survey PRIVACY notice

1. INTRODUCTION

With this information text, Embark Studios AB ("Embark"/"we") intend to fulfill our transparency obligations under the General Data Protection Regulation (the “GDPR”) the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and any other applicable privacy laws. An important aspect of this obligation is to inform individuals of what personal data we collect and how we process that personal data.

2. CONTROLLER (“business,” for CCPA purposes):

Controller: Embark Studios AB

Corporate identification number: 559172-3019

Address: Kungsträdgårdsgatan 16

111 47 Stockholm

E-mail: privacy@support.embark-studios.com

3. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS WHEN YOU PARTICIPATE IN THE SURVEY

This Privacy Policy provides information about Embark’s collection and processing of your personal data when you participate in the survey.

Categories of personal data processed by Embark:

  • Your answers to the survey questions.

  • A unique respondent ID (included in your invitation link).

  • Gameplay data already held by Embark (such as how often and how long you play, platform, and in-game activity).

For purposes of the CCPA, the categories of personal information above correspond to the following statutory categories: identifiers (the respondent ID) and internet or other electronic network activity information and inferences (survey answers and gameplay data). We do not collect Social Security numbers, financial account information, precise geolocation, or other categories of sensitive personal information through this survey, and we do not use or disclose any sensitive personal information for purposes beyond those permitted under CCPA Section 7027(m).
Note that the personal data is processed in a pseudonymized manner, connecting your answers and gameplay data only to the respondent ID and not to your email, player name or other direct identifiers.

Results are analysed and reported only in aggregate. Embark does not receive individual survey responses linked to identifiable players.

4. ACCESS

Embark collects the personal data described above from two sources: (i) directly from you, through your answers to this survey; and (ii) from Embark's existing player records, reflecting your prior use of THE FINALS, as described in Section 3 above.

5. FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS PERSONAL DATA, AND FOR HOW LONG DO WE KEEP IT?

We process the personal data described above, based on your consent (Art. 6(1)(a) GDPR and similar provisions under other relevant privacy laws), in order to gather and analyze insights from our community and understand your feedback, for Embark's internal use in developing and improving our games and services.

You may at any time withdraw your consent by contacting privacy@support.embark-studios.com. Withdrawal will not affect the lawfulness of processing based on consent before the withdrawal.

We will process the personal data only for as long as necessary for the purposes set out above, and for a maximum period of one (1) year from the date of the survey.

6. WHO CAN WE SHARE PERSONAL DATA WITH?

Suppliers to Embark - In order for us to be able to fulfill our commitments, we may transfer personal data to third- party service providers, including our agency Kurppa Hosk and providers of various IT services. The suppliers to whom Embark discloses personal data will only process the personal data for the purposes mentioned in this Privacy Policy. Embark has entered into data processing agreements with its suppliers that meet the requirements of applicable data protection laws.

For the avoidance of doubt, Embark will not sell your personal data, use it to market any products not distributed by Embark or communicate with you in a manner that is contrary to your preferences as communicated by you.

Embark does not sell, and does not share for cross-context behavioral advertising, the personal information it collects through this survey, and it has not done so in the preceding twelve (12) months. Because we do not sell or share this personal information, we do not offer an opt-out mechanism for the survey data; if this changes, we will update this notice and provide the required opt-out method beforehand.

7. TRANSFERS TO THIRD COUNTRIES

In any transfer of personal data outside the EU/EEA, Embark will always observe applicable data protection laws regarding transfers to third countries. Embark will only transfer personal data to a country outside the EU/EEA provided that (i) the third country ensures an adequate level of protection of personal data under a decision issued by the EU Commission, (ii) Embark ensures that appropriate security measures are in place according to applicable data protection laws, or (iii) if any other exception exists under applicable data protection legislation.

8. RIGHTS

According to the GDPR and other data protection laws, you have the right to request:

  • Information from Embark about what personal data we collected, from what source and how we process that personal data, and in such case request access to your personal data in the form of an extract from the register.

  • Correction of incorrect or incomplete personal data.

  • Deletion of your personal data in some cases, e.g. if your personal data is no longer necessary for the purposes for which they were collected.

  • Withdraw your consent at any time where we process your personal data based on your consent.

  • Restriction of the processing of your personal data meaning that you request Embark to limit its processing of your personal data under certain circumstances.

  • Receipt and transfer of personal data to you or another controller in some cases (data portability, determined by jurisdiction).

Additional rights for California residents. If you are a California resident, the CCPA gives you the following rights, subject to certain exceptions:

  • The right to know the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties to whom we disclose it;

  • The right to delete personal information we have collected from you;

  • The right to correct inaccurate personal information we maintain about you;

  • The right to opt out of the sale or sharing of your personal information (note that we do not sell or share the personal information collected through this survey);

  • The right to limit the use and disclosure of sensitive personal information (note that we do not collect sensitive personal information through this survey); and

  • The right not to receive discriminatory or retaliatory treatment for exercising any of these rights.

You may exercise these rights by contacting us at privacy@support.embark-studios.com. We will verify your request as required by law before responding, and you may use an authorized agent to submit a request on your behalf. We will not discriminate against you for exercising any of your CCPA rights.

If you are in the EU/EEA, you also have the right to lodge complaints regarding the processing to the Swedish Authority for Privacy Protection or other competent supervisory authority within the EU. When requesting access to your personal data, please contact Embark at e-mail: privacy@support.embark-studios.com

If you are in California you have the right to lodge a complaint with the California Attorney General, see https://oag.ca.gov/contact/consumer-complaint-against-business-or-company, for more details.

Updated on 2026-08-31