Privacy Policy

This Privacy Policy was last updated on January 11, 2024.

Welcome to the home of Frost Giant Studios!   We’re on a mission to bring you the best in real time strategy games.

This privacy policy (“Privacy Policy”) describes how Frost Giant Studios. Inc. and our affiliates (referred to as “Frost Giant” “we”, “us” or “our”) handle personal information that we collect through our digital properties that link to this Privacy Policy such as our websites, video games, marketing activities or live events (“Sites”). We also refer to “Frost Giant Services,” or “Services” by which we mean any Frost Giant game, website, application, or service that links to this policy, regardless of how you access or use it.

Data Controller’s Details. For purposes of the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), Frost Giant is the “Data Controller” of your information collected in connection with the Sites and Services.

Frost Giant Studios. Inc.
150 Progress, Suite #150, Irvine, CA 92618
Attn. Department of Legal & Business Affairs.
Email: legal@frostgiant.com

Contact Details of the Data Protection Officer (DPO). For questions regarding this Privacy Policy, our data practices, or our compliance with applicable laws, please contact our Data Protection Officer as follows:

Frost Giant Data Protection Officer
Frost Giant Studios. Inc.
150 Progress, Suite #150, Irvine, CA 92618
Attn. Department of Legal & Business Affairs.
Email: legal@frostgiant.com

Please read this entire policy to make sure you understand it. You should also read our End User License Agreement (“EULA”) carefully, and make sure you understand and agree to its terms before using Frost Giant Services.

By using the Sites and Services, you acknowledge that you have read and understand this Privacy Policy and accept our collection and use of your personal information as described below.

1. INFORMATION WE COLLECT
2. HOW WE USE YOUR INFORMATION
3. INFORMATION WE SHARE WITH THIRD PARTIES
4. HOW WE COLLECT THIS INFORMATION 
5. HOW WE STORE AND PROTECT YOUR DATA
6. CONTENT SUBMISSION POLICY
7. CHILDREN’S PRIVACY
8. YOUR PRIVACY RIGHTS, CHOICES AND ACCESS
9. CHANGES TO OUR PRIVACY POLICY
10. CONTACT INFORMATION
11. LANGUAGES

1. INFORMATION WE COLLECT

This section describes the information we collect, including information that you provide to us, information automatically collected and information from third parties. We may combine information that we collect via one method (e.g., a website, our digital advertising) with information that we have collected via another method (e.g., an offline event). We do this to get a more complete view of our consumers, which, in turn, allows us to serve you better and with more customization.

The type of information we collect depends on the Sites and Services you use and how you use them.  The type of personal information we collect includes:

• Your contact information/identifiers, such as your name, your gamer id, mailing address, email address, employer, primary language, country, social media credentials. preferred games and date of birth. If you contact us by telephone, we will also retain your telephone number.
• Your account registration information, such as your username, password, and other details that help us secure and provide access to the Frost Giant Sites or Services (such as when you login to our games or websites).
• Your payment details, such as your name, billing address, telephone number, payment method, and other data we collect to help process purchases you make.
• Your customer support-related details, including the nature of your inquiries, your account ID or your order details.
• Your feedback, including communication between you and Frost Giant such as emails in response to your feedback, inquiries, or responses to our online surveys.
• Your contest participation information, such as when you submit an entry, prove eligibility, or claim a prize for a contest for promotion.
• Your geolocation data, if your device settings allow us to collect such information.
• Your account preference information, such as your contact, communication and marketing preferences.
• Your job application materials if submitted them to Frost Giant as a part of an application for employment, including your CV, professional portfolio, references and other details pertaining to your education and employment.
• Your device and browsing information, including non-personally identifiable information about your phone, tablet, computer or device and online browsing activity, which may be automatically collected.  This may include IP addresses, unique identifiers, cookie identifiers, browser language, device and browser settings and broad location-based information, and internet service provider information.  It may also include information about when and how you accessed and used our Sites, how you navigated to our Sites (such as the date and time of your visit), the links you clicked, the websites you visited before and after our Sites, and what you searched for while on our Sites.
• If you play our games (including alpha and beta playtesting), data around your gameplay, such as crash information and disconnects, your IP address, your hardware information, gameplay stats, the version of our game you played, in-game timestamps, clicks, scrolling, browsing times, browsing heatmaps, searches, referral/exit pages, and how you interacted with other players.
• Your use of Frost Giant in-game social features like voice and text chat where the information you share may be collected and used by us to ensure compliance with our EULA or viewed, collected or used by others via screenshot, audio recording, video recording or livestream.
• Your player information, which may also be publicly viewable to others, including your gamer name, player profile, team profile, team position, game statistics, MMR, match history, ranking in various activities and performance.  
• If you participate in one of our esports competitions, we may publish additional personal profile information on our ranking, bracket and tournament standings pages,  ladders,  leaderboards, Sites and Discord servers.  For example, in addition to the player information listed above, we may include your geographic location (state, province, country)  prize pool earnings, ranking, gameplay stats, and replay files.
• If you enroll in an in-game competition with additional eligibility requirements (such as a corporate, collegiate competition or league), we may request additional pieces of personal information to verify your eligibility, such as your enrollment status in a particular academic institution or your employment by a particular company.
• Your gameplay and other related information (such as your in-game name, build order, replay files, game stats, and in-game actions), which may be recorded by us and replayed or made otherwise available to other players without further notice to you. For example, your gameplay may be viewable via spectator mode or recorded as footage or replay files that we make available to promote the Services. We may make use of your gameplay data and reports from other players to uncover patterns of abusive or inappropriate behavior which do not comport with our EULA.

Analytics & Interest-Based Ads. We partner with third parties (like sponsors, content providers, and analytics companies) to help us improve our Services and better understand how you interact with them, as well as to support our marketing initiatives and ad campaigns. These companies may collect info from you automatically in connection with your visit.

Fraud and violations detection. We may also collect certain data (like IP address, username, geolocation, etc.) that is required for our detection, investigation and prevention of cheating in the Services EULA violations. This data, being used only for the purposes of detection, investigation and prevention of frauds and cheating in the Services are deleted twelve months after their collection, unless the data can be used to prove that cheating has occurred. If the data can be used to prove that cheating or another fraud, EULA violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations. Please note that the specific data stored for this purpose may not be disclosed to you or any third parties, since the disclosure will compromise the mechanism through which we detect, investigate and prevent frauds and cheating in the Services, as well as other EULA violations.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

2. HOW WE USE YOUR INFORMATION

We use personal information to operate, maintain, and provide the features and functionality of our Sites and Services, including:

• To provide you with information about game updates, launches, new products, rewards programs, events, press releases or features you may find of interest;
• To notify you of updates to features on our Sites and Services;
• To provide you with customer service support;
• To notify you when we make changes to our agreements, Sites or Services;
• To provide you with technical and security notices;
• To build business-to-business relationships;
• To monitor if our Sites and Services are running optimally in order to offer you the best user experience;
• To contact you about your job application, to verify details contained in your job application, to improve our application process, and to comply with legal and regulatory obligations;
• To help us design, balance and generally improve our Services and to debug gameplay;
• To track your participation and performance in competitions and esports around the game as well as ladders and leaderboards in game;

• To protect our users and business; to ensure your safety and security including identifying or enforcing against fraud and breach of our Terms of Service, and other inappropriate behaviors;

• To comply with our legal obligations, including requests to us by law enforcement;
• For any other purposes disclosed at the time we collect the information or pursuant to your consent.

Additionally, but only with your consent, Frost Giant may send you text messages and push notifications in conjunction with the above Sites and Services.  Frost Giant may also contact you by telephone if you ask us to provide you with support.

You may update your contact preferences by emailing us at legal@frostgiant.com at any time.

3. INFORMATION WE SHARE WITH THIRD PARTIES

Frost Giant will not rent, sell or share your personal information to third parties for marketing or advertising purposes without first obtaining your consent.  We will only pass on your personal information to third parties to the extent described below.

We may share your information with third parties in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. For example, we may use and share aggregated or anonymized data to describe the users of our services in press releases or marketing materials.  We may also share aggregated and anonymized information about our user base with current or prospective investors.

If you have applied for a position with us, we may share information from your job application with third parties for the purpose of verifying the information you have provided, conducting reference and background checks, working with immigration attorneys or setting up travel.  When such third parties collect or receive your personal information, we will instruct them to only use the data for the performance of the designated task for which they were hired.

If you participate in one of our esports competitions, we may share via API personal profile information such as your gamer name, team name, team position, location (country, state, province), ranking in various activities, prize pool earnings, match history, MMR or other gameplay stat and your replay files so that 3^rd parties can build game stat histories, analytics and tools around the Game.

Third party service providers. From time to time, Frost Giant may need to transmit your personal data to vendors or service providers that enable us to market, sell, or deliver our services.  These service providers may require certain personal information in order to perform specific services on our behalf, such as cloud service and data storage, beta testing, tech support to enhance game operations, chat, customer support, social login, fulfillment and shipping, email and newsletter delivery, conducting surveys, payment processing, tournament operation, anti-cheat and fraud prevention, web hosting or web analytics.  Such partners include: 

• Steam
• Epic Online Services
• Xsolla
• RallyCry
• Hathora
• Brevo
• Eventbrite
• AWS
• Sentry.io 
• Google
• Easy Anti-Cheat 

We authorize such service providers to use or disclose your personal information only as necessary to perform the relevant services on our behalf or to comply with legal obligations. We require our service providers to contractually commit to protecting the security and confidentiality of the personal information they process on our behalf and not use your data for anything other than to provide services on our behalf.

Legal Disclosure. We may transfer and disclose information to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Sites, users of our Services or the public.

Links to other websites. Our Sites and Services may contain links to other websites that are not owned or controlled by Frost Giant. These links are provided for your convenience but do not imply any Frost Giant endorsement of such websites or their content. We have no control over, do not review, and are not responsible for the privacy policies of or content displayed on any such linked websites.  Please review the privacy policies of any third party website you are directed to for their data collection and use practices.

4. HOW WE COLLECT THIS INFORMATION 

We collect information that you provide to us directly.  We may also receive information from third parties such as Steam, Epic, and Google, when you use such third parties to log into our systems.  If you choose to link your account with such a third party platform to the Sites or Services, you will provide us or allow such third party to provide us with your user name and public profile. To manage the data we receive about you from third party platforms, you will need to follow the instructions of the platform for updating your data and changing your privacy settings. Once we receive your data from a third party platform, that data is stored and used by us in accordance with this Privacy Policy. In addition, we may gather certain information automatically using tracking technologies like cookies, beacons, tags, and scripts.

Cookies (Cookie Policy)

To enhance your user experience on our Sites, some of our web pages use “cookies.”

Cookies are small text files which are placed in your computer’s browser and which store your preferences. Cookies, by themselves, do not reveal your e-mail address or other personally identifiable information unless you choose to provide this information by, for example, registering on our Sites. However, once you choose to furnish our Sites with personally identifiable information, this information may be linked to the data stored in the cookie.

Frost Giant uses cookies to understand site usage, improve security, save your user login details, provide better tech support, and to improve your user experience and offerings on our Sites.

Frost Giant may use tracking technologies to collect information about your use of our Sites or services including:

• Javascript
• Cookies
• Web beacons
• File information
• Local shared objects, and other similar tools (sometimes also referred to as “Adobe Flash cookies”) which are downloaded to a computer or mobile device by the Adobe Flash media player.

Frost Giant may also use reputable third party analytics services such as Google Analytics which place and read their own cookies, web beacons, and similar technologies to collect information through our Sites, including to help us with traffic measurement, research, and analytics.

You can learn more about Google’s privacy policies at http://www.google.com/policies/privacy/partners, and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

How do you turn off cookies?

You can change your preferences and refuse to allow certain types of cookies to be stored on your computer while browsing our Sites. You can also remove any cookies already stored on your computer, but keep in mind that deleting cookies may prevent you from using parts of our Sites or services.

Please note that we are not able to respond to Do Not Track signals from your browser at this time.

If you have further questions or concerns about our cookie use, please contact us at legal@frostgiant.com.

5. HOW WE STORE AND PROTECT YOUR DATA

Frost Giant is committed to protecting the personal information of its users.

At Frost Giant, we operate our Services around the world. Frost Giant stores the personal information we collect in the United States and other countries where our third party agents operate.  By using our Services and/or providing us your data, you agree that the information you provide to us may be transferred from your location / your country of residence to the United States or to the country of one of our agents. We maintain such personal information on our secure servers, for as long as is necessary for the purpose(s) for which we originally collected it. We may also retain personal information as required by law.

Although no data protection system is infallible, Frost Giant has adopted reasonable technical, administrative, and physical procedures to help protect this information from loss, misuse, and alteration, including encryption as appropriate.

How long do we keep your data?

We retain your data for as long as it is necessary to provide you with the Services so that we can fulfil our contractual obligations and rights in relation to the data involved. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

At the expiry of the applicable data retention periods, we will take steps to have your personal information deleted, aggregated or made anonymous, unless further retention is required by applicable laws. We may be required to keep your information for as long as necessary (i) to comply with our legal and regulatory obligations,(ii)  to make or defend legal claims, (iii) to protect against the fraudulent activity of others, (iv) to enforce our Terms of Service, EULA, and this Privacy Policy, (v) to administer our Site and Services and keep them safe and secure, and for internal operations (including, but not limited to, research, statistics, troubleshooting, data analysis, testing, esports operations, rankings, surveys and similar purposes); and (vi) to disclose as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to protect our operations or those of any of our affiliated parties; (c) to protect our rights, privacy, safety or property, or that of our affiliated parties, users  or others; and/or (d) to allow us to pursue available remedies or limit the damages that we may sustain.

6. CONTENT SUBMISSION POLICY

In some cases, you may be permitted to upload your own user material to the Services, for example, your profile picture. Your user material that is uploaded to the Services may be shared, or posted to the public Services, and accordingly, by uploading user material, you waive any and all expectations of privacy with respect to your user material and communication (including without limitation chat text) on the Services.  You will have no expectation of privacy in your in-game communications (including private groups and chats) and content. Frost Giant has no obligation of confidentiality, express or implied, with respect to content that you post to or through the Services, and Frost Giant shall be entitled to use, exploit, or disclose (or choose not to use, exploit, or disclose) such content at our sole and absolute discretion without any obligation to you whatsoever (i.e., you will not be entitled to any compensation or reimbursement of any kind from us under any circumstances whatsoever).

7. CHILDREN’S PRIVACY

Frost Giant is not a service directed at children under the age of 13 and does not knowingly collect personal information from users under the age of 13.  If we become aware that we have unknowingly collected personal information from a child under 13 years of age, we will delete such information from our databases.  If you believe that Frost Giant might have any information from or about an individual under 13, please contact us at legal@frostgiant.com.

8. YOUR PRIVACY RIGHTS, CHOICES AND ACCESS

Subject to certain limitations, you have the following rights with respect to the personal information we collect about you:

1. Right to Know and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

1. Right to Delete. Subject to certain limitations, you may ask us to update or delete/deactivate certain information pertaining to you. You may also request removal of your personal information from our blog, community forums or other public areas of the Sites that are under our control.   If we cannot remove your personal information, we will give you a reason why we cannot. For account security and for the protection of your personal information, you or your authorized agent may be asked to verify your/their identity and/or account ownership.  Note that some personal data may be retained as permitted by law (e.g. to comply with legal obligations, to prevent fraud, etc.).

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

1. Right to Correct. You may also ask us to correct inaccurate personal information that we have about you.
2. Right to Opt Out of Targeted Advertising or Sale. We will provide you with the opportunity to “opt-out” of having your personal information used for certain purposes whenever we ask for this information. For example, if you no longer wish to receive marketing emails or newsletters from us, you may stop delivery by following the unsubscribe instructions contained at the bottom of the email you received or by emailing us at unsubscribe@frostgiant.com. Note that deleting certain account data may affect game play and/or your use of our Services.  Please see more information on how to use your rights to opt-out in section Advertising/Targeted Advertising; How To Opt-Out
3. Right Against Discrimination. We will not discriminate against you for exercising your rights.
4. Right to Limit Use of Sensitive Information. In some circumstances you may ask to stop or otherwise limit the use of your sensitive information. We do not use or disclose your sensitive data or sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer, to facilitate your voluntary participation in esports competitions, for security and legal reasons, with your consent, and/or for other purposes permitted by applicable law.
5. Right to Appeal. This right provides you with the opportunity to appeal a decision made by us in connection with a rights request.

Response Timing and Format. If you have questions or comments about our Privacy Policy or would like to make a request regarding your data, exercise your right to know, delete, or correct your personal information, you or your authorized agent may contact us through the following methods:

• By completing this form (preferred)
• By emailing us at legal@frostgiant.com
• By writing to us at: Frost Giant Studios, Inc. 150 Progress, Suite 150, Irvine, CA. 92618, Attn: Frost Giant Data Protection Officer

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at legal@frostgiant.com.  We endeavor to substantively respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to another 30 days), we will inform you of the reason and extension period in writing.

We may ask you for additional information to help us verify your identity, including by asking you to confirm other personal information you have provided to us. We may deny your request for reasons permitted by law, including our inability to verify your identity.  If we deny your request, we will tell you why we did so.

Subject to certain restrictions, you may have an agent exercise your rights for you. If you have an agent exercising your rights, that person must provide to us your written authorization allowing them to make such a request on your behalf.  We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper authorization and/or verify your identity as the requestor.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Disclosure in the event of a merger, sale, or other asset transfer. Frost Giant may sell or transfer all or part of our business or assets in the event we are involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, or diligence associated with such matters.   In such a case, you will be notified in advance via email or via a notice on our Sites of the change in ownership or a change in the use of your personal data, as well as any choices you may have regarding your personal data.

Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

Other than as specified elsewhere in this Privacy Policy, Frost Giant does not sell, rent or share your personal information with third parties.  California residents who have specific questions regarding this may contact us at legal@frostgiant.com.  In the body of your request, please include: “California Shine the Light Request”, your name, a current California address including, street address, city, state, and zip code, as well as sufficient information for us to determine if the law applies to you.

For users residing in Colorado, Connecticut, Utah and Virginia, in addition to the rights that are available to residents of California, if you are a resident of one of these states, you may also have the right to:

• Opt out of the processing of your personal data for the purposes of targeted advertising and for profiling in furtherance of decisions, including, for residents of Connecticut, solely automated decisions, that produce legal or similarly significant effects; and
• Appeal any decision or indecision related to the exercise of any right the consumer is granted under the applicable state law.

To make such a request, please send an email to legal@frostgiant.com.

If you are a resident of Nevada, you also have the right to request that a company not sell your personal data for monetary consideration to certain other parties. This right applies even if your personal data is not currently being sold.

If you would like to exercise any of your rights under applicable law (including the right to appeal), please email legal@frostgiant.com.

Your Rights as an International User. The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction of residence.

If you are located in certain other jurisdictions outside the United States, you may have additional data subject rights. These rights vary but they may include the right to: (i) request access to and rectification or erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) the right to data portability. You may also have the right to lodge a complaint about the processing of your personal data with a data protection authority.

You may do so by emailing us at legal@frostgiant.com.

If you are a resident of another jurisdiction, our legal basis for processing your information is typically consent to this Policy and/or any specific consent for processing your information that you have provided.

9. CHANGES TO OUR PRIVACY POLICY

Frost Giant may revise this Privacy Policy to reflect changes in the law, our practices, our Sites or our service features. When we do so, we will notify you by changing the date at the top of the policy.  We will also notify you by email before we make any material changes to the policy, give you the opportunity to review the revised policy and opt out of our services.

If you object to any of these changes, you may opt out by notifying us at legal@frostgiant.com.   You may also opt back in at any time by emailing us at the same address.

Non-material changes will be effective immediately upon posting, however Frost Giant will always update the effective date of such changes at the top of this Privacy Policy. Please periodically review this Privacy Policy so that you are abreast of our most current policies and practices.

10. CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Website: https://frostgiant.com/

Email: legal@frostgiant.com

Postal Address:  Frost Giant Studios, Inc. 150 Progress, Suite 150, Irvine, CA. 92618, Attn: Frost Giant Data Protection Officer

If you need to access to this Privacy Policy in an alternative format due to having a disability, please contact legal@frostgiant.com.

11. LANGUAGES

In the event of any conflict or inconsistency between this policy in the English and any translation thereof in any other language, the English version shall prevail.