Legal documents

Gaijin Privacy Policy

Current version
Current Archived (from August 27, 2025) List of all versions

This Privacy Policy may be translated into other languages for your convenience. In the event of any discrepancy or conflict between the English version and any translation, the English version shall prevail.

This Privacy Policy reflects how Gaijin Entertainment (“Gaijin”, also “we,” “us”) processes your personal data and explains your rights related to that processing. 

The Privacy Policy applies to data processing when you: install and play videogames owned and distributed by Gaijin (“Game(s)”), use our other applications, websites, forums, your Gaijin Account, in-game and community features, participate in tournaments, events, and creator or partner programs we organize, and when you use any other products or services we provide that reference this Privacy Policy  (“Service(s)”).

This Privacy Policy does not apply to the processing of personal data in connection with job applications, recruitment, or business partnerships. Such processing is governed by separate privacy notices or agreements provided to you at the relevant stage of the application or cooperation process.

Please note that your use of Gaijin Services is also governed by the Terms and Conditions, including the Terms of Service.

1. WHO WE ARE

Your personal data is processed by Gaijin, which refers to the following legal entities, depending on the Service(s) you use or interact with according to our Terms of Service:

Gaijin Network Ltd, a Cypriot company with registration number HE 312702 and registered office at 63 Ifigeneias Street, Office 302, Strovolos 2003, Nicosia, Cyprus; and

Gaijin Distribution Kft., a Hungarian company with registration number 01-09-182370 and registered office at Hungária körút 162-166, Budapest, 1146, Hungary.

The primary point of contact for any inquiries is the Gaijin Support Portal. You may also contact us directly via email at privacy@gaijin.net, or by mail at the following address: Gaijin Network Ltd, 63 Ifigeneias Street, Office 302, 2003 Strovolos, Nicosia, Cyprus. Additional contact information can be found in Section 12 of this Privacy Policy.

2. WHAT DATA WE PROCESS

Gaijin processes personal data collected from various sources, including:

• Data that you provide to us directly.

• Data that we collect automatically when you use our Services.

• Data that we receive from third parties.

The categories described in Section 2 reflect the main types of data we process. 

2.1. Data You Provide Us

You directly provide us with personal information when you register and manage your Gaijin Account, access Gaijin websites, use our Services, make purchases, or contact Gaijin Support. 

The types of data we collect may include the following categories:

Account and Contact Information. During registration, you provide your email address, password, and username. You may also provide additional contact information, such as a mobile phone number or a secondary email address, for enhanced security and account recovery purposes. If you sign in via a third-party platform account, we process the associated account data. In some countries, we may also ask you to provide your age.

Parent or Guardian Information. If you indicated that you are a minor, we may request contact information for a parent, guardian, or other legal representative. 

Support Requests. When you contact Gaijin Support, we collect the information from your request, such as your email, name, username, User ID, and the contents of your message.

Security Data. In case of a security issue, we may ask security questions to verify account ownership. The information requested may include data that should reasonably be known to the account owner, such as your email address, username(s), Gaijin Account registration date, login, location, and purchase or gameplay details.

Settings and Preferences. When you adjust settings in our Games and Services, we collect your choices, such as language preferences, interface and localization settings, and other gameplay preferences.

In-game Communications. Our Games allow you to send text and audio messages that are visible to other players during a session. 

Community Services Communications. When you use our forums, bug-reporting system, other websites, official communities on social media accounts, and other third-party platforms (collectively, "Community Services"), the information you post is visible to us.

Purchase and Payer Data. When you make purchases through our Services, we collect the information provided by you: the payer's name, billing address, payment amount, and other tax-related information where required. Your purchase is linked to your Account Data.

Creator and Moderator Data. If you partner with Gaijin or if we are considering a partnership with you, as a creator or moderator on social media or game-related platforms, we may review the relevant social media data you share with us. Data processed includes account identifiers, statistics from your social media channels, or your activity on forums. 

Bug Reporting Data. When you submit a bug report, we collect the information you provide, such as the issue title and description, platform, bug category, and game client version. You may also attach supporting materials, such as screenshots, videos, gameplay replays, and other files (e.g., game configuration logs).

User-Generated Content (“UGC”). You may create and share content related to our Games and other Services on various gaming platforms, as well as on our websites (such as forums). 

EdenSpark Data. When you use EdenSpark as a developer, we process your EdenSpark profile (username, reputation, posts, comments), project names, submission data (builds, version identifiers), communication interactions, and prompts submitted to the AI-assisted creation tools.

Esports Data. When you participate in our events, apart from the content you submit for events, you may provide your full name, email, age, and related verification data, and delivery and payment information in case of a win.

Other Data You Voluntarily Provide. You may also contact us with inquiries, requests, or suggestions, which may include personal data. This can occur, for example, when you reach out via email, respond to surveys, or engage with us in other ways. 

2.2. Data We Collect Automatically 

When you use our Services, we may collect certain information automatically. Such data may include the following categories: 

Gameplay Data. We collect your in-game user ID, other game-related identifiers, data about your in-game actions, matches, interactions with other players, session start and duration, results, login history, history of purchases, and account restriction history. We may also collect recordings of your gameplay, but we will keep them for a limited time and then delete them.

Usage Information. This includes your user and device ID, approximate location data (such as IP address and related information like country and city), authentication security details, and other related information.

Device Data. This data may include, but is not limited to, the following: IP address, device type and model, device ID, MAC address, approximate location, language settings, time zone, localization settings,  operating system and version, installed applications, phone network operator, network type and connection, internet speed, screen resolution and orientation, device hardware specifications (such as CPU and memory, GPU, RAM, ROM size, battery), serial numbers and other relevant software and hardware information.

Transactions Data. We automatically collect information related to purchases made through our Services. This includes the type, quantity, and cost of items purchased.

Performance Data. We may collect crash reports (which may contain event timestamps, CPU model, OS version, build version, GUID, IP address, other technical identifiers), technical errors, and connection issues encountered during gameplay.

Anti-Cheat Data. Our anti-cheat systems automatically collect and analyze technical data from your device to detect cheats, hacks, and other unauthorized software. This may include your IP address, game-related identifiers (such as your in-game name and account ID), hardware and device identifiers (such as device IDs, serial numbers), information about your operating system, information about game-related and operating system files and memory, information about running processes, services, drivers, applications, and other executable code relevant to cheat detection, limited visual data related to the game environment (such as screenshots), and file names and file paths associated with the above, which may incidentally include personal information such as your operating system username. 

User-Engaging Programs and Events Data. If you participate in user-engaging programs or events related to our Game(s), we collect information about your Gaijin Account, participation, and performance. If you appear in our event broadcasts, we may record your name, in-game activity, and likeness as described in the release form provided to you. 

EdenSpark Technical Data. When you use EdenSpark, we automatically collect certain project submission data (timestamps and review results), and, if you use the AI-assisted tools, the generated outputs, your generation history, and request-related metadata (such as IP address, device and platform information, operating system details, tokens, language and locale settings, network-related information, and timestamps).

Analytics Data. We collect analytics data, including website and in-app events with timestamps (such as pages or screens viewed, features used, session start and duration), technical performance indicators (loading times, browser and device compatibility, errors), session identifiers and randomly generated identifiers, and aggregated usage statistics. Where feasible, this data is collected in pseudonymized or anonymized form.

Advertising Data. We analyze your interactions with advertisements on our Services or via our advertising partners. This data may include your Device Data, device ID, advertising IDs, Gaijin user ID, app version, your consent settings, your location and device settings, system language, install and attribution data (referring URL, event timestamps), and ad-related actions (such as impressions, clicks, website visits, account registrations, and bonus claims).

Cookies and Similar Technologies. We may use cookies and similar tracking technologies to recognize you and/or your device for the purposes outlined in this Privacy Policy. For more information about how we use cookies, please refer to our Cookie Policy.

2.3. Data We Receive from Third Parties

We may receive certain data from our partners, affiliates, and vendors that help us provide our Services. This data may include the categories listed below.

Third-Party Log-In. You can log into our Services using credentials from social media (e.g., Facebook), gaming platforms and consoles (e.g., Steam), device accounts (e.g., Apple Account), or similar services and websites. In these cases, the respective platform may share specific information with Gaijin, in accordance with their privacy policies. This may include your third-party account display name, user ID, email address, device identification, and location.

Data from Gaming Platforms. For our Games accessible through third-party platforms, such as PlayStation, XBOX, Nintendo Switch, or mobile app stores, we may receive your platform user IDs, email addresses, approximate location, language, store purchase history, game activity, friends list, rankings, achievements, and related preferences. Some platforms allow you to control which data is shared with us.

Advertising and Analytical Data. When our advertising and marketing partners analyze the performance of our applications and advertising campaigns, they may provide us with enhanced data resulting from their analysis, as well as anti-fraud signals relating to advertising traffic. In this context, they process website events and timestamps, click and campaign identifiers, referral source, device and browser data, country and region, language, platform (Steam, PlayStation, XBOX), session and randomly generated identifiers, hashed email (where applicable), characteristics or demographics, for registered users – the account data needed to confirm the qualifying action.

Payment Verification Data. Our payment providers collect your credit card details, e-wallet information, or other payment details (amount, currency) depending on the payment method.  Payment providers also process technical and behavioral data in connection with your transactions, including device identifiers, IP address, and approximate location, limited payment card metadata (such as the card's issuing bank identifier). We only receive payment verification data and do not have access to the full payment details.

Social Media Data. We do not collect information from public sources, such as social media or public registries, unless you voluntarily share your social media data (such as YouTube or Twitch) for participation in our events or programs (e.g., Content Creator Programs). In such cases, social networks may share your display name, user ID, and account statistics (e.g., subscriber counts, streaming times). 

Gaming Social Media Data. If you link a third-party gaming or social platform account (such as Twitch) to your Gaijin Account, for example, to participate in Twitch Drops, we may receive information associated with your account on that platform. This includes your platform user ID and login name, the linking status of your accounts, and campaign entitlement data (the reward you have qualified for and its requirements), accrual dates, and processing errors. 

3. PURPOSES FOR WHICH WE PROCESS YOUR DATA

We collect and process your data for the following purposes:

• Providing You with Our Services. To use our Services, you must agree to our Terms and Conditions. To fulfill this contract and provide the Services, we need to process your personal data. Namely, we process your personal data to: 

- Register and manage your Gaijin Account, including sign-in through third-party services and websites, and allow you to change your settings and data;

- Provide access to our Games, save your gameplay progress, settings, and preferences, and support other game functionality and features; 

- Provide access to our other Services, including Community Services;

- Provide you with technical support, including responding to your support requests.

Data involved: For these purposes, we may process all categories of personal data, whether provided by you, collected automatically, or received from our partners, except for Advertising Data, Advertising and Analytics Data.

Legal basis for processing: Contract performance 

• Payment Processing. We process data to complete your purchases, reflect transactions in your Gaijin Account, verify payments, and meet tax and accounting requirements.

Data involved: Purchase and Payer Data, Transactions Data, Payment Verification Data, Account and Contact Information.

Legal basis for processing: Contract performance; Сompliance with legal obligations, where we are required to store data for tax, accounting, and financial reporting purposes. 

• Improving Our Services and User Experience. We are committed to continually improving our Services and your experience when using them. To do this, we may process your data to:

- Diagnose, correct, and prevent technical issues or failures with our Services;

- Optimize our Services for different devices;

- Analyze gameplay and usage patterns to improve existing features and develop new ones;

- Store match history, replays, and game results;

- Collect and analyze feedback through surveys, forums, other Community Services, and direct communications;

- Otherwise improve user experience and community interaction across our Services and Community Services.

Data involved: Account and Contact Information, Gameplay Data, Usage Information, Performance Data, Device Data, Analytics Data, Data from Gaming Platforms, Other Data You Voluntarily Provide, Community Services Communications, Bug Reporting Data.

Legal basis for processing: Our legitimate interest to improve Services, tailor them to user interests, and develop new Services. For storing game replays, we have a legitimate interest to enhance player experience by enabling access to game replays for review and improvement.

• Ensuring Security. We process data to protect your account and our Services, including to:

- Ensure and enhance the security of your Gaijin Account and the data we process;

- Verify your identity when addressing a security issue or account recovery request;

- Detect and prevent unauthorized access to accounts.

Data involved: Security Data, Account and Contact Information, Support Requests, Other Data You Voluntarily Provide, Device Data, Usage Information.

Legal basis for processing: Legitimate interest to protect users, our Services, and our systems from security threats.

• Protection of Minors. We may collect age information from you or receive your account's age category or signals from gaming platforms to help protect minors using our Services. We may process this information to: 

- Determine which features of our Services are appropriate for you;

- Where necessary, request a parent's or guardian's email address.

Data involved: Account and Contact Information, Parent or Guardian Information, Settings and Preferences, Data from Gaming Platforms

Legal basis for processing: Legitimate interest to protect minors and provide age-appropriate Services, and, where applicable, compliance with legal obligations relating to the implementation of safeguards for children.

• Prevention of Cheating. Our Terms and Conditions strictly prohibit the use of cheats, hacks, and unauthorized game modifications. Therefore, we process your personal data to detect and prevent cheating, including with the use of anti-cheat technologies. 

Our anti-cheat systems run in the background of your device only when the Game is running and automatically analyze data to flag prohibited behavior such as cheating or hacking. These systems follow a data minimization approach: data is analyzed locally and is collected only where there are indications of unauthorized software or suspicious activity. For most players, no anti-cheat data is retained. As cheating methods evolve, the scope of analyzed data may be adapted where necessary to keep detection effective. 

Data involved: Gameplay Data, Anti-Cheat Data, Device Data, Usage Information.

Legal basis for processing: Legitimate interest to maintain fair play, quality services, protect intellectual property, and safeguard our reputation.

• Fraud Prevention. We process data to detect, prevent, and investigate fraud and other unlawful activity affecting our Services, including to identify fraudulent purchases, payment abuse, chargebacks, and misuse of promotions, bonuses, or referral programs.

Data involved: Account and Contact Information, Purchase and Payer Data, Transactions Data, Payment Verification Data, Device Data.

Legal basis for processing: Legitimate interest to protect our users and Services from fraud and financial harm, and, where applicable, compliance with legal obligations (e.g., payment and anti-fraud regulations).

• Personalization. We may personalize your experience by presenting content, features, or offers better suited to your interests and how you play. 

Data involved: Settings and Preferences, Device Data, Gameplay Data, Usage Information.

Legal basis for processing: Legitimate interest to tailor Services to user interests.

• Communicating with Users. We may communicate with you by email, through in-app and in-game notifications, and, for service messages such as security codes, by SMS. So, we process your personal data to:

- Send service communications, such as security alerts and technical notices;

- Send information about changes to our Services, updates to Terms and Conditions, or other legal documents;

- Interact with you on forums and other Community Services;

- Inform you about updates and improvements to our Services; 

- Notify you about events, competitions, and special offers within our Services;

- Respond to your inquiries, complaints, and requests; 

- Send emails with offers and promo codes, including for re-engagement if you have not played recently.

Data involved: Account and Contact Information, Community Services Communications, Gameplay Data, Other Data You Voluntarily Provide. 

Legal basis for processing: Contract performance for service communications, legal obligation for document notices, and our legitimate interest to respond to inquiries, community interaction, and inform you about events and programs.

• Bonus and Referral Campaigns. Gaijin offers bonus and referral campaigns organized via gaming social media and other partners. For example, you can link your Gaijin Account to your Twitch account to participate in Twitch Drops. We process your personal data to:

- Verify that you meet campaign conditions;

- Grant you in-game bonuses;

- Assess cooperation potential;

- Track referrals attributed to you and related purchases to calculate your rewards.

Data involved: Account and Contact Information, Creator and Moderator Data, Gameplay Data, User-Engaging Programs and Events Data, Social Media Data, Gaming Social Media Data.

Legal basis for processing: Contract performance, compliance with legal obligations (for reporting when required).

• Tournaments, Events, and Other Activities. If you participate in our events, tournaments, or user-engagement programs, we process data to:

- Verify winners’ identity and confirm their eligibility to participate in the relevant activities;

- Monitor your activity and ensure compliance with the cooperation terms;

- Provide informational and administrative support for the activities;

- Produce and publish broadcasts and recordings of competitive events.

- Select winners of events;

- Calculate, distribute, and deliver rewards, bonuses, or other compensations

- Publish news and announcements about our events, including tournament results and winner announcements featuring participants' in-game names on our Community Services.

Data involved: Account and Contact Information, Gameplay Data, Other Data You Voluntarily Provide, Esports Data, User-Engaging Programs and Events Data.

Legal basis for processing: Contract performance for participation in events, legitimate interest to promote our events for broadcasting and news publication, compliance with legal obligations for reporting in case of a prize.

• Marketing and Promotion. We promote our Games through advertising and partner campaigns, and we measure how these promotional activities perform. We might analyze your interaction with our promotional content to manage our ad campaigns and assess their effectiveness. For example, our advertising partners may place a registration link, via which we can track registration numbers and ad effectiveness. Accordingly, your personal data may be processed to:

- Display advertising for our Games and Services in our Games, websites, social networks, and third-party platforms;

- Promote our Games through affiliate networks and content creators;

- Show promotions within our Games from advertising partners;

- Attribute registrations, logins, and other events to the advertising campaign or referral link that brought you to us;

- Measure ad conversions and campaign performance.

When you consent to personalized advertising, we may share with our advertising partners your identifiers (like cookie IDs) and advertising cookies or similar technologies like tags, pixels, and beacons as described in our Cookie Policy. When we match identifiers, we may use this information along with your web browsing activity and interactions with ads to determine which ads to display, improve our advertising campaigns, and assess their effectiveness. You can disable cookies and withdraw your consent anytime at the page “Cookie Settings" on our websites. Please note that while you may still see ads, they may not be as relevant to your interests.

Data involved: Device Data, Advertising Data, Advertising and Analytics Data.

Legal basis for processing: Legitimate interest to promote our Services and tailor them to user interests, and, where required by applicable law, your consent.

• Website Analytics. We analyze the performance of our websites (loading speed, browser and device compatibility, technical errors) and how visitors move through them (pages visited, interactions, session flows), where feasible in pseudonymized or anonymized form, to improve the user experience.

Data involved: Usage Information, Device Data, Performance Data, Analytics Data, Advertising and Analytics Data.

Legal basis for processing: Legitimate Interest to optimize website functionality, consent to provide optional website features, including personalized content (See Cookie Settings for more details).

• Marketing in Mobile Applications. We promote our mobile Games and applications, and show advertising from our partners there. We also analyze how our mobile applications are used and how our campaigns perform. Accordingly, your personal data may be processed to:

- Advertise our mobile Games through advertising networks and content creators;

- Measure advertising conversions and campaign performance;

- Analyze events to improve our offers and campaigns;

- Create remarketing audiences based on in-app events (for example, users who played a Game but uninstalled a Game), and show relevant ads to those audiences;

- Show you advertising from our partners within our Games (non-personalized ads by default, or personalized ads only where you have given consent);

- Collect and manage your advertising consent settings;

- Send you marketing push notifications about our Games, offers, and events, where you have enabled them.

Data involved: Advertising Data, Device Data, Gameplay Data, Advertising and Analytics Data.

Legal basis for processing: Legitimate interest to improve, promote, and monetize our Services, consent for personalized activities, compliance with legal obligations for maintaining records of your consent choices.

• EdenSpark. EdenSpark lets you create, publish, and play games. When you use EdenSpark as a player or as a developer, we process your data to: 

- Operate the platform (registering and managing your access via your Gaijin Account, enabling developers to upload, submit, and publish games and assets, reviewing and testing submitted builds for quality, compatibility, and compliance with our Terms of Use, hosting published projects, displaying developer information publicly);

- Show developers aggregated statistics about their games' performance (number of likes, downloads, and launches);

- Keep the Service stable by collecting telemetry, usage, and crash data to monitor performance, diagnose errors, and improve the Service; 

- Provide AI-assisted creation tools.

Data involved: Account and Contact Information, Device Data, EdenSpark Data, EdenSpark Technical Data. 

Legal basis for processing: Contract performance, legitimate interest to improve our Services.

• T&C Enforcement. Our Terms and Conditions prohibit abusive, unlawful, and otherwise harmful content and behavior. To enforce this, we may process your data to:

- Review public in-game communications and other UGC, including by automated tools described below; 

- Review forum posts and communications in our Community Services when flagged for review following a report of a violation; 

- Apply and manage account sanctions, such as communication restrictions, account penalties, or suspension;

- Handle complaints and appeals, and correct erroneous decisions.

We use both manual tools (such as reports you and other players submit) and automated tools to support these efforts. Our automated tools used for moderation run entirely on our own servers, with no messages transferred to external providers. These tools analyze public in-game chat, together with a limited surrounding context, to identify language that may fall within defined violation categories. Violations are graded by severity, and repeated or systematic violations carry escalating consequences under our moderation rules. Where thresholds are met, a restriction on the use of social features may be applied automatically. 

If a restriction is applied, you will be notified of its reason, and may appeal the decision. Appeals are reviewed by a human moderator not involved in the original decision.

If you submit a report, we may inform you of its outcome. We do not disclose your identity or other personal data to the reported user.

Data involved: Account and Contact Information, In-game Communications, Community Services Communications, Creator and Moderator Data, UGC, Other Data You Voluntarily Provide, Gameplay Data.

Legal basis for processing: Our legitimate interest to protect our users and community, maintain a safe gaming environment, and safeguard our reputation; where applicable, compliance with legal obligations, including EU Digital Services Act.

• Regulatory Compliance.  We may process data to comply with laws applicable to Gaijin, including responding to lawful requests from courts, regulators, or other authorities. We carefully assess each request to confirm whether a specific legal obligation applies. 

Data involved: The types of data that may be required for this purpose include all categories of data we process. Common examples include purchase data, contact information, and device data.

Legal basis for processing: Compliance with legal obligations.

• Claims Management. If we become involved in a dispute, whether as a claimant, defendant, or third party, we may process the personal data required to support and defend our position. This applies to both negotiations and dispute resolution with authorized bodies.

Data involved: The data required for this purpose may include all categories of data we process, depending on the specifics of the claim. This may include, for example, account restriction history, active penalties, case details, and interactions with Gaijin Support.

Legal basis for processing: Legitimate interest to handle claims and defend our position.

• Corporate Transactions. We may process and transfer your personal data to third parties in connection with a sale, merger, reorganization, dissolution, or other transfer of some or all of our assets or business. 

Data involved: Potentially all categories described in Section 2.

Legal basis for processing: Contract performance, legitimate interest to complete corporate transactions, intra-group reorganizations, and ensure business continuity.

4. HOW WE SHARE DATA

We may share data in limited circumstances with our partners, service providers, and affiliates, including those outside the European Economic Area (EEA). 

In certain cases, our partners may be considered data controllers for specific aspects of personal data processing. For instance, when you access our Services through gaming consoles or platforms, your interactions with those platforms are controlled by their respective providers. You can learn more about their data processing practices by reviewing their respective privacy policies.

4.1. With Whom We Share Data

Affiliates. We may share personal data with companies within the Gaijin group of companies or affiliated entities.

Platforms, Distribution and Authorization Partners. Where you access our Services through third-party gaming platforms, app stores, or account authentication providers, login data is exchanged with the relevant platform operator. In some cases, gameplay data may be shared with the platforms, which enables user support and provides all features related to our Services for those playing our Games on these platforms. 

Payment Service Providers. We use authorized payment service providers to process payments for our Services.  Your payment information is collected and processed directly by the payment provider or platform you select. We do not receive or store your complete payment information.

Infrastructure and Hosting Providers. We use infrastructure and hosting providers to host our Games, websites, databases, content delivery services, and other technical systems necessary to provide our Services.

Anti-Cheat Providers. We engage third-party anti-cheat providers to detect, investigate, and prevent cheating and other violations of our Terms and Conditions involving unauthorized software, tools, modifications, or other methods. 

Communications Providers. We use communications providers to facilitate user communications, two-factor authentication (2FA), customer support, ticket handling, and delivery of transactional and marketing communications. 

Analytics and Product Improvement Providers. We use analytics and product improvement providers to understand how our Games and Services are used, measure performance, diagnose technical issues, improve stability and user experience, and evaluate the effectiveness of features.

Advertising and Marketing Partners. We use advertising, attribution, and marketing partners to promote our Games and services of our partners, measure the effectiveness of advertising campaigns, acquire new users, and attribute application installs and conversions.  We may share anonymized information such as your device, location, purchase data, and usage of our Services. These partners may combine this data with their own to enhance their advertising targeting.

Cookies. Information regarding our use of cookies and similar technologies and specific providers is available in our Cookie Policy. We also use consent management platforms to collect, record, and manage users' cookie and tracking preferences, including consents and withdrawals of consent. These providers help us demonstrate compliance with applicable data protection and ePrivacy requirements.

Partner Developers, Publishers, and Local Distributors. We share your data with publishers and developers who collaborate with Gaijin to publish their games, use Gaijin's game development and operations tools, or utilize Gaijin Accounts for login and access to Gaijin Services for game development through the Gaijin Application Platform. If you are accessing our Services through a local distributor, you can find more detailed information about this data-sharing process in this Annex.

Community Volunteers and Moderators. Some of your personal data may be visible to volunteer contributors and community moderators who support our Community Services. They can access only information that is already publicly available to other users, such as public posts, comments, and public profile details.

Event Sponsors. Where a sponsor provides prizes, we may share the winner's name, delivery address, and contact details with the sponsor or its delivery provider.

Broadcasting Platforms. We broadcast our esports events on third-party streaming platforms, such as YouTube and Twitch. If you participate in a broadcast event, your in-game identity, gameplay, and likeness may appear in the stream and in recordings available on those platforms. 

Business Service Providers. We may share personal data with third-party service providers, such as software developers or administrative service providers, who help us operate and manage our Services.

Consultants, Auditors, Professional Advisors. In cases where an audit or financial reporting requirement is mandated by applicable law, or in case of a legal dispute, we may engage auditors and external consultants, such as legal, financial, and accounting consultants. These third parties may need to process your personal data to provide their services to us. We carefully evaluate each situation and ensure that only the minimal necessary data is shared.

Governmental Bodies. We may share data with government authorities, if required by applicable law.

Our Contracting Parties in Contracting Transactions. In the event of a reorganization, merger, sale, or other acquisition, we may transfer all data we collect to the relevant third party.

The list of our partners and service providers, along with more detailed information about data processing under their respective Privacy Policies, is available here.

4.2. Transferring Your Data Abroad

As a global organization, we may transfer your data to third parties in various countries, including those outside the European Economic Area (EEA). We make every effort, including compliance with applicable laws, to ensure an adequate level of personal data protection for each such case. In particular, to safeguard data transfer, we rely on adequacy decisions adopted by the European Commission or enter into the Standard Contractual Clauses approved by the European Commission. Where necessary, we supplement these with additional technical and organizational measures. Where applicable, we may rely on other safeguards or derogations permitted under Chapter 5 of the General Data Protection Regulation (GDPR).We may also rely on EU-US Data Privacy Framework – when transferring to US recipients certified under this Framework (full list). 

5. HOW LONG WE PROCESS YOUR DATA

We process your data for as long as necessary for the processing purposes described in this Policy, and then we delete or anonymize it. Some data may be kept longer where the law requires it or where we need it to resolve disputes or safeguard our other interests.

In general, we retain data associated with your Gaijin Account for as long as your account remains active, so that we can provide the Services and maintain your progress and purchases. The precise periods for data storage vary depending on the category of personal data and purpose of processing. 

Factors we consider in determining these periods include the minimum retention period prescribed by law, the period during which a claim can be made with respect to a contract or other matter, whether the purpose of data collection was achieved, and whether data can be anonymized. For example, gameplay recordings are stored for 14 or 30 calendar days depending on the Game, and support tickets are retained for 5 years or until your account is deleted, whichever comes first. You may delete your account in the Personal Area of your profile or request deletion of your Gaijin Account by contacting Gaijin Support (See Section 9: Your Rights).

Please note that we may retain limited user data even after your deletion request, where:

• We are required by law to store data (for example, purchase records are retained under tax regulations);

• We need it to establish, exercise, or defend legal claims (for example, records are relevant to an ongoing dispute or to enforcing our Terms and Conditions);

• Data is needed for security, cheating and fraud prevention (for example, to prevent ban evasion and repeated abuse);

• We have other lawful bases to continue processing your data beyond your consent; 

• Your user data has been anonymized so that it can no longer identify you, thus no longer constituting personal data.

Data retained under these exceptions is restricted from any other use and is deleted once the relevant basis no longer applies.

6. CHILDREN’S PRIVACY

We recognize the importance of protecting children’s data. We strongly encourage parents, guardians, and other holders of parental responsibility to educate their children not to disclose their real names, addresses, phone numbers, financial details, or other sensitive data about themselves when online. We also recommend that parents familiarize themselves with parental controls available on consoles, app stores, and devices. 

Our Games and Services are directed to the general audience and are not specifically directed at minors. We do not knowingly collect personal information from children under 18 years of age (or the minimum age of digital consent in your country) without parental consent. 

Some app stores and distribution platforms are subject to age-verification laws in certain jurisdictions, including state-level laws in the United States. They may share your account's age category or signal with us. We use this information solely to enforce age-appropriate restrictions and safety features and to comply with legal requirements. We do not share it with third parties for advertising reasons.

If you are a parent or guardian and have questions about your child's data or wish to exercise their rights, you may contact us via the channels indicated in Section 12. To request deletion of a child’s account, please follow the procedure described in Section 9.2.

7. HOW WE SECURE DATA

We continuously work to develop, enhance, and implement administrative and technical measures to protect your data. These measures are designed to prevent unauthorized actions by third parties or accidental events, such as unauthorized access, disclosure, alteration, destruction, malicious use, or accidental loss or corruption of your data. We protect your data with encryption, access controls, and other state-of-the-art technical and organizational measures, as well as take all reasonable steps necessary to ensure that your data is securely handled and in compliance with this Privacy Policy.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the competent supervisory authorities and, where required, affected individuals without undue delay and in accordance with applicable law.

8. AUTOMATED DECISION-MAKING AND ONLINE TRACKING

We use automated systems to detect cheating, fraud and other behavior prohibited by our Terms and Conditions. Depending on the violation type, restrictions may be applied automatically upon detection or following review by our staff. Our team oversees these systems on an ongoing basis, including validating detections, cross-checking between detection tools, and reviewing for false positives. If you believe a measure was applied to your account in error, you can contest it and request a human review by contacting Gaijin Support. 

9. YOUR RIGHTS

9.1. Your Rights Related to Your Personal Data

Depending on the applicable data protection laws, you have the following rights regarding data processing:

• Right to Be Informed. You have the right to be informed how we collect and use your personal data.’

• Right to Access. You have the right to request information about the data we hold about you and to receive a copy of it. Please note that your access request should not adversely affect the rights and freedoms of others, and we can limit the scope of the personal data provided. For example, we may not disclose the specific data points, signals, or detection methods behind an anti-cheat or fraud enforcement action, as disclosing this would enable circumvention of our systems. 

• Right to Rectification. You have the right to request corrections to your personal data if it is inaccurate, incomplete, outdated, incorrect, unlawfully obtained, or no longer needed for processing.

• Right to Erasure (“Right to be Forgotten”). You can request that Gaijin erase your data unless we are required by law to continue processing some of your personal information, or unless there are other overriding legitimate grounds for processing. Please note that an erasure request may be limited to the extent necessary to enforce an active account restriction or penalty and to prevent circumvention of such measures (See Section 5).

• Right to Data Portability. You have the right to request to be provided with your data in a structured, commonly used, machine-readable format or to ask Gaijin to transfer your data directly to a third party, where technically feasible and reasonable.

• Right to Restrict Processing. You have the right to limit the use of your data in certain circumstances, either fully or partially, unless we are required by law to continue processing it.

• Right to Withdraw Consent. If your data is processed based on your freely given consent, you have the right to withdraw that consent at any time.

• Right to Object (“Right to Opt Out”). You have the right to object to the processing of your personal data when the processing of your data is based on our legitimate interest. For example, when your data is processed for direct marketing purposes.

• Right not to be Subject to Decision Based on Solely Automated Processing. Where a decision that produces legal or similarly significant effects is based solely on automated processing, you have the right to request human intervention in that decision. This does not entitle you to object to the use of automated processing as such, but any significant decision made by automated means will, on your request, be reviewed by our staff. 

• Right to File a Complaint. If you are located in the United Kingdom, you have the right to file a complaint directly with us if you believe that your personal data has been mishandled or if the processing of your data does not comply with applicable data protection laws.

9.2. How to Exercise Your Rights

Managing Privacy and Marketing Preferences

• For Direct Marketing: Gaijin may send news, offers, and updates to the email associated with your account. If you prefer not to receive marketing communications, you can opt out by adjusting your settings in your Gaijin Account. Simply log in to your account, go to Settings > Mailing Settings or Manage Subscriptions, and you can either disable all informational emails or deselect specific categories you are not interested in.

• For Mobile Advertising: If you previously gave consent to receive ads before starting to play, you can withdraw this consent for targeted advertising by unchecking the boxes in the Personal Area > Privacy section of your mobile app.

• For Cookies and Similar Technologies: We use cookies, pixels, beacons, tags, scripts, and similar technologies when you visit Gaijin websites. These are not linked to your account on our Services. You can adjust your cookie preferences on any of our websites by clicking the “Cookie Settings” link in the footer of our websites. Please note that disabling cookies in your settings will not automatically delete them from your device, as this is not technically possible. To remove cookies, you must clear them from your browser. For more details, please refer to our Cookie Policy.

• For Other Types of Marketing Activities. If your data is processed for other types of marketing activities, we will provide you with information on how to manage your privacy choices when the processing begins. In any case, you may direct your request to Gaijin Support portal.

Data Erasure

If you choose to erase the data we hold about you, we will delete your information where possible, considering our legal obligations to retain certain data and, in some cases, our right to continue processing it for other lawful reasons (such as investigating prohibited activities).

Please note that erasing your data will result in the complete, irrevocable, and permanent deletion of your Gaijin Account, meaning you will not be able to recover your game progress, in-game assets, or currencies.

To submit a data erasure, please follow the account deletion procedure in the Personal Area of your profile. You can find the guide here.

We will first suspend your account while we gather all the personal data we have on you. During this time, you will not have access to our Services. Typically, we delete personal data within 30 calendar days. However, if we need more time due to technical issues or the complexity of the request, we will complete the erasure within 2 months.

If you decide to restore your account after submitting your data erasure request, you can contact us through Gaijin Support within 30 calendar days of account suspension. We will restore your Gaijin Account and inform you if the deletion process is still ongoing. Otherwise, your account and personal data will be permanently deleted after the suspension period ends.

Exercising Other Rights

If you wish to exercise any other rights related to Gaijin's processing of your personal data, please submit your request to Gaijin Support after signing in to your Gaijin Account. We ask that you sign in to your Gaijin Account to verify your identity and help prevent third parties from accessing your personal data or interfering with the processing of your data and the exercise of your rights.

If you have lost access to your Gaijin Account, you can still exercise your rights. In this case, when we receive your request without identifying information, we may ask for security details to verify your identity and restore access to your Gaijin Account. Typically, these details will relate to questions referring to your account and game data, which only you should know.

When a request is submitted by a designated agent, additionally, we will take steps to verify that your agent is authorized to make a request on your behalf.

10. FOR UNITED STATES RESIDENTS

This section applies only to users residing in states where consumer privacy laws are in effect ("State Privacy Laws").

Your Rights

In accordance with State Privacy Laws, and subject to certain exceptions, you may have the following rights:

• Right to Access (Right to Know). You have the right to know what personal information Gaijin has collected about you and how it is being used and shared. You may also request access to the personal information we have collected about you. The details we provide you and the procedure for responding will depend on the applicable laws. Please note that certain information may be exempt from such requests under applicable law. 

• Right to Data Portability. You have the right to request that we provide your personal information in a readable format, making it easy for you to transfer your data to another entity.

• Right to Correct. If you believe the information we hold about you is inaccurate or outdated, you can request that we correct it.

• Right to Delete. You have the right to request the deletion of your personal information held by Gaijin or shared with third parties. Please note that deleting your personal information will result in the permanent deletion of your Gaijin Account. Once deleted, your account, along with any game progress and purchases, cannot be restored. Some personal information may be exempt from such requests under applicable law.

• Right to Opt-Out of Certain Processing. You may restrict Gaijin's ability to process your personal information unless we have legitimate grounds to continue processing it.

• Right to Opt-Out of Sales or Targeted Advertising. We do not engage in the traditional "selling" of your personal information, meaning we do not trade your phone numbers, email addresses, or other personal details for any compensation. However, like many companies, we may share some of your personal information with third parties to help personalize and enhance advertising on external websites or apps. In certain states, these actions might be considered a “sale” or “sharing” of personal information for targeted advertising, and as such, you have the right to opt out. You may exercise the right to opt out of sale of personal data by changing your cookie settings and privacy choices, or by submitting a request at the Gaijin Support Portal. For more details, please refer to Section 9.2 of this Privacy Policy. 

• Right to be Free from Discrimination. State privacy laws typically prevent discrimination based on your decision to exercise your privacy rights. This includes practices like offering different quality goods or services, charging different prices, or imposing penalties. We will not discriminate against you in any way if you choose to exercise your privacy rights.

• Right to Appeal. If we deny your request to exercise any of the rights mentioned above, depending on your state of residence, you may have the right to appeal our decision.

• Private Right of Action. Under the laws of some states, you may have the right to seek civil damages for violations of privacy laws, subject to certain limitations.

• Limit Use of Your Sensitive Personal Information. Some of the personal information we collect may be considered "sensitive" under the laws of US states (for example, payment information). \We do not use or disclose sensitive personal information in terms of US state privacy laws for purposes other than those permitted by applicable law. 

To learn more about how to exercise your rights regarding your personal data, please refer to Clause 9.2 above.

11. UPDATES

We may update this Privacy Policy from time to time by posting a modified version here.

In case of material changes, we will provide a relevant notice in accordance with legal requirements. We reserve the right to suspend services that require the processing of your data if you refuse to acknowledge the new version of the Privacy Policy. 

For minor changes, no notice will be provided.  We encourage you to review this Policy periodically so that you are aware of any changes.

Any updates to this Privacy Policy will take effect the day after the revised version is published.

12. CONTACT US

If you have any questions about how Gaijin processes personal data or if you disagree with how we handle data processing and protection, please feel free to reach out to us.

The primary point of contact is the Gaijin Support Portal. You may also contact us via email at: privacy@gaijin.net or by postal mail at the following address: 63 Ifigeneias Street, Office 302, 2003 Strovolos, Nicosia, Cyprus (Gaijin Network Ltd).

For further questions or complaints, please contact our Data Protection Officer via email at dpo@gaijin.net or send a letter to Gaijin Network Ltd at 63 Ifigeneias Street, Office 302, 2003 Strovolos, Nicosia, Cyprus (attention: Data Protection Officer).

You also have the right to submit a complaint to our lead supervisory data protection authority in Cyprus or in the country where you are located.

Last updated: August 17, 2026