Last update: 15 June 2023
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.
1. 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.
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.
2. 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
4. 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.
5. 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.
6. 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 email@example.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 firstname.lastname@example.org.
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.
7. Cookies and Similar Technologies
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.
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.
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 email@example.com.
9. 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
However, you are always free to contact your own EU-vested authority.
10. How to Contact Us
If you have any questions about the use of your personal data, please send us an email to firstname.lastname@example.org.
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 email@example.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:
17 A New Bride Street