Privacy Policy for early access subscribers

Last updated Oct 22, 2021

This Privacy Policy (hereinafter “Policy”) is applicable to individuals who have expressed their interest into being an early access player. The purpose of this Policy is to inform you about how we collect and use your personal data in accordance with EU General Data Protection Regulation.

Data controller

The data controller in accordance with EU General Data Protection Regulation is Return Entertainment Oy (hereinafter “we”, “us” or “our”).

Contact details of the data controller:

Return Entertainment Oy
Business ID: 3088344-9
Address: Lapinlahdenkatu 16, 00180 Helsinki
Contact email for privacy matters:

2. Personal data

The following type of personal data is collected about you:

  • Email address (as provided by you); and
  • Name, country, workplace (if applicable), gamer type, favorite game, preferred platform, age group (asked by the person inviting you to the early access)

3. Purpose and legal basis

We will use your email address to send you a link to our game when early access is available and to provide you more information about our game. This collection and use of your personal data is based on your consent (GDPR Article 6 (1) (a)). You have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

We do not disclose your personal data to third parties, except when required by law, for instance to comply with requests by competent authorities or related to legal proceedings. In such case, the processing will be based on legal obligation.

In addition, we may use third party service providers for the purpose of analytics. These service providers work on behalf of us and under our instructions. We will control and be responsible for the use of your personal data at all times.

4. Transfer of personal data

We process your personal data within European Economic Area (EEA). However, some of our service providers process personal data outside the EEA and may process your personal data outside the EEA. Therefore, to ensure that your personal data receive an adequate level of protection we have ascertained that sufficient safety measures have been implemented to allow for the transfer outside the EEA, including specific contracts approved by the European Commission (Standard Contractual Clauses).

5. Retention

We will keep your personal data during early access phase. We may periodically delete or de-identify unnecessary data.

6. Your privacy rights

Under certain circumstances, you have the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party (also known as data portability). Where our processing is solely based on your consent you have the right to with-draw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. I

f you think there is a problem with the way we are handling your personal data, you also have a right to file in a complaint to your national data protection authority in the EU. In Finland you can lodge a complaint with the Office of the Data Protection Ombudsman at The list of all data protection authorities in the EU can be found at

If you wish to exercise any of the privacy rights that are available to you then please send your request to us by email at

7 .Security

We maintain reasonable security measures (including physical, electronic, and administrative) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, we limit access to personal data to authorized employees and contractors who need to know the information in the course of their work tasks.

8. Changes to this Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will let you know it on our website at, where you will also find the latest version of this Policy.

9. Contact us

If you have any questions regarding this Policy or the personal data we process about you, please contact us at