General
Larian Studios values your privacy and respects your right to keep control over your personal data. We aim to be transparent about what data we're collecting and why. Most importantly we do our best to protect your data like a dragon protects its treasure. On our quest to do so we have chosen not to sell your data to third parties.
The main reason why we collect data is to improve our games and your gaming experience.
Whether we are asking you to tell us who you are and what you like, or whether we are
offering you customer support when something goes wrong, our goal is for you to enjoy
our games as much as possible. However, we do our best to limit the amount of
information we collect to only what is necessary, because your right to privacy is as
important to us as our games.
This policy explains the personal data we collect from and about you, either directly or
indirectly, and how we use such information. The policy also covers what choices you can
make about the data we collect, and how you can control those choices. It applies to all
Larian Studios Products (games, merchandise, etc.). It additionally applies to any
Larian Studios Services, like our website, as well as offline interactions such as
Larian Studios events or Larian Studios booths at conventions.
The terms "we", "us", or "Larian Studios" are each
intended to refer to Larian Studios.
Accessing or using any of the Larian Studios owned websites implies your approval of the
way Larian Studios collects, uses, and processes your personal data. This does not mean
that you are giving your explicit consent to every processing activity. Instead, it
simply means that for every type of processing that does not require your explicit
consent you will implicitly be agreeing to Larian Studios’ reasoning for
processing. Hence, if you do not agree or accept the content of this policy, you should
not use any of the Larian Studios’ websites.
To make the information in this policy easier to digest, it's structured to
highlight the different ways in which a typical data subject would potentially share
information with Larian Studios. It is broken down into the following segments:
- Learning about Larian Studios
- Purchasing Larian Studios Products
- Using Larian Studios Products
- Getting help from Larian Studios
- Joining the Larian Studios Forum/Setting up a Larian Studios Account
- Doing business with Larian Studios
Additional sections give more detail about How We Use Personal Data, Sharing and
Disclosure, How to Access and Control Your Personal Data, Other Important Privacy
Information, and How to Contact Us regarding your personal data.
This policy for the protection of your personal data aims to be compliant with the
European Union Regulation of 2016 on the protection of natural persons with regard to
the processing of personal data and on the free movement of such data, and repealing
Directive 95/46/EC (“GDPR”).
We reserve the right to change, modify and update this policy from time to time by
posting a revised version on our websites. Therefore, we recommend you regularly consult
this policy, to make sure that you are aware of any changes.
Personal Data We Collect and Why
a. Learning about Larian Studios
As you gather more information about Larian Studios, you may visit a virtual or physical
site, which we manage. Examples include browsing one of our websites, attending an event
Larian Studios is organizing or is a part of or subscribing to our newsletter, the
Larian Gazette. During these interactions, in order to learn more about our Products,
you may voluntarily provide some personal data, such as your name and email address. You
might also provide information online via cookies or similar technologies when you visit
our websites.
We collect: name, email address, IP address, and information provided
by cookies or similar technology.
Why: We use this information to share news about events and products
being offered by Larian Studios. We collect the minimum needed personal data for the
smooth running of our websites.
Rationale: We collect the data only with your explicit agreement and
participation (also known as “explicit consent” in GDPR). Regardless of
whether you choose to share the personal data with us or not, you will still have access
to the Larian informational services. Note that necessary cookies might be applicable on
our websites. These are collected for functional reasons only for us to operate and to
allow you access to the website.
b. Purchasing Larian Studios Products
When you purchase Larian Studios Products directly from us (for instance at events, via
Kickstarter, and via our merch store), you may be asked to provide information so that
we can complete your purchase.
We collect: your name, phone number (optional), email address, shipping
address, and payment information.
Why: We use this information to complete your transaction, follow up
with you about your purchase, help with the delivery process, handle returns, and other
issues related to the purchase of your Larian Studios Products. Note that we do not
store any payment or credit card information. We only use payment information in
connection with your purchase of Larian Studios Products.
Rationale: We collect the information solely for the purpose of being
able to complete the transaction. Therefore, any information collected by us is
necessary for the performance of the contract that we have entered into when you
purchased a product from Larian Studios.
c. Setting up a Larian Studios Account
You could also sign up for the Larian Studios Account Launcher, which will require you
to set up a Larian Studios Account.
We collect: username (login), display name, email address,
password (encrypted), platform id (user id steam, gog, stadia), save game data, and at
player’s option friends lists. Additionally, if you use your Account to purchase
Larian Studios products from the Merch store, Larian Studios will collect additional
information, as specified in ‘b. Purchasing Larian Studios
Products’.
Rationale: We collect the information so we can operate the Account
service, allow cross platform play and cross platform saves, as well as potentially
fulfill your purchase orders. Hence the processing of personal data is necessary for the
performance of the contract.
d. Getting Help from Larian Studios
From time to time, you may decide to contact our Support team for assistance with your
Larian Studios Products. In order to offer you the best service possible, we may collect
certain data from you or your Products.
We collect: Contact information such as your name, email address, and
the content of your emails, chats, and other communications with Larian Studios Support.
In certain situations, it is useful for the Support team to have a
"Diagnostic" of your hardware. We collect this information with your
permission when helping you troubleshoot your Larian Studios
Product. Optionally, you can provide the Support team with a dxdiag file,
which contains information about your computer such as your computer specifications
(e.g., CPU, GPU, driver information, etc.). Normally these data are not personal data,
but because they are combined with the other data you share with us in the context of
your request, we will treat them in accordance with this privacy policy.
Note that these are the contact data we ask for. If you voluntarily share more
information with us, such as data from an email signature, we will inevitably process
that data. You are free to share more data with us, but this is not the
intention.
Why: We collect this information to give you the best and most
efficient customer support possible.
Rationale: Receiving personalized help from Larian is a service players
can decide whether to use or not. Players can continue to use and enjoy Larian
Studios’ games even without receiving personal support. Therefore, Larian Studios
obtains and processes the information on the basis of a performance of a contract
– the player requesting personal help, and Larian Studios fulfilling it.
e. Joining the Larian Forum
It could be that you want to join our online community to talk about the latest Larian
Studios games, report feedback or just hang out with fellow players.
We collect: Upon registration we collect your login name, display name, e-mail address
and an encrypted password. You could choose to also fill in your date of birth, hobbies
and interests, in-game class and/or alignment but this is completely optional. During
your visit of the Larian Forum, we also collect your IP address and information provided
by cookies or similar technology.
Why: We collect this information to manage our forum and to ensure that
all users adhere to our forum rules. This way, the forum stays a positive place where
players can discuss their adventures.
Rationale: The players can choose to sign up to the Larian Forum as an
additional way to be a part of the community, but it is not by any means mandatory for
the enjoyment of the games. Hence, the information collected for the Larian Forum is
obtained on the basis of performance of a contract. Players are provided with the
service of being able to chat in a community about the Larian Studios games.
f. Doing Business with Larian Studios
Larian Studios mainly does business with other companies. However, in the performance of
the agreements between the business partner and Larian Studios, we do collect some
contact details of the business partner’s staff.
We collect: name, e-mail address, telephone number and/or photo of the
business partner's contact person.
Why: We need this information to fulfil our obligations or exercise our
rights and to maintain our professional relationship with our business partner.
g. Applying at Larian Studios
You may decide that you want to work at Larian Studios and apply for a position in our
team. To evaluate your application, we need to process relevant personal data about your
skills and qualifications.
We collect: name, e-mail address, CV and the information contained
therein, phone (optional), current company of employment (optional), LinkedIn
(optional), additional links to portfolio websites (optional).
Why: We collect this information to evaluate candidates for a position
at the company. Hence, this processing is necessary for and based on the preparation of
a potential contract.
h. Gameplay Data (Anonymous)
When playing our game, you can opt to share gameplay data. Whether you choose to share
this data or not, will not affect your access to use the game.
The gameplay data we collect does not allow for the identification of data subjects and
thus, is not considered personal data within the meaning of the GDPR.
The main reason why we are interested in information from your use of Larian Studios
games is to improve the Larian Studios Products over time and to provide the best
experience for our players.
We collect: the information for the improvement of the game in general
consists of gameplay logs. It records things like story decisions, combat decisions,
deaths, in-game locations players have visited, party and character customization
decisions. (It does not include hardware or software information, IP address, email
address, usernames, or anything else that does not have anything to do with playing the
game.). This is generic data that can then be used by our production teams.
Why: We collect this information so that we can help ensure Larian
Studios Products are balanced, fun, clear, working the way we intended, and so we can
predict and prevent potential problems with Larian Studios.
Information We Obtain from Third-Party Sources
We protect personal data obtained from third parties according to the practices
described in this Policy and we also apply any additional restrictions imposed by the
source of data. These third-party sources vary over time but include partners with which
we offer co-branded services or engage in joint marketing activities.
3. Purposes for Processing Personal Data
Larian Studios always processes your data based on one of the lawful processing grounds
the GDPR allows. The list of those legal grounds is “consent” for the
websites, “legal obligations” and “contractual necessity” for
Services and Products, or “legitimate interest”.
Larian Studios uses the data collected for the following purposes (the reasons for which
are already disclosed in Chapter 1 and 2):
- Providing our Product Experience
- Customer Support
- Product Improvement
- Dispute Resolution/Legal Requirements
- Business Operations
- Communication, Marketing and Advertising
Sharing and Disclosure
Larian Studios does not sell personal data about its customers. We only
disclose your data as described in this statement. We may share information with the
following types of third parties described below and always ensure, when sharing
information, such third parties adhere to the same principles.
We disclose personal data to the following parties:
- Third party vendors. Larian Studios uses a variety of third-party vendors to perform services such as website management and hosting, online Product purchases and shipping, credit card processing and email communications. We share your personal data as necessary to complete any transaction or provide any Product or Service you have requested or authorized; with vendors or agents working on our behalf for the purposes described in this statement. An up-to-date list of these parties may be requested from Larian Studios at any time.
- Required by law or legal proceedings. Parties with whom it might be necessary when we reasonably believe it is required by law or in connection with legal proceedings; to prevent harm to Larian Studios or its customers; for the prevention and detection of crime or the apprehension or prosecution of offenders; to protect the rights or property of Larian Studios.
- Merger, acquisition, or sale of assets. Parties with whom it might be necessary to complete a financial or corporate transaction such as a merger or sale of assets.
- Affiliates and subsidiaries. Data may be shared within and between Larian Studios-controlled affiliates and subsidiaries all of which adhere to the principles and restrictions set forth in this Policy.
Please note that our Products sometimes run in applications of third parties whose
privacy practices differ from Larian Studios. If you provide personal data to any of
those third parties or their products, your information is governed by their privacy
statements.
Also, on our website we have included some third-party links that might be interesting
to you, but please consider we have no influence over these sites. When you decide to
follow the links, your visit to the website will not be covered by this privacy policy.
You should contact the relevant provider for information about their applicable data
privacy statement or policy.
Your Rights as a Data Subject
Larian wants to ensure that all our data subjects are well aware of their rights and be
able to exercise them to their benefit. Hence, we have summarized them for you.
- a. Right of Access: You have the right to obtain access to your personal information, as well as to be informed about the purpose of the processing by Larian Studios.
- b. Right to Rectification, Erasure, or Restriction: You have the choice to share your personal information with Larian Studios. You can request Larian Studios to rectify your personal information or have it erased. You can also request the processing of your personal data to be restricted. When you choose not to share data, or when you request that we erase your personal information, we may be prevented from providing you with several Services, Products, and access to a Larian Studios website.
- c. Right to Object: You have the right to object to the processing of your personal information when you have legitimate reasons to do so. You also have the right to object to the use of your personal information for purposes of direct marketing. In such a case specific reasoning will not be requested.
- d. Right to Data Portability: You have the right to obtain your personal information which is processed by Larian Studios in a structured, commonly used, and machine-readable format and/or to transfer this data to another data controller.
- e. Right to Withdraw Consent: When the processing is based on prior consent you have the right to withdraw this consent.
- f. Rights related to automated decision-making: If we were to use automated processes, including profiling, that significantly impact you, you have the right to know about it, request human intervention, and challenge the decision. At this point, we do not process personal data in this manner.
Note that you will in principle not have to pay to exercise any of these rights regarding your personal information. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in those circumstances.
How to Access and Control Your Personal Data
You can view, edit, or delete your personal data in either your Larian Studios account,
or by reaching out to us directly to privacy@larian.com.
If you want to exercise any of your rights to your personal data, we have made available
a request form which can be downloaded from
[https://larian.com/20200603_Larian_DSR_form.pdf] and sent to privacy@larian.com.
You are not obliged to complete this form to make an initial request but doing so will
make it easier for us to process your request promptly. If you do not use this form, we
might require you to do it anyway, e.g., to allow us to verify your identity. Whether we
need this or not will i.a. depend on the nature of your request.
Please be advised that, when receiving a request regarding personal data, we may be
required to first take appropriate action to verify your identity and ensure that you
are who you claim to be and that you have a legitimate interest in the personal data you
are inquiring about.
Note that you can also always choose to stop receiving promotional emails and other
types of marketing communication from us by unsubscribing from our mailing list at the
bottom of that email.
Cookies and Similar Technologies
We use cookies and similar technologies like pixels, and other identifiers to help us
personalize our website for you, remember your preferences, understand how users are
using our website, and help customize our marketing offerings. By visiting our website,
you agree to the use of cookies and similar technologies for the purposes we describe in
this statement.
a. Cookies
A "cookie" is a small data file containing a string of characters that is sent
to your computer when you visit a website. When you visit the website again, the cookie
allows that site to recognize your browser. The length of time a cookie will stay on
your computer or mobile device depends on whether it is a "persistent" or
"session" cookie. Larian Studios uses both types of cookies. Session cookies
will only stay on your device until you stop browsing. Persistent cookies stay on your
computer or mobile device until they expire or are deleted.
With the exception of cookies that are used solely to transmit communications or those
that are strictly necessary to the functioning of our websites, we will only place
cookies where you have previously provided your consent. You can do this when prompted
by our cookie banner. If you do not provide your consent, then you can still access and
use our websites.
We use the following types of cookies on our website:
- Strictly necessary cookies. These cookies are essential to enable you to browse around our website and use its features. Without these cookies, services like shopping baskets cannot be provided.
- Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate.
- Functional cookies. These cookies allow our website to remember your settings and help personalize your experience. For instance, we may store your geographic location in a cookie to ensure that we show you the Larian Studios website localized for your area.
- Analytics cookies. We use analytics cookies, such as those offered by Google Analytics, to help us understand things like how long a visitor stays on our website, what pages they find most useful, and how they arrived at larian.com.
When you visit our websites, a cookie banner appears on which you have the option to either agree to our use of cookies and similar technologies for the purposes we describe in this statement or to deny the use of non-necessary cookies. For the purposes of the technical running of the website the necessary cookies shall remain turned on, more information on which will be provided in the cookie banner.
b. Pixels
In addition to cookies, we sometimes utilize small graphic images known as
"pixels" (also known as web beacons, clear GIFs, or pixel tags). We may use
pixels in our email communications sent to you (if you have selected to receive such
communications) to help us to understand whether our email communication was viewed.
Additionally, we may use third-party pixels (such as those from Google, Facebook, and
other advertising networks) to help us provide advertising of Larian Studios Products or
Services that is relevant to your interests.
c. Advertising and Modern Marketing Tools
To help more people play Larian Studios games, we utilize several modern marketing tools
for our advertising efforts.
Larian Studios may work with third party advertisers that utilize cookies and similar
technologies to provide more relevant advertising about Larian Studios Products across
the internet. Examples of this may include a display of a Larian Studios advertisement
on a Facebook page, on a Google-owned page such as a search results page or YouTube, or
on a site within Google's advertising network. We do not share personal data we have
obtained as part of this process. You can opt-out of receiving personalized ads from
third party advertisers and ad networks who are members of the Network Advertising
Initiative (NAI) or who follow the Digital Advertising Alliance's
Self-Regulatory Principles for Online Behavioral Advertising by visiting the
opt-out pages on the NAI website and DAA website. Electing to opt out may make
the ads you see on the internet less relevant to you.
If you have opted out of receiving communications from us, we will not use your email
address in this for interest-based advertising, although you may still be subject to
certain interest-based advertising depending upon your browser and device
settings.
Security
We use a variety of security technologies and procedures to protect your personal data
from unauthorized access, use or disclosure.
While no security system is completely secure, Larian Studios takes reasonable industry
standard to protect personal data from loss, theft, misuse and unauthorized access,
disclosure, alteration, and destruction.
The servers on which your personal data is stored are kept in a controlled and secured
environment with controlled access. Activity on the server is locked so we can track and
trace any irregularities and act swiftly in case of any calamities.
Security begins with you so you may access your Larian Studios account information and
our service only through the use of an individual user login and password. To protect
the confidentiality of personal data, you must keep your password confidential and not
disclose it to any other person. Please advise us immediately if you believe your
password has been misused. In addition, always log out and close your browser when you
finish your session. Please note that we will never ask you to disclose your
password in an unsolicited phone call or email.
If you have any questions about the security of your personal data, you can contact us
at privacy@larian.com.
Other Important Topics
a. Our Policy Towards Children
Larian Studios does not knowingly solicit personal data from children or send them
requests for personal data.
Although visitors of all ages may navigate through our website, we do not intentionally
collect personal data from persons under the age of sixteen. If following a notification
by a parent or guardian, or discovery by other means, we become aware that a minor has
improperly registered on our site or service by using false information, we will cancel
the child's account and delete the child's personal data from our
records.
b. Where We Store and Process Personal Data (Third Country
Transfer)
Personal data collected by Larian Studios may be stored and processed in your region, in
the United States or in any other country where Larian Studios or its affiliates,
subsidiaries or service providers maintain facilities.
All information you provide may be transferred or accessed by entities around the world
as described in this statement. All information you provide may be transferred or
accessed by entities around the world as described in this statement. Whenever we share
your personal data outside the EEA, we will ensure the adequate protection of your
personal data and apply lawful measures of data transfer, such as EU standard
contractual clauses.
c. Our Retention of Personal Data
Larian Studios retains personal data for as long as necessary to provide the Services,
support your Product and fulfill the transactions you have requested, or for other
essential purposes such as complying with our legal obligations, and resolving disputes
and enforcing our agreements. Because these needs can vary for different data types in
the context of different Products or Services, actual retention periods can vary
significantly.
d. Changes to Our Privacy statement
Larian Studios may modify or update this statement when necessary to reflect customer
feedback and changes in our Products and Service; so, please review it periodically.
When we update this statement, we will revise the "Last Updated" date at the
top of the statement. If there are material changes to the statement or in how Larian
Studios uses your personal data, we will notify you either by posting a notice of such
changes before they take effect or by sending you a notification. We encourage you to
periodically review this statement to learn more about how Larian Studios is using and
protecting your information.
e. Data Protection Authority
While we have multiple entities in different locations, we consider our main Data
Protection Authority to be the Irish Data Protection Commission (DPC), and all of our
processing activities fall under its governance and scope.
Therefore, if you have any complaints about the way Larian Studios collect, use and/or
processes your personal data, you have the right to file a complaint with the Irish Data
Protection Authority or Supervisory authority, which is the Lead Supervisory Authority
of Larian Studios:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
https://forms.dataprotection.ie/contact
However, you are always free to contact your own EU-vested authority.
How to Contact Us
If you have any questions about the use of your personal data, please send us an email
to privacy@larian.com.
We further note that Larian Studios has appointed an external data protection officer
(“DPO”) to consult, advise and supervise on all matters related to GDPR. Our
DPO can be contacted via privacy@larian.com as
well.
Unless otherwise stated, Larian Studios is a data controller for personal data we
collect through the Products and Services subject to this statement. Our address
is:
Larian Studios
17 A New Bride Street
Dublin 8
Ireland