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SYSTEMS HEAVY INC.

PRIVACY POLICY

Last Updated: Aug 8th, 2026

Systems Heavy Inc. (“Systems Heavy,” “we,” “us,” or “our”) respects your privacy.

This Privacy Policy explains how we collect, use, disclose, retain and otherwise process Personal Data when you:

  • visit or interact with our website at www.systemsheavy.com (the “Website”);

  • play, access or interact with VCO: Victor Charlie One, including any demo, playtest, test version, Early Access version, full-release version, update, downloadable content or associated software that links to this Privacy Policy (the “Game”);

  • use online, server, leaderboard, cloud, community or other functionality that we may make available in connection with the Game (the “Game Services”); or

  • contact or otherwise interact with Systems Heavy in connection with the Website, Game or Game Services.

The Website, Game and Game Services are collectively referred to in this Privacy Policy as the “Services.”

This Privacy Policy is a notice describing our privacy practices. It is not intended to obtain consent where applicable law requires consent to be obtained separately.

Where consent is required for particular processing, we will request that consent separately where required by applicable law.

 

1. WHO WE ARE

Systems Heavy Inc. is a corporation organised under the laws of Delaware, United States.

For Personal Data for which Systems Heavy determines the purposes and means of processing, Systems Heavy is the relevant data controller, business or equivalent responsible entity under applicable data-protection law.

Our contact details are:

Systems Heavy Inc.
8 The Green, STE B
Dover, Delaware 19901
United States of America

Privacy Email: Socials@SystemsHeavy.com

We have not appointed a Data Protection Officer unless otherwise stated.

Where applicable law requires Systems Heavy to appoint a representative in a particular jurisdiction, the representative's details will be made available in this Privacy Policy or through an accompanying privacy notice.

 

2. WHAT IS PERSONAL DATA?

For purposes of this Privacy Policy, “Personal Data” means information that identifies you or relates to an identified or identifiable individual.

Depending on applicable law, similar terms such as “personal information” may have substantially equivalent meanings.

Information that has been aggregated or deidentified so that it cannot reasonably be associated with an identified or identifiable individual is not treated as Personal Data to the extent permitted by applicable law.

 

3. PERSONAL DATA WE COLLECT

The Personal Data we collect depends on how you interact with the Services, which features you use, the configuration of those features, and the technologies and service providers used to operate them.

We seek to collect Personal Data that is reasonably necessary and proportionate to the relevant purpose.

3.1 Information You Provide Directly

You may provide Personal Data directly to us when you contact Systems Heavy, submit a request, communicate with us or otherwise interact with us.

This information may include:

  • your name;

  • email address;

  • contact information;

  • correspondence and the contents of messages you send to us;

  • support requests;

  • bug reports;

  • feedback;

  • survey responses;

  • information voluntarily submitted in connection with testing or playtests; and

  • other information you choose to provide.

Please do not send us sensitive Personal Data unless it is necessary for your request and you have a lawful reason to provide it.

 

4. GAME AND GAMEPLAY DATA

When you use the Game, we may automatically receive, generate or collect information concerning the Game and your interaction with it.

Depending on the version of the Game and enabled functionality, this may include:

4.1 Gameplay and Telemetry Data

We may process information such as:

  • game sessions and session duration;

  • game version and build number;

  • gameplay events;

  • progression;

  • mission, level or encounter information;

  • choices and interactions within the Game;

  • gameplay outcomes;

  • game difficulty or balancing information;

  • achievements or achievement-related information;

  • statistics;

  • performance information;

  • settings and configuration;

  • feature usage;

  • errors encountered during gameplay; and

  • similar information concerning how the Game is used.

We may use this information to understand how the Game performs, identify problems, improve gameplay, balance systems, develop features and maintain the Game.

Not every version of the Game necessarily collects every category described above.

 

5. DEVICE AND TECHNICAL INFORMATION

When you use the Game or Game Services, we may process technical information relating to the device and software environment used to run them.

Depending on the relevant functionality, this may include:

  • operating system and version;

  • hardware configuration;

  • processor or CPU information;

  • graphics processor or GPU information;

  • system memory information;

  • display or graphics settings;

  • device type;

  • driver information;

  • application and Game version;

  • language and regional settings;

  • IP address;

  • network information;

  • timestamps;

  • device or software identifiers;

  • technical configuration information; and

  • other diagnostic or compatibility information.

We use this information primarily for compatibility, debugging, security, performance analysis, technical support and improvement of the Game.

 

6. CRASH REPORTS AND DIAGNOSTIC

INFORMATION

When the Game experiences an error, crash, performance problem or other technical issue, we or our service providers may receive diagnostic information.

This may include:

  • crash logs;

  • stack traces;

  • error codes;

  • Game state associated with an error;

  • Game build information;

  • operating-system information;

  • hardware information;

  • memory or performance information;

  • diagnostic logs;

  • timestamps;

  • identifiers associated with the relevant installation, session or platform account; and

  • technical information reasonably necessary to diagnose the problem.

Diagnostic information may sometimes contain information that constitutes Personal Data, particularly where it contains identifiers or can otherwise be linked to an identifiable player.

We use this information to diagnose errors, investigate defects, improve stability and performance, maintain compatibility, secure the Game and provide technical support.

 

7. STEAM AND PLATFORM INFORMATION

The Game is distributed through Steam, which is operated by Valve Corporation and/or its affiliates.

Steam and Valve independently collect and process information relating to your Steam account and your use of Steam under Valve's own terms and privacy policies.

Systems Heavy does not control Valve's independent processing of your Personal Data.

Depending on the Steam functionality used by the Game, Systems Heavy may receive or process information made available through Steam or Steamworks, including:

  • Steam identifiers, such as a Steam ID or other platform identifier;

  • ownership, licence or entitlement information;

  • achievement information;

  • leaderboard information;

  • platform language or region information;

  • limited profile or account-related information made available through Steam;

  • matchmaking, networking or server-related information if relevant functionality is enabled;

  • Steam Cloud or save-related information where relevant;

  • user-generated-content or Steam Workshop information if such functionality is enabled in the future; and

  • other information that Steam makes available to the Game through authorised Steam functionality.

We may associate Steam-provided information with Game telemetry, diagnostic information or Game Services where reasonably necessary to provide the relevant functionality.

Purchases made through Steam are processed through Steam. Systems Heavy does not receive your full payment-card details from Steam.

Your relationship with Valve and your use of Steam remain subject to Valve's applicable terms and privacy policies.

 

8. SAVE DATA, PROGRESSION AND CLOUD FUNCTIONALITY

The Game may store information locally on your device and may support Steam Cloud or other cloud-storage functionality.

Depending on the functionality enabled, save or progression information may include:

  • Game progress;

  • unlocked content;

  • campaign state;

  • settings;

  • preferences;

  • statistics;

  • achievement-related state; and

  • other information required to maintain your Game state.

Where Steam Cloud is used, Valve may process the relevant information through Steam.

Systems Heavy may process save or progression information where necessary to provide, maintain, debug or support Game functionality.

 

9. ONLINE, SERVER AND NETWORKED FUNCTIONALITY

The Game is primarily intended as a single-player game at present, but Systems Heavy may introduce additional Game Services or networked functionality.

If online, multiplayer, cooperative, leaderboard, dedicated-server, community or similar functionality is introduced, we may process information reasonably necessary to operate and secure those features, including:

  • Steam or player identifiers;

  • session information;

  • server information;

  • connection information;

  • IP addresses;

  • gameplay statistics;

  • leaderboard data;

  • authentication information;

  • security events;

  • reports of abuse or misconduct; and

  • information necessary to detect fraud, cheating, malicious activity or unauthorised access.

If new functionality materially changes our processing of Personal Data, we will update this Privacy Policy or provide an additional notice where required.

 

10. WEBSITE USAGE DATA

When you visit the Website, we and our service providers may automatically collect technical and usage information.

This may include:

  • IP address;

  • browser type and version;

  • operating system;

  • device type;

  • pages viewed;

  • referring and destination pages;

  • time and date of access;

  • time spent on pages;

  • interactions with Website features;

  • approximate location derived from IP address;

  • cookie or similar identifiers; and

  • diagnostic information.

We use this information to operate, secure, maintain, understand and improve the Website.

 

11. COOKIES AND SIMILAR TECHNOLOGIES

The Website may use cookies, pixels, local storage, tags, scripts and similar technologies.

These technologies may be used for purposes such as:

  • providing functionality necessary for the Website to operate;

  • maintaining security;

  • remembering privacy or cookie preferences;

  • understanding Website performance;

  • measuring Website usage;

  • diagnosing technical problems; and

  • analytics.

Where applicable law requires consent before non-essential cookies or similar technologies are used, we will seek that consent through an appropriate consent mechanism.

You may also be able to control cookies using your browser settings.

Rejecting certain non-essential technologies should not prevent use of functionality for which those technologies are not necessary, although disabling technically necessary storage may affect some Website functionality.

Cookie choices and available controls may be described in a cookie banner, cookie-management interface or separate cookie notice where applicable.

 

12. INFORMATION WE RECEIVE FROM OTHER SOURCES

We may receive Personal Data from sources other than directly from you, including:

  • Valve and Steam;

  • service providers operating on our behalf;

  • crash-reporting or diagnostic providers;

  • hosting and infrastructure providers;

  • analytics providers;

  • security providers;

  • communication platforms;

  • business partners where legally permitted;

  • publicly available sources; and

  • another person acting on your behalf.

We use information obtained from third parties only for purposes that are compatible with the circumstances in which it was obtained and as permitted by applicable law.

 

13. HOW WE USE PERSONAL DATA

We may use Personal Data to:

Provide and Operate the Services

We may process information to:

  • provide access to the Game and Game Services;

  • deliver requested functionality;

  • authenticate or validate entitlements where necessary;

  • operate Game systems;

  • provide Steam-integrated features;

  • maintain saves, progression, achievements or leaderboards where applicable;

  • operate online or server functionality; and

  • respond to requests for support.

Maintain, Debug and Improve the Game

We may process telemetry, diagnostics and other information to:

  • identify crashes and bugs;

  • reproduce and resolve technical problems;

  • understand compatibility issues;

  • improve stability and performance;

  • optimise the Game;

  • understand feature usage;

  • improve user experience;

  • assess gameplay balance;

  • identify problematic or confusing systems; and

  • guide future development.

Security and Abuse Prevention

We may process information to:

  • protect the Game and Game Services;

  • prevent unauthorised access;

  • investigate security incidents;

  • protect our infrastructure;

  • detect malicious activity;

  • detect or investigate cheating where relevant;

  • protect our intellectual property;

  • investigate breaches of applicable terms; and

  • prevent fraud or misuse.

Communications and Support

We may process Personal Data to:

  • respond to questions;

  • provide technical support;

  • investigate reports;

  • administer playtests or surveys;

  • send information you request; and

  • communicate about security, technical or material service-related matters.

Analytics and Development

We may analyse information to:

  • understand how the Game and Website are used;

  • assess performance;

  • understand aggregate player behaviour;

  • improve current products;

  • plan future features or products;

  • conduct research and statistical analysis; and

  • create aggregated or deidentified information.

Marketing

Where permitted by applicable law, we may use contact information to communicate with you about Systems Heavy, our games, releases, events or similar matters.

Where consent is required, we will obtain consent before sending the relevant marketing communication.

You may unsubscribe from marketing communications using the unsubscribe mechanism provided in the communication or by contacting us.

Legal and Business Purposes

We may process Personal Data to:

  • comply with law;

  • respond to lawful government or court requests;

  • establish, exercise or defend legal claims;

  • enforce agreements and policies;

  • maintain business records;

  • protect Systems Heavy, our users or others;

  • conduct corporate transactions; and

  • obtain professional legal, accounting, insurance or other advice.

 

14. LAWFUL BASES FOR PROCESSING

Where the UK GDPR, EU GDPR or another law requiring a lawful basis applies, the lawful basis depends on the particular processing.

We may rely on the following bases:

14.1 Performance of a Contract

We may process Personal Data where necessary to perform a contract with you or take steps at your request before entering into a contract.

This may apply to processing necessary to provide the Game or Game Services, provide requested functionality or respond to certain contractual support requests.

14.2 Legitimate Interests

We may process Personal Data where necessary for our legitimate interests or those of a third party and where those interests are not overridden by your rights and interests.

Our legitimate interests may include:

  • operating and improving the Game and Website;

  • debugging and maintaining software;

  • understanding product performance;

  • analysing Game usage;

  • protecting our systems and users;

  • detecting fraud, abuse or security threats;

  • protecting intellectual property;

  • operating an efficient game-development business;

  • responding to users;

  • maintaining appropriate business records; and

  • establishing or defending legal claims.

Where required, we assess whether the relevant processing is necessary and proportionate and balance our interests against the interests, rights and freedoms of affected individuals.

14.3 Consent

We may rely on your consent where applicable law requires it or where we choose consent as the appropriate lawful basis.

This may include certain:

  • cookies;

  • tracking technologies;

  • optional analytics;

  • marketing communications; or

  • other optional processing.

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

14.4 Legal Obligation

We may process Personal Data where necessary to comply with a legal obligation to which Systems Heavy is subject.

14.5 Other Lawful Bases

Where applicable law provides another lawful basis that applies to particular processing, we may rely on that basis as permitted by law.

 

15. OPTIONAL AND REQUIRED INFORMATION

Some Personal Data may be necessary for us to provide particular Game or Game Services functionality.

If information is technically or contractually necessary for requested functionality and you do not provide or permit the required processing, the relevant functionality may not be available.

Other processing may be optional.

Where applicable law gives you a right to refuse optional processing without losing unrelated functionality, we will respect that right.

 

16. HOW WE DISCLOSE PERSONAL DATA

We do not disclose Personal Data merely because it may be commercially useful to another person.

We may disclose Personal Data in the following circumstances.

16.1 Service Providers

We may use third parties to help us operate the Services and our business.

Depending on the systems we use, these may include providers of:

  • hosting and cloud infrastructure;

  • Game infrastructure;

  • server services;

  • crash reporting;

  • error monitoring;

  • diagnostics;

  • analytics;

  • security;

  • data storage;

  • Website hosting;

  • email and communications;

  • customer or player support;

  • development tools;

  • testing;

  • business administration; and

  • other technical services.

Where a service provider processes Personal Data on our behalf, we take appropriate steps to require the provider to process that information consistently with applicable contractual and legal obligations.

16.2 Steam and Valve

Information may be communicated to or received from Valve where necessary for Steam distribution, Steamworks functionality, authentication, achievements, leaderboards, Steam Cloud, networking, Workshop functionality or other Steam services.

Valve may also process Personal Data independently under its own terms and privacy policy.

16.3 Professional Advisers

We may disclose information where reasonably necessary to lawyers, accountants, auditors, insurers and other professional advisers.

16.4 Affiliates

We may disclose information to entities controlling, controlled by or under common control with Systems Heavy where reasonably necessary for purposes described in this Privacy Policy and permitted by applicable law.

16.5 Corporate Transactions

Personal Data may be disclosed, transferred or reviewed in connection with a merger, financing, acquisition, reorganisation, sale of assets, insolvency proceeding or similar corporate transaction.

Where required by law, we will provide appropriate notice or protection in connection with such a transaction.

16.6 Legal Requirements and Protection of Rights

We may disclose Personal Data where we reasonably believe disclosure is necessary to:

  • comply with applicable law or valid legal process;

  • respond to a lawful request from a court, regulator or governmental authority;

  • investigate unlawful conduct;

  • protect the security or integrity of the Services;

  • enforce our legal rights;

  • protect the rights, property or safety of Systems Heavy, our users or others; or

  • establish, exercise or defend legal claims.

16.7 With Your Direction or Consent

We may disclose information where you direct us to do so or provide valid consent.

 

17. SALE AND TARGETED ADVERTISING

Systems Heavy does not sell Personal Data in exchange for monetary consideration.

Systems Heavy does not sell Game telemetry, crash data or gameplay data to data brokers.

We do not use Game telemetry for third-party targeted advertising unless we provide additional notice and any choice or consent required by applicable law.

Certain privacy laws use specialised definitions of “sell,” “share,” “targeted advertising” or similar terms that may extend beyond transfers made in exchange for money.

If Systems Heavy engages in processing that is treated as a sale, sharing or targeted advertising under an applicable privacy law, we will provide the notices and opt-out mechanisms required by that law.

 

18. AGGREGATED AND DEIDENTIFIED INFORMATION

We may aggregate or deidentify information so that it no longer identifies or can reasonably be linked to a particular individual.

We may use aggregated or deidentified information for purposes including:

  • game development;

  • product analysis;

  • statistical analysis;

  • performance analysis;

  • business planning;

  • research;

  • reporting; and

  • improving our products and services.

Where applicable law requires restrictions on attempts to reidentify deidentified information, we will maintain the information in deidentified form and will not attempt to reidentify it except where permitted by law.

 

19. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected or another compatible lawful purpose.

The appropriate retention period depends on factors including:

  • the nature of the information;

  • the purpose for which it is processed;

  • whether the information remains necessary to provide the Services;

  • the duration of your relationship with us;

  • technical and operational requirements;

  • security requirements;

  • whether information is required to investigate or resolve a problem;

  • applicable limitation periods;

  • legal, tax, accounting or recordkeeping requirements;

  • actual or anticipated disputes;

  • enforcement of agreements; and

  • whether the information can instead be aggregated or deidentified.

Gameplay telemetry and diagnostic information are generally retained only while reasonably useful for operation, analysis, debugging, security or development, unless a longer period is required for legal purposes.

Support correspondence may be retained for as long as reasonably necessary to address the request, maintain an appropriate support history, resolve disputes and protect legal rights.

Security records may be retained for a period reasonably necessary to detect patterns of abuse, investigate incidents and protect our Services.

Marketing information may be retained until you unsubscribe or otherwise object, subject to retaining limited suppression information where necessary to ensure that we honour your request.

Where Personal Data is no longer required, we will delete, anonymise, deidentify or otherwise dispose of it in accordance with applicable law and our technical capabilities.

Residual copies may remain temporarily in backups or disaster-recovery systems until those copies are overwritten or deleted in the ordinary course.

 

20. INTERNATIONAL DATA TRANSFERS

Systems Heavy is based in the United States.

Accordingly, Personal Data collected from individuals outside the United States may be transferred to, stored in or otherwise processed in the United States or other countries in which Systems Heavy or its service providers operate.

The data-protection laws of those countries may differ from those of your jurisdiction.

Where applicable data-protection law restricts international transfers of Personal Data, we will use a lawful transfer mechanism where one is required.

Depending on the relevant jurisdiction and transfer, these mechanisms may include:

  • an applicable adequacy decision or adequacy regulation;

  • the European Commission's Standard Contractual Clauses;

  • the United Kingdom International Data Transfer Agreement;

  • the United Kingdom Addendum to the European Commission Standard Contractual Clauses;

  • another approved contractual safeguard;

  • another legally recognised transfer mechanism; or

  • a statutory derogation where lawfully available and appropriate.

Where required, we will undertake any applicable assessment concerning the level of protection associated with a restricted transfer.

You may contact us at Socials@SystemsHeavy.com for further information about safeguards used for international transfers relevant to your Personal Data.

We do not treat your mere use of the Services or acceptance of this Privacy Policy as blanket consent to international transfers where applicable law requires another transfer mechanism.

 

21. DATA SECURITY

We use reasonable administrative, organisational and technical measures designed to protect Personal Data against:

  • accidental or unlawful destruction;

  • loss;

  • alteration;

  • unauthorised disclosure;

  • unauthorised access; and

  • other unlawful processing.

Our security measures are selected having regard to factors including the nature of the information, processing activities, available technology and relevant risks.

No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

If a Personal Data breach occurs, we will take steps required by applicable law, which may include notifying affected individuals or relevant authorities where legally required.

 

22. YOUR PRIVACY RIGHTS

Depending on where you live and the applicable law, you may have rights concerning your Personal Data.

These may include the right to:

  • obtain information about how your Personal Data is processed;

  • request access to Personal Data held about you;

  • request correction of inaccurate Personal Data;

  • request completion of incomplete Personal Data;

  • request deletion or erasure;

  • request restriction of processing;

  • object to certain processing;

  • receive certain Personal Data in a portable format;

  • request transfer of certain information where applicable;

  • withdraw consent where processing relies on consent;

  • opt out of certain marketing;

  • opt out of certain sales, sharing, targeted advertising or profiling where applicable;

  • appeal certain privacy-request decisions where applicable; and

  • lodge a complaint with an applicable privacy or data-protection authority.

These rights are not absolute. They may depend upon the jurisdiction, the nature of the information, the purpose of processing and the lawful basis relied upon.

We may retain information notwithstanding a deletion request where continued retention is permitted or required by law.

 

23. RIGHT TO OBJECT — UK AND EEA USERS

If we process your Personal Data on the basis of legitimate interests, you may have the right to object to that processing on grounds relating to your particular situation.

You also have the right to object at any time to processing of your Personal Data for direct-marketing purposes.

Where a valid objection applies, we will stop the relevant processing unless applicable law permits us to continue it.

To exercise this right, contact:

Socials@SystemsHeavy.com

 

24. WITHDRAWAL OF CONSENT

Where we rely upon consent to process Personal Data, you may withdraw that consent at any time.

You can withdraw consent using any control made available for the relevant processing or by contacting us where appropriate.

Withdrawing consent does not affect processing that was lawfully carried out before withdrawal.

Where a particular feature requires processing based on consent, withdrawing consent may prevent us from continuing to provide that particular feature, but it will not affect unrelated functionality unless technically necessary.

 

25. EXERCISING YOUR RIGHTS

To make a privacy request, contact:

Socials@SystemsHeavy.com

Please describe your request sufficiently for us to understand what right you wish to exercise.

We may need to take reasonable steps to verify your identity before fulfilling certain requests.

Verification requirements will depend upon the nature and sensitivity of the information requested and the risk of unauthorised disclosure or deletion.

You may use an authorised agent to make a request where applicable law permits this. We may require appropriate evidence of the agent's authority.

We will respond within the period required by applicable law.

We will not discriminate against you for exercising a privacy right protected by applicable law.

 

26. UK AND EEA PRIVACY RIGHTS

If the UK GDPR or EU GDPR applies to processing of your Personal Data, your rights may include:

  • the right of access;

  • the right to rectification;

  • the right to erasure;

  • the right to restriction of processing;

  • the right to data portability in applicable circumstances;

  • the right to object;

  • the right to withdraw consent where consent is relied upon; and

  • rights concerning certain automated decision-making.

You may also have the right to lodge a complaint with a supervisory authority.

If you are in the United Kingdom, you may have the right to complain to the Information Commissioner's Office (ICO).

If you are in the European Economic Area, you may have the right to complain to the competent supervisory authority in the country where you live or work, or where the alleged infringement occurred.

We would welcome the opportunity to address your concern directly, but contacting us first does not remove any right you have to complain to a supervisory authority.

 

27. UNITED STATES PRIVACY RIGHTS

Residents of certain United States jurisdictions may have additional privacy rights under applicable state law.

Where a state consumer-privacy law applies to Systems Heavy and to the relevant processing, those rights may include the ability to:

  • know or confirm whether we process Personal Data;

  • access Personal Data;

  • correct inaccuracies;

  • request deletion;

  • obtain a portable copy of certain Personal Data;

  • obtain information concerning categories of Personal Data, sources, purposes and recipients;

  • opt out of qualifying sales of Personal Data;

  • opt out of qualifying sharing or targeted advertising;

  • opt out of certain profiling;

  • limit certain uses of sensitive Personal Data; and

  • appeal a refusal to act on a request.

The existence and scope of these rights vary by state and may be subject to statutory thresholds and exceptions.

Systems Heavy will provide any additional jurisdiction-specific notice required if and when applicable law requires one.

 

28. CALIFORNIA

If the California Consumer Privacy Act, as amended, or another California privacy law applies to Systems Heavy and to your Personal Data, California residents may have the rights provided by that law.

Categories of Personal Data described in this Privacy Policy that we may collect include:

  • identifiers;

  • internet or other electronic-network activity;

  • commercial or entitlement information where relevant;

  • geolocation information at an approximate level where derived from an IP address;

  • inferences or analytics derived from activity where applicable; and

  • other information you voluntarily provide.

The sources, purposes and categories of recipients for this information are described elsewhere in this Privacy Policy.

We retain Personal Data in accordance with Section 19 and do not retain it for longer than reasonably necessary for the disclosed purposes.

Systems Heavy does not sell Personal Data for monetary consideration.

If our practices constitute “selling” or “sharing” under California law despite no monetary sale, and the relevant law applies to Systems Heavy, we will provide the applicable right to opt out.

We do not discriminate against consumers for exercising rights protected by applicable California privacy law.

 

29. AUTOMATED DECISION-MAKING

Systems Heavy does not currently use Personal Data to make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you within the meaning of applicable UK or EU data-protection law.

We may use automated systems for ordinary technical purposes such as:

  • error detection;

  • security monitoring;

  • fraud or abuse detection;

  • gameplay systems;

  • analytics;

  • matchmaking or balancing if such functionality is introduced; or

  • other operational functions.

The use of automation for these technical purposes does not necessarily constitute automated decision-making with legal or similarly significant effects.

If we introduce processing that is subject to specific automated-decision-making disclosure or rights requirements, we will provide the required information.

 

30. CHILDREN'S PRIVACY

The Services are not directed specifically at children under 13.

We do not knowingly seek to collect Personal Data directly from a child under 13 in circumstances where doing so would require parental authorisation that has not been obtained.

The age at which a person may validly consent to particular processing varies by jurisdiction.

Where we rely on consent and applicable law requires parental or guardian authorisation for a person of a particular age, we will seek the required authorisation where reasonably necessary.

If you are a parent or guardian and believe that a child has provided Personal Data to Systems Heavy unlawfully or without required authorisation, please contact:

Socials@SystemsHeavy.com

If we determine that Personal Data was collected from a child in violation of applicable law, we will take appropriate steps to delete or otherwise lawfully handle the information.

 

31. SPECIAL OR SENSITIVE PERSONAL DATA

Systems Heavy does not intentionally request special-category or highly sensitive Personal Data from ordinary players for the purpose of playing the Game.

Please do not provide health information, government identifiers, precise financial information or other sensitive information in free-form support requests unless it is genuinely necessary.

If we introduce functionality involving sensitive Personal Data, we will provide any additional notice and obtain any consent or other legal authorisation required by applicable law.

 

32. THIRD-PARTY LINKS AND SERVICES

The Website or Game may contain links to, integrate with or provide access to services operated by third parties.

Third-party services may collect and process Personal Data independently under their own privacy policies.

Systems Heavy is not responsible for the independent privacy practices of a third party merely because the Services link to or interoperate with that third party.

You should review the applicable third party's privacy information where appropriate.

This includes Steam and Valve services, which are governed by Valve's own privacy practices.

 

33. BUSINESS TRANSFERS

If Systems Heavy undergoes or considers a merger, financing, restructuring, acquisition, bankruptcy, reorganisation, sale of assets or similar transaction, Personal Data may be disclosed or transferred as part of that transaction where lawful.

A successor or acquiring entity receiving Personal Data will be required to process that information consistently with applicable law.

Where applicable law requires notice of a material change in the controller or use of Personal Data, we will provide that notice.

 

34. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

When we make changes, we will update the “Last Updated” date at the beginning of the Privacy Policy.

Where a change is material or applicable law requires additional notice, we may provide notice through:

  • the Website;

  • the Game;

  • Steam;

  • email, where we have an appropriate email address and use of email is appropriate; or

  • another reasonable method.

Where applicable law requires consent to a new processing activity, merely posting an updated Privacy Policy will not substitute for obtaining that consent.

We encourage you to review this Privacy Policy periodically.

 

35. CONTACT US

Questions, concerns or requests concerning this Privacy Policy or Systems Heavy's processing of Personal Data may be directed to:

Systems Heavy Inc.
8 The Green, STE B
Dover, Delaware 19901
United States of America

Privacy Email: Socials@SystemsHeavy.com

When contacting us about a privacy right, please provide enough information for us to identify the nature of your request without sending unnecessary sensitive information.

 

© Systems Heavy Inc. All rights reserved.

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