Last updated: 2 June 2025

Introduction -- What is this notice for?

This privacy notice (this "notice") is about how we use personal information about you called "personal data" when you're playing the Wardogs playtest (the "game" or the "service").

Who are we?

We are Bulkhead ("we" or "us" in the rest of this notice).
We are located at The Tramshed, St James Yard, 19-21 St James's St, Derby DE1 1RN, United Kingdom and you can contact us at: info@bulkhead.com.
 

We make decisions about how and why we use your personal data when you use the game. This means we're what's called a "data controller" of this personal data.

What is personal data and why is it important?

Personal data is any information which identifies you (like your name, nickname, and email address). It is also information which can be pieced together with other information to identify you like your age, gender, or the technical IDs given to your phone/laptop (these IDs are sometimes known as "online identifiers"); and the interactions of you and your character in the game from which it's possible to work out things about you, such as play time, item acquisition rates, inventory amounts, avatar characteristics and choices ("gameplay data").

It's important to know what we do with your personal data, because you should be able to control what happens to it. By reading and understanding this notice, you will know how we collect, use, share, and protect your personal data, and how you can ask us to use it differently.

How do we collect your personal data?

Sometimes you give us your personal data directly - for example, when you are filling in forms at the end of the playtest or contacting our customer support teams. The information that you are asked to provide and the reasons why you are asked to provide it will be made clear to you at the point we request it. Providing us with this information is voluntary, but if you choose not to provide it you may not be able to access the service or certain aspects of the service.
 

Sometimes we also collect information about you automatically when you use the service. Where this information can be linked back to you, it will be personal data. This information includes IP address, geographic location information using IP information, event data related transactional data.

When are we allowed to use your personal data?

We are only legally allowed to use your personal data where a "legal basis" allows us to do so. These are the legal bases which could apply:

Legal Basis 1: "Contract" We need to carry out or sign up to a contract

When does this Legal Basis apply?

When it's necessary to use your personal data to perform a contract with you, or because you have asked us to do something before signing a contract with you that requires the processing of your personal data.
 

In these cases, if you don't provide your personal data, then we won't be able to perform the contract or do what you have asked us to do before signing the contract.

Legal Basis 2: "Legitimate Interest" - It's in our or someone else's "legitimate interests"

When does this Legal Basis apply?

"Legitimate interests" is a legal phrase. It usually means a commercial or business interest that is important to us or another company, and which we've balanced against your right to privacy.

We will always let you know what the interest is, and you can object to us using your personal data for these reasons via email at info@bulkhead.com.

Legal Basis 3: "Consent" - You have given us your consent

When does this Legal Basis apply?

Sometimes we will ask for your (or we might need to ask for your parent's) consent to use your personal data. This consent will always be clear and separated out from other information.

You can always withdraw your consent by contacting us at info@bulkhead.com.

 

Legal Basis 4: "Legal obligation" - We need to do something a legal obligation tells us to

When does this Legal Basis apply?

When it's necessary to use your personal data so that we can perform our legal and regulatory obligations -- so that we don't break the law.

What personal data about you do we use, and why?

This table lists the types of personal data we use about you, and our reason for this:

(A) Information you provide to us (either directly or through a third party):

(1) Account login information

• Personal data we use: SteamID, date of birth and alias and a unique identifier that we use for the playtest.

• Why we use this personal data: We use this information to allow you to login to the service from a third-party platform in accordance with your request.

• Legal Basis for processing: Contract.

(2) Customer Support

• Personal data we use: Any information voluntarily provided to customer support including email, login data, gameplay data and transaction data.

• Why we use this personal data: We use this information to help provide support to you in relation to the issue you've contact us about.

• Legal Basis for processing: Legitimate interest -- our interest in answering your questions about our service in order to improve your experience and improve our relationship with you.

(3) Security

• Personal data we use: IP address, IP lookup information, account ID.

• Why we use this personal data: We use this information to help provide security and network protection mechanisms.

• Legal Basis for processing: Contract Where the data processing activities are not necessary for performance of a contract -- Legitimate interest -- our interest in ensuring the security of our services & technologies.

(4) Opt-in surveys

• Personal data we use: email, account alias, platform, transaction data.

• Why we use this personal data: We use this information when you voluntarily provide it for the purposes of providing you with update and promotional emails.

• Legal Basis for processing: Consent for surveys.

(5) Data subject request information

• Personal data we use: alias, email address, transaction history, login history, proof of user's identity.

• Why we use this personal data: If a data subject request is submitted, we use this information to confirm the requestor's identity, your rights and to process the request.

• Legal Basis for processing: Legal obligation - our obligations under data protection laws.

(6) Sending legal reports/responding to court orders

• Personal data we use: Purchase and activity data, online identifiers, information requested by law enforcement.

• Why we use this personal data: We may be required by law to disclose this information to law enforcement bodies.

• Legal Basis for processing: Legal obligation -- our obligations under intelligence and security laws.

(B) Information collected automatically or generated as part of our service to you:

(1) Transaction records

• Personal data we use: details of transactions linked to your account using the in-game currency.

• Why we use this personal data: We use this information to facilitate your transactions in game using the in-game currency.

• Legal Basis for processing: Contract.

(2) Generated account ID

• Why we use this personal data: We generate this and use this to store your service gameplay data (including progress) with your profile, and it allows you to connect to the service server.

• Legal Basis for processing: Contract.

(3) Gameplay Data

• Personal data we use: Various gameplay related data (i.e. account state, mission time, item acquisition rates, inventory amounts, ability usage).

• Why we use this personal data: We use this information to improve the game and provide you with feedback and information about your gameplay and progress.

• Legal Basis for processing: Legitimate interest our interest in improving your and others' future experiences with the game.

(4) IP address

• Why we use this personal data: We use this information to: allow you to connect to the service server, optimize your matchmaking experience, determine your country of origin, security and anti-cheat functions.

• Legal Basis for processing: Contract + See legal bases for matchmaking + security / anti-cheat.

(5) Anti-cheat and security related information

• Personal data we use: basic hardware information, uniquely generated hardware ID, IP address, running process list, operating system information, user account information, processes, memory, and driver which is related to the game running, user behaviour and status that may be related to cheating software.

• Why we use this personal data: We use this information:

  • for security and verification purposes, including to detect and observe cheating behaviours and consider restricting or banning access to the service

  • identify and address bugs and assess game function for optimisation

  • solve game crashes and optimise compatibility of hardware with the game

  • to combat users registering for multiple accounts

  • If your account is determined to breach our Terms of service, we may consider restricting or banning your access to the service.

• Legal Basis for processing: Legitimate interest -- our interest in ensuring the security of our services, maintaining a fair gaming environment

(6) Data to provide you with chat access

• Personal data we use: audio and text communicated to other players in-game, and through public chat channel or sent to peers, including alias and account ID.

• Why we use this personal data: If you engage with chat services then we will process such data in order to deliver your messages to other users.

• Legal Basis for processing: Contract.
   

Who do we share your personal data with?

Sometimes we share your personal data with other companies and organisations.

The types of companies and organisations we share your personal data with are as follows:

• Playtest manager -- we need help from other companies to get you to join the playtest and set up your account and we might share your personal data with those companies as part of that process or they may obtain personal data from you directly. For this playtest, we are using firstlook.gg

• Companies in our "group" of companies -- We have lots of different companies in our "group", who are linked to us. Some of them provide us with services to help us to manage our games. We share your personal data with these other companies so they can provide us with these services, and to fulfil some of our legal obligations.

• Other companies who provide us with services -- We need separate companies to provide us with services we use to support the game (for example, hosting providers, companies which process support ticket IDs and support communication, anti-cheat software providers, and companies that help send or display marketing or advertisements if these are relevant). We share your personal data with those companies so they can provide us with those services.

 

For this playtest, the services that we use include Easy Anti-cheat, a tool provided by Epic Games to protect our games from cheating, and we use AWS to host the servers.

• Regulators, official authorities, and other third parties in relation to legal compliance -- For example, the police or the government might legally require use to give them personal data to help them with an investigation, or we might be required to give these companies personal data to enforce our terms, address security and fraud, and to protect you.

• A third party that acquires all or part of our business -- we might disclose your personal data to another company which buys or undertakes another type of corporate transaction in respect of our shares or buys all or part of our assets.
   

Does your personal data ever go to other countries?

Yes, sometimes your personal data goes to other countries as part of using your personal data in the ways we listed above. These countries will include the United States of America and European Union.

If you are in the UK, the EU, or Switzerland and your personal data goes outside of the UK, the EEA or Switzerland, the law requires us to take extra steps to make sure your personal data is protected in the place it is going to.

We do the following things to make sure we are not breaking these laws:

• If an adequacy decision/regulation from the European Commission or UK government is in place, we will rely on that adequacy decision.

• Before you enter the game, we ask for your consent to transfer your data overseas (we might need to ask your parent to provide this consent for you).

• If we send your personal data to a company (either in our "group" of companies or a separate company) which is in a jurisdiction not subject to an adequacy decision so they can provide us with services, we will have a contract with that company called the "standard contractual clauses and the UK addendum" which requires that company to protect your personal data.

• Sometimes the companies who provide us with services have special documents in place called "binding corporate rules". If a company has one of these documents in place, this will be enough to make sure the personal data is protected.

We might take similar steps where you are in another country with similar legal requirements, as well.

If you want proof of or more information about any of these things, you can contact us using info@bulkhead.com.

How long do we keep your personal data for?

We only keep your personal data for as long as is necessary and much of the gameplay data will be deleted once the game session ends or at the end of the playtest. We will keep some data for longer to get the most benefit out the playtest, including information on your opinions about the game - generally we will only keep this data for a maximum of 18 months after completion of the playtest.

We might need to keep your personal data for longer if a law requires us to or if it relates to a contract (for example, UK laws about record-keeping and tax and the non-disclosure agreement that you sign to enter into the playtest. This can be up to 6 years. If we are keeping your personal data for longer, we will make sure it is secure and you can still change what we do with it (see below).

Will we use automated decision-making?
 

We work with a third-party anti-cheat software provider to detect cheating. We may process your personal data using automated decision-making methods in order to identify users who are cheating by observing and detecting cheating behaviours and users registering for multiple accounts.
 

If your account is determined to breach our Terms of Service, we may consider restricting or banning your access to the playtest and any future playtests. If this happens, you will be informed of the outcome of the decision and you will have the right to obtain human intervention to express your point of view and context the decision by contacting us at info@bulkhead.com.

What control do you have over your personal data, and how can you make us change what we do with it?
Because your personal data is about you, you should be able to control what happens to it.

We provide different ways you can do this. The easiest way is to write us an email at info@bulkhead.com requesting one or more of the following:

• "Stop using my data" -- you can object to how we are using your personal data if we are using it based on legitimate interests (see above) in certain situations.

• "Download my data" -- you can request a downloadable copy of your personal data and for us to transfer it to another party. If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible;

• "Access my data" -- you can request to access to the personal data we use about you, and information about how we use it and who we share it with;

• "Delete my data" -- you can request that your account or specific personal data we store about you is deleted from the game. Please be aware that once an account has been deleted there is no way to recover it;

• "Correct my data" -- you can request that information about you that is wrong or outdated is corrected. You can update your account information at any time by logging on to your account profile;

• "Restrict the use of my data" - you can request to restrict the use your personal data, for example to storage purposes only;

• "I don't consent any more" -- you can withdraw your consent if our reason for using your personal data is consent (see above). We will then stop using your personal data in this way (though this doesn't affect the lawfulness of the processing until you withdraw).

Unfortunately, we're sometimes not able to do the things you tell us to, for example because of the particular legal basis we have been relying on to process your personal data, or because it would interfere with another person's own privacy rights. If this happens, we'll explain to you why we aren't able to do what you tell us to with that piece of personal data.
 

We may also be required to keep certain personal data to satisfy legal requirements or for security purposes, or if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Updates to this policy

We may make updates to this policy from time to time (for example because our services have changed or because of changes in laws). We will appropriately notify you of this. The date this notice was last updated can be found at the top.
 

How can you ask questions or make a complaint about your privacy?

If you have any questions about what we have said in this notice or how your personal data is used, you can contact us about it.

Our contact details are: info@bulkhead.com

Our data protection officer's contact details are: Philippa Ludin philippa.ludin@bulkhead.com

If you are located in the EEA and have questions about your personal data or would like to request to access, update, or delete it, you may contact our representative at:

Bird & Bird GDPR Representative Ireland

• Key contact: Vincent Rezzouk-Hammachi

• Email: EUrepresentative.Splash@twobirds.com

• Address: Deloitte House, 29 Earlsfort Terrace, Dublin 2, D02 AY28

You can also contact the official organisation which regulates personal data in your country (the "regulator") to lodge a complaint, if you think we are not using your personal data correctly. If you are in the UK or the EEA:

• You can find a list of EEA data protection regulators here.

• In the UK, the regulator is the Information Commissioner's Office which you can contact here.

Thank you!