. If any invalid, unenforceable or illegal provision of this EULA would be valid, enforceable and legal if some part of it were deleted, the provision shall apply with the minimum modification necessary to make it legal, valid and enforceable to reflect our initial intentions.
15.5 If we do not insist immediately that you do anything you are required to do under the terms of this EULA, or if we delay in taking steps against you in respect of your breaking this EULA, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.
15.6 This EULA shall be governed by and construed in accordance with the laws of New Zealand. You consent to the exclusive jurisdiction of the courts of New Zealand.
PRIVACY POLICY
Gravity Grid Studios 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.
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
The following are some key terms used in this privacy notice and an explanation of what those key terms mean:
Who we are
We are Gravity Grid Studios Limited (“GGS”), a video games developer and publisher; for more information see our Steam Page Profile: https://store.steampowered.com/developer/GravityGridStudios.
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:
For UK players, the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
For players based in the European Economic Area (EEA), the EU General Data Protection Regulation (EU GDPR).
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.
What is personal data and why is it important?
Personal data is any information which identifies you (like your name, nickname, and email address). It is also information which can be pieced together with other information to identify you like your age, gender, or the technical IDs given to your phone/laptop/computer (these IDs are sometimes known as “online identifiers”); and the interactions of you and your character in the games from which it’s possible to work out things about you, such as play time, item acquisition rates, inventory amounts, character characteristics and choices (“gameplay data”). It’s important to know what we do with your personal data, because you should be able to control what happens to it. By reading and understanding this notice, you will know how we collect, use, share, and protect your personal data, and how you can ask us to use it differently.
How do we collect your personal data?
We may collect personal data:
When are we allowed to 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:
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.
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 list below sets out the personal data we may collect about you:
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.
What we use your personal data for
The list 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.
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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), 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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam 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 and where appropriate, impose a ban on a player.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), Godot Engine 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), Godot Engine account data, IP address, username/alias, game data, reporting 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), Godot Engine account data, IP address, username/alias, game data, reporting 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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Identity personal data, contact personal data, Steam account data (if applicable), Godot Engine account data, IP address, username/alias, game data, reporting 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.
Lawful basis (UK/EU GDPR): Necessary for the legitimate interests of the organisation you represent and our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for compliance with a legal obligation (Article 6(1)(c))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for compliance with a legal obligation (Article 6(1)(c)),
Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: 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:
Other players
For enabling interaction between players when playing our games
Personal data that may be shared: username
Third party service provider
Azure
Use by recipient: Cloud hosting for enabling you to use our online services and play our games with other players
Personal data that may be shared: Steam account data (if applicable), IP address, username/alias, game data, other personal data
Third party service provider
Neon
Use by recipient: For storage to the cloud of your in-game progress
To assist with game functionality
Personal data that may be shared: Device hardware ID, Steam account data, IP address, username/alias, game data, other personal data
Law enforcement/regulatory agencies
e.g. the Information Commissioner’s Office
Use by recipient: For their investigations
Personal data that may be shared: Potentially any personal data
Our insurers, brokers and professional advisers
Professional advisers e.g. solicitors, barristers, IT specialists
Use by recipient: For assisting, advising and representing us as necessary
Personal data that may be shared: Potentially any personal data
Other parties that have or may acquire control or ownership of our business or part of our business
Personal data that may be shared: 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:
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:
TRANSFERRING YOUR 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:
We will ensure the transfer complies with the UK GDPR and EU GDPR by ensuring that for example:
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:
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 (https://ico.org.uk/for-the-public)
If you would like to exercise any of the above rights, please email us (see below: ‘How to contact us’) and provide:
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 (https://ico.org.uk/).
CHANGES TO THIS PRIVACY POLICY
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: info.gravitygridstudios@gmail.com
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
May 29th 2026
Version 1
PLEASE READ THESE TERMS CAREFULLY
This end user licence agreement (EULA) is a legal agreement between you (you) and Gravity Grid Studios Limited, (us or we) regarding your use of our computer game software and includes any applicable updates, “patches” and modifications applied or activities carried out by us to support, maintain and otherwise run the game as a service (the Game).
We license use of the Game to you on the terms of this EULA. We do not sell the Game to you and this EULA confers no title or ownership to the Game or any copy thereof. We remain the owner of the Game at all times.
OPERATING SYSTEM REQUIREMENTS: This Game requires a device that meets or exceeds certain requirements in order to play. We recommend a PC with at least the following:
Intel Core i5-4590 / AMD Ryzen 5 2600 CPU;
NVIDIA RTX 2060 / AMD Radeon RX 5700 GPU;
8GB RAM;
Windows 10;
an Internet connection with a minimum download/upload speed of 10Mbps/6Mbps; and
a microphone, to use some features of the game such as voice recognition, voice play-back and multiplayer online voice chat, but there may be other requirements that need to be met in order to play the Game. We therefore do not warrant that you will be able to play the Game if these recommended minimum requirements are met.
AGREED TERMS
1 GRANT AND SCOPE OF LICENCE
1.1 In consideration of you agreeing to abide by the terms of this EULA, we hereby grant to you a limited, indefinite, non-exclusive and non-transferable licence to use the Game on the terms of this EULA.
1.2 You may:
1.2.1 install and use the Game for your personal purposes only; and
1.2.2 receive and use any free supplementary software code or update of the Game incorporating “patches” and corrections of errors as may be provided by us from time to time (but see clause 1.3).
1.3 We may update or require you to update the Game, provided that the Game shall substantially match the description of it that we provided to you before you bought it.
2 RESTRICTIONS
2.1 Except as expressly set out in this EULA or as permitted by any local law, you undertake:
2.1.1 not to copy the Game, except where such copying is incidental to normal use of the Game or where it is necessary for the purpose of back-up or operational security;
2.1.2 not to rent, lease, sub-licence, loan, translate, merge, adapt, vary, alter or modify, the whole or any part of the Game nor permit the Game or any part of it to be combined with, or become incorporated in, any other programs;
2.1.3 not to disassemble, de-compile, reverse engineer or create derivative works based on the whole or any part of the Game nor attempt to do any such things, except to the extent that (by virtue of sections 50B and 296A of the Copyright, Designs and Patents Act 1988) such actions cannot be prohibited because they are necessary to decompile the Game to obtain the information necessary to create an independent program that can be operated with the Game or with another program (Permitted Objective), and provided that the information obtained by you during such activities:
(a) is used only for the Permitted Objective;
(b) is not disclosed or communicated without our prior written consent to any third party to whom it is not necessary to disclose or communicate it in order to achieve the Permitted Objective; and
(c) is not used to create any software that is substantially similar in its expression to the Game;
2.1.4 to keep all copies of the Game secure and to maintain accurate and up-to-date records of the number and locations of all copies of the Game;
2.1.5 to include our copyright notice on all entire and partial copies of the Game in any form;
2.1.6 not to provide, or otherwise make available, the Game in any form, in whole or in part (including, but not limited to, program listings, object and source program listings, object code and source code) to any person without prior written consent from us;
2.1.7 to comply with all applicable technology control or export laws and regulations;
2.1.8 not to create, use, offer, advertise, make available and/or distribute any code, data, method or device:
(i) that influences and/or facilitates gameplay and thereby gives you and/or any other user an advantage over other players not using such means;
(ii) that accesses or modifies the Game in a manner not authorised by us; or
(iii) that can be used in connection with the Game, and/or any component or feature of it which changes and/or facilitates the way the game is played and/or imitates or copies data or functionality in the Game;
2.1.9 not to make improper use of our support services;
2.1.10 not to disrupt, or overload whether directly or indirectly servers used to support the Game or launch or participate in any type of attack, or otherwise attempt to disrupt the use and operation of the Game including but not exclusively by denial of service attacks;
2.1.11 not to sell, charge others for the right to use, or transfer any in-game content or Third-Party Account (as defined below) in connection with the Game;
2.1.12 not to access, intercept, or otherwise collect information without or consent by any means: (a) from or through support services we may provide for the Game, (b) that is in transit from or to the Game, or (c) that is contained in network traffic used by the Game to store information about content related to the Game.
2.2 You agree not to do any of the following whilst using the Game:
2.2.1 anything that contravenes our Code of Conduct or our gaming content guidelines.
2.2.2 attempt to, or harass, abuse, or harm, or advocate or incite harassment, abuse or harm of another person;
2.2.3 act in any way (including by transmitting or causing to be transmitted any communication) that would objectively be considered to be of an inappropriate nature including in a manner that is disruptive, unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, hateful, racially, sexually, or ethnically objectionable;
2.2.4 impersonate any person or entity, including but not limited to other users of the Game;
2.2.5 disrupt the normal functionality of the Game, or otherwise act in a manner that negatively affects other users of the Game;
2.2.6 except in accordance with and to the extent permitted by our Guidelines, post or transmit any advertising, promotional materials, or anything similar;
2.2.7 violate any applicable law while using or accessing the Game;
2.2.8 transmit unauthorised communications, including junk mail, chain letters, spam and any materials that promote malware, spyware and downloadable items;
2.2.9 make available any material or information that infringes any copyright, trademark, patent, trade secret, right of privacy, right of publicity, or other right of any person or entity or impersonates any other person; or
2.2.10 invade the privacy or violate or infringe any right of any person or entity, including by soliciting, collecting, harvesting or posting anyone's private information, including personally identifiable information (whether in text, image or video form), identification documents, or financial information through the Game.
3 INTELLECTUAL PROPERTY RIGHTS
3.1 You acknowledge that all intellectual property rights and all similar or equivalent rights or forms of protection, which subsist or will subsist now or in the future, in any part of the world (IPR) in the Game belong to us, that rights in the Game are licensed (not sold) to you, and that you have no IPR in, or to, the Game other than the right to use the Game in accordance with the terms of this EULA.
3.2 You acknowledge that you have no right to have access to the Game in source code form other than as expressly provided in this EULA.
4 UPDATES TO THE EULA AND OUR PRIVACY POLICY
4.1 We reserve the right, at our discretion, to change, modify, add or remove portions of this EULA and/or our privacy policy at any time by posting the updated EULA and/or our privacy policy on our website or by providing you with digital access to the amended EULA and/or our privacy policy through the Game or other means.
4.2 If you do not agree to any term of this EULA (or any updated version of such as adopted), you may terminate the EULA immediately without notice, and you must stop using the Game immediately.
4.3 The terms of any updated EULA shall automatically become effective after 30 days if they are posted on our website or Steam. By using the Game after the updated EULA becomes effective, or otherwise indicating your acceptance of the updated EULA, you agree to be bound by the terms of the updated EULA.
5 GAME UPDATES
5.1 From time to time we may provide updates and other modifications to the Game that must be installed for you to be able to continue to play the Game properly or at all. We may update or modify the Game for such purpose. You hereby grant us the right to deploy and apply such updates and modifications.
5.2 To help us provide you with the best gameplay experience possible, we may collect data relating to how you play the game, including what actions you take or selections you make, how long you play for and the performance of our online systems when you connect. This data is anonymised and is only kept for a reasonable period for analysis purposes. For further details, please see our privacy policy.
6 USER ACCOUNTS
6.1 In order to use the Game and for us to provide software features relating to the Game so that it operates correctly, you may be required to have and maintain a valid and active user account with an online service, such as a third-party gaming platform (Third-Party Account). If you do not maintain such an account, then certain features of the Game may not operate or may cease to function properly, either in whole or in part. You are responsible for all use and the security of your Third-Party Account that you use to access and use the Game.
6.2 This EULA is subject to the additional terms and conditions of or required by any applicable Third-Party Account and you shall comply with any applicable Third-Party Account terms and conditions. We are not responsible or liable to you for any credit card or other charges or fees related to your purchase transactions in respect of the Game made via a Third-Party Account. All such transactions are administered by the Third-Party Account.
7 USER COMMUNICATIONS
7.1 We may provide chat or other communication features as part of the Game and the support services for the Game (Communication Features). The Communication Features must always be used in compliance with our Code of Conduct. You also undertake that in using any Communication Features you will comply with your obligations set out in section 2 (Restrictions) above.
7.2 We are not responsible for communications made by you or other users via the Communication Features.
7.3 We are not responsible for and do not endorse the opinions, advice and/or recommendations displayed, sent or made by you in the Game, including in-game lobby communications. Such communications are the sole responsibility of the user in question.
8 HEALTH AND SAFETY CONSIDERATIONS
READ THE INFORMATION IN THIS SECTION CAREFULLY BEFORE PLAYING.
8.1 The Game allows for immersive gameplay. Please pay attention to the following health and safety considerations and guidance as well as all instructions for use and warnings issued by the manufacturer(s) of your PC equipment.
8.2 Failing to follow applicable health and safety considerations, guidance and instructions could cause damage to property, personal injury to you or others, or death.
8.3 Certain people can experience various physiological effects when playing an immersive game, including:
8.3.1 loss of spatial awareness
8.3.2 nausea
8.3.3 dizziness
8.3.4 disorientation.
Other short-term effects following game use may include:
8.3.5 eye strain and trouble focusing
8.3.6 impaired hand-eye coordination
8.3.7 reduced depth perception
8.3.8 decreased reaction time
8.3.9 loss of balance.
Stop playing if you do not feel well or if you experience any of the above effects. Such effects can continue for some hours after use.
8.4 If you suffer from epilepsy, a heart condition, are pregnant or if you have any other pre-existing medical condition, you should obtain professional medical advice before playing the Game.
8.5 Photosensitivity Notice: This game features flashing lights, intense visual effects, and rapid patterns. A small percentage of individuals may experience seizures or disorientation when exposed to certain visual stimuli in video games, even without a prior history of epilepsy. If you experience dizziness, altered vision, or any discomfort, please discontinue playing immediately and consult a medical professional.
9 OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU
9.1 We are responsible to you for foreseeable loss and damage caused by us. If we fail to comply with these terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking this EULA or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time this EULA was made, both we and you knew it might happen.
9.2 We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors or for fraud or fraudulent misrepresentation.
9.3 We will not be liable for damage that you could have avoided by following our advice to apply an update offered to you free of charge or for damage that was caused by you overclocking your hardware, failing to follow the manufacturer’s instructions (including PC), failing to correctly follow installation instructions, failing to restrict settings (PC, in-game or otherwise) to those that are reasonable for the hardware being used to run the Game or failing to have in place the recommended minimum system requirements advised by us.
9.4 We are not liable for business losses. The Game is for domestic and private use only. If you use the Game for any commercial, business or resale purpose we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
9.5 You acknowledge that the Game has not been developed to meet your individual requirements, and that it is therefore your responsibility to ensure that the facilities and functions of the Game meet your requirements.
10 TERMINATION, SUSPENSION AND RESTRICTIONS ON USE
10.1 We may terminate this EULA immediately by written notice to you if you commit a material or persistent breach of this EULA which you fail to remedy (if remediable) within 14 days after the service of written notice requiring you to do so.
10.2 Upon termination for any reason:
10.2.1 all rights granted to you under this EULA shall cease;
10.2.2 you must cease all activities authorised by this EULA; and
10.2.3 you must immediately delete or remove the Game from all computer equipment in your possession and immediately destroy or return to us (at our option) all copies of the Game then in your possession, custody or control and, in the case of destruction, certify to us that you have done so.
10.3 We reserve the right to stop offering and/or supporting the Game or stop any service that supports or maintains the Game at any time, either permanently or temporarily. In such event, we shall not be required to provide any refund, benefit, compensation or alternative service to you in connection with the affected or discontinued elements of the Game and/or any supporting service.
10.4 We may immediately suspend, ban you from using, or otherwise restrict your licence to use the Game or certain features and functionalities of the Game (including multiplayer and online play functionalities) if you use the Game or any part of it in breach of the law, or any of the terms of: this EULA any applicable Third-Party Account, our Code of Conduct or our Guidelines. Please refer to the Code of Conduct section for more information on our policy on suspension and bans.
10.5 When you are using the Game, the Game may monitor your hardware RAM for unauthorised third party programs prohibited by clause 2 that interact with the Game. In the event that the Game detects such an unauthorised third party program, information may be communicated back to us, including the name of your User Account, your internet protocol (IP) address, details about the unauthorised third party program detected, and the time and date that the unauthorised third party program was detected, along with the hardware specifications and performance characteristics of your hardware, with or without additional notice to you. If the Game detects the use of an unauthorised third party program, this EULA and your access to the Game may be terminated with or without additional notice to you.
11 INTERNATIONAL USE
Although the Game may be accessible worldwide, we do not warrant that the Game may be lawfully used in your location, or that the content is not prohibited by applicable local laws. Users who choose to access the Game do so at their own risk and are responsible for compliance with any applicable local laws.
12 COMMUNICATIONS BETWEEN US
12.1 If you wish to contact us in writing, or if any condition in this EULA requires you to give us notice in writing, you can send this to us by email at info.gravitygridstudios@gmail.com
12.2 If we have to contact you or give you notice in writing, we will do so by email.
13 FEEDBACK
If you provide us with any feedback, suggestions or comments regarding the Game (Feedback), you hereby grant us a non-exclusive, royalty-free, irrevocable, perpetual licence to use such Feedback for any purpose in our discretion as we see fit and without any obligation to you. If any such rights may not be licensed under applicable law (such as moral and other personal rights), you hereby waive and agree not to assert all such rights.
14 DATA PROTECTION
14.1 Under data protection legislation, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data and how to exercise them. This information is provided in our Privacy Policy and it is important that you read our Privacy Policy.
14.2 By accessing or using the Game you accept and agree to be bound by this EULA and consent to the collection, use and storage of your information as outlined in our privacy policy.
15 OTHER IMPORTANT TERMS
15.1 Some features of the Game may require an internet connection, which you are responsible for providing at your expense. You are responsible for all costs and fees charged by your internet service provider related to the use of the Game.
15.2 We may at any time assign, transfer, subcontract or delegate any of our rights or obligations under this EULA. You may not assign, transfer, subcontract or delegate any of your rights and obligations under this EULA.
15.3 This EULA does not give rise to any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of this EULA.
15.4 Each of the clauses of this EULA operates separately. If any court of competent jurisdiction or competent authority decides that any provision of this EULA is invalid, illegal or unenforceable, that provision or part-provision shall, to the extent required, be deemed to be deleted, and the remaining provisions of this EULA will remain in full force and effect. If any invalid, unenforceable or illegal provision of this EULA would be valid, enforceable and legal if some part of it were deleted, the provision shall apply with the minimum modification necessary to make it legal, valid and enforceable to reflect our initial intentions.
15.5 If we do not insist immediately that you do anything you are required to do under the terms of this EULA, or if we delay in taking steps against you in respect of your breaking this EULA, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.
15.6 This EULA shall be governed by and construed in accordance with the laws of New Zealand. You consent to the exclusive jurisdiction of the courts of New Zealand.
PRIVACY POLICY
Gravity Grid Studios 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.
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
The following are some key terms used in this privacy notice and an explanation of what those key terms mean:
- we, us, our - Gravity Grid Studios Limited (A company registered in New Zealand, NZBN: 9429053133120)
- distributors - means Valve Corporation (Steam) and Godot Engine
- games - means PNEUMA and any other game developed by us
- personal data - means any information relating to an identified or identifiable individual
Who we are
We are Gravity Grid Studios Limited (“GGS”), a video games developer and publisher; for more information see our Steam Page Profile: https://store.steampowered.com/developer/GravityGridStudios.
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:
For UK players, the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
For players based in the European Economic Area (EEA), the EU General Data Protection Regulation (EU GDPR).
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.
What is personal data and why is it important?
Personal data is any information which identifies you (like your name, nickname, and email address). It is also information which can be pieced together with other information to identify you like your age, gender, or the technical IDs given to your phone/laptop/computer (these IDs are sometimes known as “online identifiers”); and the interactions of you and your character in the games from which it’s possible to work out things about you, such as play time, item acquisition rates, inventory amounts, character characteristics and choices (“gameplay data”). It’s important to know what we do with your personal data, because you should be able to control what happens to it. By reading and understanding this notice, you will know how we collect, use, share, and protect your personal data, and how you can ask us to use it differently.
How do we collect your personal data?
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.
When are we allowed to 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.
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 list below sets out the personal data we may collect about you:
- 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
- Discord user details - Discord username, ID, Profile picture
- IP address
- username/alias
- Game data - Details of your in-game progress, in-game voice-chat. Short clips of your in-game voice chat.
- Reporting data - Account identity/username/alias of individual making report. Account identity/username/alias of individual being reported. Confirmation of whether an individual being reported has been previously banned. Reason for making a 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 Reddit)
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.
What we use your personal data for
The list 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.
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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), 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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam 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 and where appropriate, impose a ban on a player.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), Godot Engine 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), Godot Engine account data, IP address, username/alias, game data, reporting 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: Steam account data (if applicable), Godot Engine account data, IP address, username/alias, game data, reporting 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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: Identity personal data, contact personal data, Steam account data (if applicable), Godot Engine account data, IP address, username/alias, game data, reporting 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.
Lawful basis (UK/EU GDPR): Necessary for the legitimate interests of the organisation you represent and our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for compliance with a legal obligation (Article 6(1)(c))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for compliance with a legal obligation (Article 6(1)(c)),
Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for our legitimate interests (Article 6(1)(f))
What personal data we may use: 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.
Lawful basis (UK/EU GDPR): Necessary for your and our legitimate interests (Article 6(1)(f))
What personal data we may use: 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:
Other players
For enabling interaction between players when playing our games
Personal data that may be shared: username
Third party service provider
Azure
Use by recipient: Cloud hosting for enabling you to use our online services and play our games with other players
Personal data that may be shared: Steam account data (if applicable), IP address, username/alias, game data, other personal data
Third party service provider
Neon
Use by recipient: For storage to the cloud of your in-game progress
To assist with game functionality
Personal data that may be shared: Device hardware ID, Steam account data, IP address, username/alias, game data, other personal data
Law enforcement/regulatory agencies
e.g. the Information Commissioner’s Office
Use by recipient: For their investigations
Personal data that may be shared: Potentially any personal data
Our insurers, brokers and professional advisers
Professional advisers e.g. solicitors, barristers, IT specialists
Use by recipient: For assisting, advising and representing us as necessary
Personal data that may be shared: Potentially any personal data
Other parties that have or may acquire control or ownership of our business or part of our business
Personal data that may be shared: 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 account data, username/alias, and game data – where there is an error during your use of our online services: Gravity Grid Studios 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, or in some instances until a match is complete. Short clips of your in-game voice chat - this is deleted after a match and is never stored on our servers.
- 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 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:
- New Zealand in order for Gravity Grid Studios 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 Gravity Grid Studios to provide their services;
- Our other third party service providers including Azure and Neon; 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:
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 (https://ico.org.uk/for-the-public)
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 (https://ico.org.uk/).
CHANGES TO THIS PRIVACY POLICY
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: info.gravitygridstudios@gmail.com
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
May 29th 2026
Version 1