Effective Date: May 5th, 2023


These terms apply to the use of apps and other products and services developed and/or published by BEARHAMMER GAMES LTD.  ( “we” / “us”) and as further detailed below. We process your data as a controller. We are a company registered in Scotland, with company number SC616982.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all of our games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (the “Games”), as well as any other online features relating to the Games, our websites (including, without limitation, (the “Websites”). Together, the Games and Websites are referred to herein as the “Online Services.”

Except where it may otherwise be expressly set out in terms of use for our relevant Online Service, our Online Service is not marketed to users under the age of 16, and those aged under-16 should not use our Online Services. We do not use our Online Services to knowingly solicit information from, or market to, those under the age of 16. 

If you have any questions or comments about this Privacy Policy, or if you want to exercise your right to object to the processing of your personal data, you can contact us at

We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose and means for which personal data you supply through these Online Services is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (the “EU GDPR”), the EU GDPR as it forms part of UK law by virtue of the European Union (Withdrawal) Act 2018  (the “UK GDPR”) and the UK Data Protection Act 2018.

Please read this Privacy Policy carefully, as it contains important information about the following:

  • What information we may collect about you;
  • How we will use the information we collect about you;
  • Whether we will disclose your details to anyone else; and
  • Your choices and rights regarding the personal data we hold about you.

This Privacy Policy should be read in conjunction with our terms of use as may be applicable in respect of the relevant Online Service. Where terms of use are applicable, they will be made available via the relevant Online Service.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies, and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Online Service.


We may collect and process the following personal data from you when you use our Online Services (together, the “Online Services Information”):

Information provided by you when using a Game:

(“Submitted Information”)

  • Username;
  • Language; and
  • Your physical demographic information (provided during in-game calibration).

Information that may be provided by you when you contact us for support:

(“Contact Information”)

  • Your name; and
  • Your email address.

Information about your activities:


We will collect some technical information about your use of our Online Services through the use of tracking technologies and analytics. Personal data we will collect in this way, depending on your use of the Online Services and your preferences, include the following: 

  • Your IP address and MAC address;
  • Your user/account ID with us;
  • Device country;
  • Time, date, and install source of your Game;
  • Session start, duration and end timings;
  • Identifying information about crashes and defects;
  • Device information (e.g. device type, device unique ID and browser);
  • Session results, progress and timings; and
  • ‘Events’ related to your Game usage, such as your achievement of a milestone and other particular events during your Game usage (such as session durations, completing a tutorial, map sections completed, menu/navigation usage).

This also includes the use of ‘cookies’ and similar technologies, as further detailed below.

User-generated content and information hosted and displayed in our Online Services:

(“User Content”)

When using our Online Services, you may decide to post information that may or may not contain personal data, in accordance with the rules of the relevant Online Service (where this functionality may be available). Similarly, when using some of our Games or other Online Services (where this functionality is provided by us) you may decide to post certain content such as leaderboard information and messages to other users, in accordance with the terms of use applicable for the relevant Online Service (“Leaderboards”).

Leaderboards may be posted automatically and can be a significant or essential part of the gameplay and user experience. Please be aware that it may not be possible for us to turn off this type of User Content functionality for you within the Online Service.

As per our T&Cs, sharing of Games and their contents is not permitted. However, we cannot control the wider dissemination via the public internet of personal data that you may choose to post, or make available, in User Content or Leaderboards. 

Accepting this Privacy Policy indicates that you agree that BEARHAMMER GAMES LTD. can request your Steam username data and display it in-game for the purpose of profile creation.


To provide the Online Services to you 

We will process information about you (including the Submitted Information and certain Analytics information) to deliver our Online Services to you under the terms of use agreed between us. The processing of information in this way is necessary, for example, for us to record your progress and current status within an Online Service such as a Game, and to ensure the Online Services deliver the features promised and function properly. For these purposes, we rely upon the legal basis of the performance of a contract (being performance of the terms of use agreed between us) and our legitimate interests (our commercial interests in providing enhanced services and functionality to you).

Where we process your personal data for Leaderboards, or other User Content, in our Online Services, we also rely upon our legitimate interests as a legal basis for undertaking that processing, being our commercial interests in providing an enhanced experience in our Online Services (though, depending on the nature of our particular Online Service, the Leaderboard or User Content may be a part of the core functionality of the Online Service). 

We do not actively collect special category data about you, such as health data, and we do not create information about your presumed health status.

To enable purchases

If you make purchases through the Online Services (where we may make that functionality available), your order and certain Online Services Information (such as, without limitation, your Contact Information if you contacted us, and certain Analytics information) may be processed so that you can access these features within the Online Service.

For the above purposes, we rely upon the legal basis of performance of a contract (being performance of the terms of use agreed between us).

To respond to your enquiries and requests for support 

We may process certain of your Online Services Information (including your Contact Information and certain other Online Services Information) so that we are able to properly respond to your enquiries and support requests in accordance with the terms of use agreed between us.

For the above purposes, we rely upon the legal basis of performance of a contract (being our terms of use with you for the relevant Online Service) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.

To better engage current users 

We may process certain information (including Submitted Information and certain Analytics) to encourage engagement from our Game users and to notify them of new recommendations, services, virtual items or other promotions or offers (where we may make these available). We process this information based on our legitimate interests, being our commercial interests in improving the success of our Games and user engagement with our Games.

To prevent fraudulent or illegal activity

We may process your Online Services Information for our legitimate interests of ensuring that your use of our Online Services is lawful and in compliance with our agreement (being the terms of use agreed between us), to prevent disruption to our Online Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.

To help us to improve the Online Services and help us fix any problems   

We may process information about you (being certain of the Submitted Information and Analytics) so that we can analyse and improve our Online Services and also for us to develop new Online Services or new parts thereof.

This processing is necessary for us to pursue our legitimate interests, being our commercial interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Games and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Online Services.

To help us to understand your usage of the Online Services

We may process information (being the Online Services Information or any part thereof) to understand how users use our Online Services and to compile statistical reports regarding that activity, as well as understand how users progress within a particular Online Service such as a Game. This data processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems and to improve our future products and services.

To keep you up to date

Where you have consented, or where it is otherwise lawful for us to do so, we may use your Online Services Information to send you emails to keep you informed about our news and products. You can withdraw your consent anytime by using the “unsubscribe” feature attached to each email.


We will share your information with third parties only in the ways that are described in this Privacy Policy.

Group members, personnel, suppliers or subcontractors: We keep your information confidential but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal data to third parties (e.g. gaming platform operators, game console manufacturers or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of BEARHAMMER GAMES LTD, our customers or others.

Digital Content Stores:  Where our Game is downloaded through a third party store service such as (without limitation) Steam or Oculus, we may disclose your personal data to the relevant store/platform for the purposes of facilitating any in-Game payments made through these platforms.


We will obtain your consent to collect your information to be used for marketing purposes that require consent. Where this is not required, we may rely on our legitimate interests as described above. 


You have the rights over the way that we process your personal data, as set out below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. In some cases, your ability to access or control your personal data will be limited as required or permitted by such applicable laws.

Ask for a copy of personal data we are processing about you and have inaccuracies corrected or request erasure:

You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. You can request a copy by emailing

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Object to us processing personal data about you:

You can ask us to restrict, stop processing or delete your personal data if:

  • you consented to our processing the personal data and have withdrawn that consent;
  • we no longer need to process that personal data for the reason it was collected;
  • we are processing the relevant personal data for direct marketing purposes;
  • we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate  interest of BearHammer Games Ltd. or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed;
  • you need the personal data to be deleted in order to comply with legal obligations; and/or
  • the personal data is processed in relation to the offer of a service to a child.

You can request account deletion by sending an email to

Make a complaint to a Supervisory Authority:

If you are unhappy with how we process your personal data, please contact us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. Contact information for the Information Commissioner’s Office, the UK’s independent authority to uphold information rights, is available here: 


In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. The specific retention periods depend on the nature of the information, why it is collected and processed, and the nature of the legal requirement. Details of retention periods for different aspects of your personal data are available from us on request by contacting us at


We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 16. In the event that we learn that we have collected personal data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16 years of age, please contact us at


We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Online Services, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored, or otherwise processed by us. 

Please be aware that, while we make the security of our Online Services and your personal information a high priority, no security system can prevent all security breaches. 

Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted through our Online Services; the sharing of your personal information with us and any transmission is at your own risk.


The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or the UK. It may also be processed by staff that operate outside the EEA or UK and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of the Online Service, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where your personal data is transferred outside of the EEA or the UK to a territory not subject to an adequacy decision by the European Commission or the UK, we have agreements in place with the relevant parties, which include standard data protection clauses adopted by the European Commission and/or the UK, to ensure that appropriate safeguards are used to protect your personal data.


All questions, comments or enquiries should be directed to BEARHAMMER GAMES LTD. at  We will endeavour to respond to any query or questions within a reasonable time. 

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