Updated: 25.5.2018

1. General Information

1.1. This Privacy Policy (“Privacy Policy” or “Policy”) regulates how We use and process Your personal data, how We handle it and how You can exercise Your rights regarding Your personal data.

1.2. This Privacy Policy also provides You with all necessary information according to the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1.3. In this Policy the following definitions are used:

  1. “Company", “We” means BOHEMIA INTERACTIVE a.s. residing at Stříbrná Lhota 747, 252 10 Mníšek pod Brdy, Czech Republic, registered in the Commercial Register kept by the Municipal Court in Prague, section B, insert 9791 (Id.No.: 272 18 864, DIČ: CZ 272 18 864).
  2. "User", “You” means the person, company or institution that uses the Services.
  3. “Services” means services, games and websites operated by the Company and used by the User.

1.4. This Privacy Policy is an integral part of the Terms of Use or End User License Agreement of any of Our Services You use and when You agree to the respective document regulating the use of Our Services, You declare that you are familiar with this Policy. This Policy also contains Our Cookie Policy which can be found here.

1.5. Information contained in this Policy shall apply to any User of Our Services particularly to players of Our games and Users of Services associated with them, Users of Bohemia Account, Users of Bohemia Store, Users of Our websites and any other Users who use any of Our Services.

1.6. We are the controller and under some circumstances the processor of Your personal data unless this Policy states otherwise.

2. Purposes of processing and legal basis for processing of personal data

Processing of personal data based on applicable laws

2.1. We process Your personal data based on applicable laws which apply to Our business activities. As the processing of Your personal data is based on law Your consent to such processing is not necessary.

  1. If You buy Our products via Bohemia Store We process Your personal data in compliance with law No. 563/1991 Coll., Accounting Act, law No. 235/2004 Coll., Value Added Tax Act and law No. 586/1992 Coll., Income Tax Act, for purposes of carrying out Our obligations arising out of mentioned laws, particularly keeping records of all purchases and payments made within Bohemia Store.
  2. If You buy Our products via Bohemia Store We also process Your personal data in compliance with law No. 634/1992 Coll., Consumer Protection Act for purposes of carrying out Our obligations arising out of this law and securing Your rights You have according to this law (for example if You wish to file a complaint that You did not receive the products You bought) and thus enable You to exercise such rights.

Processing of personal data for purposes of carrying out Our obligations arising out of the contract concluded with You

2.2. We process Your personal data for purposes of carrying out Our obligations arising out of contract concluded with You. Without processing Your personal data such contracts cannot be concluded and We cannot carry out the obligations arising thereof.

  1. If You buy Our products via Bohemia Store You conclude with Us a purchase agreement based on which We are obliged to provide You with the products You purchased. For purposes of delivery of purchased products We have to process Your personal data.
  2. We process Your personal data You filled during Your registration to Bohemia Account for purposes of providing You with Our Services. You also need to be registered and acquire Bohemia Account to be able to use some of Our Services. Without Your registration We would not be able to identify You and thus provide You with Our Services.
  3. We also process Your personal data We acquire during Your use of Our Services such as User forums, Bohemia Store, Our community Wiki, Ylands Workshop API, Arma 3 Units/Groups API and feedback tracker for purposes of providing proper functionality of such Services.
  4. We also process Your personal data when You apply for approval for server monetization. We process Your personal data for purposes of keeping records of granted approvals and for purposes of supervising whether the conditions of Our approvals are followed.
  5. We also process Your personal data during Your playing of any of Our games (including using of Our game servers) for purposes of providing proper functionality of Our games.

Processing of personal data based on Our legitimate interests

2.3. We also process Your personal data based on Our legitimate interests.

  1. We process Your personal data We acquire during Your use of Our Services such as User forums, Bohemia Store, Our community Wiki, Ylands Workshop API and Arma 3 Units/Groups API for purposes of preventing fraudulent behavior of other Users during their use of such Services and for purposes of improving Our Services. Legitimate interest consists of improving Services and preventing fraudulent behavior of some Users.
  2. We also process Your personal data We acquire during Your use of Our feedback tracker (as well as the content You public via Our feedback tracker) for purposes of processing Your feedbacks and improving Our Services. Legitimate interest consists of ability to process Your feedback and improving Our Services.
  3. We also process Your personal data when You launch Our games Arma 3 and DayZ through Arma 3 – Launcher and DayZ – Launcher for purposes of collecting data about game crashes so We can improve the qualities of the particular game in the future. Legitimate interest consists of ability to monitor the crashes of Our game in order to be able to improve Our games or remove bugs.
  4. We also process Your personal data during Your playing of any of Our games (including using Our game servers) for purposes of detecting and preventing fraudulent behavior of players of Our games and for purposes of improving Our games. If You play the following games: Arma 3, Arma 2, DayZ and Argo Your personal data is transferred to BattlEye Innovations e.K., Gmelinstr. 66, 72076 Tübingen, Germany. When installing above mentioned games You may opt for installing software BattlEye to be able to access certain servers where You can play Our games in multiplayer mode. Such installation is optional and does not limit the functionalities of Our games. Use of above mentioned software is regulated by its provider. Legitimate interest consists of preventing fraudulent behavior of some players and improving Our games.
  5. We also process the email addresses of Our customers We have acquired from them for sending them Our newsletters for purposes of keeping them informed about Our products and Services all via application described in Sec 2.4. a) of this Policy. Legitimate interest consists of informing Our customers about Our products and Services.

Processing of personal data based on Your consent

2.4. We also process Your personal data based on Your consent.

  1. Based on Your consent We process Your email address You gave Us during Your registration to or use of Bohemia Account to:
    • Send You newsletters and other marketing materials containing marketing information regarding Us (such as Our current and new products and other information and events regarding Our Company) all via application Mailtrain operated by Us. To send the newsletter via this application We may use third party services.
    • Send You newsletters and other marketing materials containing marketing information regarding Us (such as Our current and new products and other information and events regarding Our Company) all via application MailChimp operated by company The Rocket Science Group LLC, 75 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, providing that this company will obtain Your email to send You Our newsletters or other marketing materials through the application.
  2. Based on Your consent We process Your personal data We can collect during Your playing of Our games which offer You an opportunity to enable analytical functionalities. All collected data will be used for statistical analysis for purposes of improving Our games and Your game experience. Such collected data is pseudonymized and We are not able by standard means to identify You personally.

2.5. List of personal data We process according to Sec. 2. of this Policy is contained in Appendix No. 1 to this Policy including its classification.

3. Ways of processing of Your personal data

3.1. Privacy and security are key considerations in the creation and delivery of Our products and Services. We have assigned specific responsibilities to address privacy and security related matters. We enforce Our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, We limit access to our databases containing personal data to authorized persons having a justified need to access such information.

4. Recipients of Your personal data

4.1. The personal data We collect is mainly disclosed to selected employees of Our Company. The access of these employees to Your personal data is limited and these employees may access Your personal data only in the extent they need to carry out the obligations arising out of their work. All these employees signed a non-disclosure agreement with Our Company and are also obliged to behave in compliance with Our policies regulating the use of Our systems where they can access Your personal data.

4.2. Personal data collected by Us with regard to Your purchases via Bohemia Store may be transferred to third parties based on the legal obligations We may have. We may disclose some of Your personal data to Tax authorities, criminal law authorities and in certain extent also to judicial authorities.

4.3. Some of Your personal data regarding Your purchases in Bohemia Store may be shared with Our partners which provide for Us accounting or similar services and which operate Bohemia Store for Us. We may also share necessary subset of Your personal data We collect during Your use of Our Services with Our affiliates in order to operate and improve Our Services. All these partners or affiliates concluded a non-disclosure agreement with Our Company and are also obliged to behave in compliance with Our policies regulating the use of Your personal data.

4.4. Your email address We use for emailing may be shared with providers of such emailing services providing that Your email address cannot be used for any other purpose than the purpose for which You gave Us Your consent. Your personal data we collect based on Your consent according to Sec. 2.4. b) of this Policy may be uploaded on third parties´ servers belonging to providers of analytical functionalities We use for processing of Your data providing that Your personal data cannot be used for any other purpose than the purpose for which You gave Us Your consent. For enabling users from the whole world to play Our games we have to use third party servers to provide proper functioning of Our games. Data regarding Your playing of Our games may be uploaded to these servers. With providers of servers We use within providing of Our Services to You We have concluded the agreements based on which Your personal data are secured in compliance with GDPR.

4.5. List of Our partners and third parties with which We may share Your personal data is listed in Appendix No. 2 to this Policy.

5. How long do We keep Your personal data?

5.1. We keep and process Your personal data only for the time period which is necessary to satisfy the purposes for which We process it. We regularly check whether there is still need to keep Your personal data and process it for particular purposes. If We find that keeping Your personal data is not necessary We erase it. The time period for which We keep Your personal data is listed in Appendix No. 1 to this Policy.

6. The sources of Your personal data

6.1. We acquire Your personal data from following sources:

  1. Directly from You during Your registration to Bohemia Account or other of Our Services where necessary, by filling forms during Your use of Our Services or by direct communication with You.
  2. From monitoring of the use of Our Services. This way We also acquire Your Steam ID so We can communicate with You.

7. Your rights

7.1. Right to access and rectification of personal data. You have the right to access and rectify or amend incorrect or incomplete personal data about You which We collect.

7.2. Right to erasure of personal data. You have the right to request Us to erase all Your personal data we collected during Your use of Our Services based on Your consent or data that is no longer necessary or those that have been unlawfully processed. If you would like Us to erase Your personal data You can contact Us at dataprotection@bohemia.net. Once We receive Your request We erase all the personal data We are obliged to according to GDPR. We cannot erase personal data processed based on applicable laws.

7.3. Right to restriction of processing of personal data. You have the right to request Us to restrict processing of Your personal data in some cases until your request to erase or change your personal data or your objection is not processed.

7.4. Right to portability of Your personal data. You have the right to request Us to give You Your personal data You provided to Us if such data is processed based on Your consent or based on the contract concluded with and such personal data is processed automatically. If such request appears We provide You with Your personal data We collected in structured machine-readable form. You are also entitled to request Us to transfer such personal data to a new controller if it is technically possible.

7.5. Right to withdraw the consent to process Your personal data. Where We process Your personal data based on Your consent You can withdraw such consent at any time by sending Us request at dataprotection@bohemia.net or by other means enabled within Our Services.

7.6. Right to object to processing of Your personal data. If You feel that processing of Your personal data based on legitimate interest is not proportional to Your rights You can object to such processing and request Us to make remedy.

7.7. Right to file a complaint. If You think that during the processing of Your personal data We breached applicable laws You are entitled to file a complaint to the official authority residing in Your state, in the state where You work or where the infringement of your rights took place. In the Czech Republic such official authority is:

The Office for Personal Data Protection
Pplk. Sochora 27
170 00 Praha 7
Czech Republic

8. Final provisions

8.1. This Policy is valid and effective as of 24th May 2018.

8.2. We may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, We will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.

8.3. If You have any questions regarding the processing of Your personal data or wish to exercise any of Your rights according to GDPR You can contact Us at dataprotection@bohemia.net.

Appendix No. 1 to Privacy Policy

List of personal data we process and the time period for which We keep it

Provision of Privacy Policy Processed personal data Time period for which We keep personal data
Sec. 2.1. a)
  • Records of purchased products
  • Records of executed payments
  • Records of refunds
10 years
Sec. 2.1. b)
  • Name
  • Address
  • Date of birth
  • Email address
  • Bohemia Account ID
  • Records of complaints
10 years
Sec. 2.2. a)
  • Name
  • Address
  • Date of Birth
  • Email address
  • Bohemia Account ID
  • Steam ID
  • Username
  • PayPal identification
5 years
Sec. 2.2. b)
  • Name
  • Address
  • Login
  • Last logon
  • Email address
  • Bohemia Account ID
  • Facebook ID
  • Google Play/Apple Game Center ID
  • Live ID
  • Twitter ID
  • PSN ID
  • Twitter ID
  • Steam ID
  • Username
  • IP Address
Until Bohemia Account is terminated
Sec. 2.2. c)
  • Name
  • Address
  • Telephone No.
  • Date of Birth
  • Login
  • Last logon
  • Bohemia Account ID
  • Facebook ID
  • Steam ID
  • Username
  • IP address
Until Bohemia Account connected with such Services is terminated
Sec. 2.2. d)
  • Name
  • Email address
  • Nickname
  • IP address of server
Until the approval for monetization is withdrawn
Sec. 2.2. e)
  • Name
  • Login
  • Last logon
  • Bohemia Account ID
  • Facebook ID
  • Google Play/Apple Game Center ID
  • Username
  • IP address
  • Hardware data about Your device,
  • Information about command line (such as name of the computer)
  • The list of running processes on Your device
  • Setting of Your device
  • Crash dumps
Until the game is uninstalled from Your device
Sec. 2.3. a)
  • Login
  • Last logon
  • Bohemia Account ID
  • Facebook ID
  • Steam ID
  • Username
  • IP address
For duration of legitimate interest
Sec. 2.3. b)
  • Name
  • Login
  • Last logon
  • Bohemia Account ID
  • Facebook ID
  • Steam ID
  • Username
  • IP address
For duration of legitimate interest
Sec. 2.3. c)
  • Username
  • Hardware data about Your device,
  • Information about command line (such as name of the computer)
  • The list of running processes on Your device
  • Settings of Your device
  • Crash dumps
For duration of legitimate interest
Sec. 2.3. d)
  • Name
  • Login
  • Last logon
  • Bohemia Account ID
  • Facebook ID
  • Google Play/Apple Game Center ID
  • Username
  • IP address
  • Hardware data about Your device,
  • Information about command line (such as name of the computer)
  • The list of running processes on Your device
  • Setting of Your device
  • Crash dumps
For duration of legitimate interest
Sec. 2.3. e)
  • Email address
Until the person unsubscribes from receiving newsletters
Sec. 2.4. a)
  • Email address
Until the Consent is withdrawn or the email address ceases to exist
Sec. 2.4. b)

Data regarding Your playing of a specific game, particularly:

  • Your time spent within the game or its parts (the time of Your login and Your last logon),
  • the region from which You play the game (including Your IP address),
  • Your on-line activities within the game or its parts (such as which activities You did during playing, which
  • characters You picked, how Your characters died),
  • information about crashes and connection issues
  • statistics of Your activities in in-game shop, and
  • characteristics of Your hardware
Until the consent is withdrawn or the game uninstalled from Your device

Appendix No. 2 to Privacy Policy

Identification of Our Partner Identification of data shared with Our partner Purpose of sharing
BOHEMIA INTERACTIVE STUDIO s.r.o.,
ID No.: 257 64 730,
registered office: Nad Pomnikem 467/9, Prague 5, Postcode: 152 00, Czech Republic
  • Records of purchased products
  • Records of executed payments
  • Name
  • Address
  • Date of Birth
  • Email address
  • Bohemia Account ID
  • Steam ID
  • Username
  • PayPal identification
  • Records of complaints
Purposes of operating Bohemia Store.
Purposes of providing accounting and related services.
The Rocket Science Group LLC,
Registered office: 75 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, United States of America
  • Email address
Purposes of providing emailing services via application MailChimp.
Treasure Data, Inc.,
registered office: 2565 Leghorn St., Mountain View, CA 94043, United States of America

Data regarding Your playing of a specific game, particularly:

  • Your time spent within the game or its parts (the time of Your login and Your last logon),
  • the region from which You play the game (including Your IP address),
  • Your on-line activities within the game or its parts (such as which activities You did during playing, which characters You picked, how Your characters died),
  • information about crashes and connection issues
  • statistics of Your activities in the in-game shop, and
  • characteristics of Your hardware
Data is uploaded to the servers of our Partner so we can use the analytical functionalities of Our partner providing that Our partner shall not access Your personal data.

iomart Hosting Limited,
Registered office: Lister Pavilion, Kelvin Campus, West of Scotland Science Park, Glasgow, G20 0SP, UK (servers in UK)

Amazon Web Services, Inc.
Registered office: Seattle, WA 98108-1226, United States of America (servers in South America – Brazil)

OVH US LLC,
Registered office: 11480 Commerce Park Dr., Suite 500
Reston, VA 20191, United States of America (servers in USA, Australia)

Multiplay (UK) Ltd.,
Registered office: The Oak Barn
Whitefield Business Units, Lepe Road, Blackfield, Southampton
SO45 1XR, UK (servers in USA, Australia)

Fragnet Networks AB,
Registered office: Ostra Vittusgatan 36, SE-37133 Karlskrona, Sweden (servers in USA, Australia)

Data regarding Your playing of Our games For enabling worldwide users to play Our games We have to use third party servers to provide proper functioning of Our games.

OUR AFFILIATES

BOHEMIA INTERACTIVE STUDIO s.r.o.,
ID No.: 257 64 730,
registered office: Nad Pomnikem 467/9, Prague 5, Postcode: 152 00, Czech Republic

BOHEMIA INTERACTIVE s.r.o.,
ID No.: 47 489 863,
registered office: Palárikova 27, 811 04 Bratislava, Slovakia

BOHEMIA INTERACTIVE B.V.,
RSIN: 85614799, registered office: Danzigerkade 223, 1ste verdieping, 1013AP Amsterdam, the Netherlands

Bohemia Interactive Co., Ltd.
registered office 378/80-81,
Moo 12, Nongprue, Banglamung, Chonburi, 20150, Kingdom of Thailand

Necessary subset of Your personal data For providing of proper functioning of Our services