Your privacy is important to VTLog and we take our responsibility of caring for it seriously. This policy describes how Virtual Truck Log. ("VTLog") processes the personal information we collect about you when you use our products and services or when you attend events hosted by or in connection with VTLog (collectively, "Services" or "VTLog Services"). In some cases, our subsidiaries may be considered data controllers, either together with VTLog or by themselves.
1. Information We Collect
The information we collect depends on what Services you use and how you use them.
A. Information You Give Us Directly
We collect information that you provide us, such as:
- Your VTLog account information, including Steam ID and username;
- Security questions and answers;
- Information you provide in response to surveys or polls about our Services;
- Information you provide when seeking help from us, such as your name, discord account information, and records (including call recordings) of the issues you experience; and
- Billing information, such as your name, payment card number, payment account details, and shipping address.
B. Information You Provide When Playing Online
When you use our social features, any text, audio, visual, and/or other electronic communications information that you disclose may be read, copied, collected, or used by other players and VTLog, and may become publicly available and/or may be processed by VTLog for the purposes described in Section 2(D): Anti-Cheat, Inappropriate Content, and Fraud Prevention Technologies.
When you play associated online games, your in-game profile information, gameplay, and statistics are collected and some may be visible in-game, as well as visible to players outside the game in other VTLog Services, such as API. In some of our titles, we may record your gameplay and make it visible to other players outside the game in other VTLog Services. Leaderboards may also be available to view by other players outside the game in other VTLog Services.
C. Other Information We Collect When You Use Our Services
We may collect other information automatically when you use our Services, such as:
- IP address;
- Information about your device, hardware, and software, such as your hardware identifiers, mobile device identifiers, platform type, settings and components, VTLog software and updates you have installed, and the presence of required plugins;
- Approximate geolocation data (derived from IP or device settings);
- Browser information, including your browser type and the language preference;
- Referring and exit pages, including pages viewed and other interactions with web content;
- Details about what Services you purchase or obtain, and your use of them;
- Device event information, including crash reports, request and referral URLs, and system activity details (e.g., whether you encountered an error playing associated games or lost Internet access); and
- Other information (such as your likeness) that you may provide as part of your participation in (live) events.
We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5), and application data caches.
D. Information Provided to Us by Third Parties
We may receive information about you contained in third-party user accounts when you use VTLog online Services on or through third-party gaming platforms, such as those listed below. This information is provided to VTLog as part of establishing or linking an VTLog Account, which is necessary to access VTLog’s online services. Your use of VTLog online Services through these third parties indicates your agreement for the transfer of this information. Examples of information we receive when creating VTLog Accounts for our recently released titles are provided below. We never receive your credit card number or other financial information from these third parties as part of establishing or linking an VTLog Account.
Social Gaming Platforms. When you use third-party social gaming platforms (such as Discord or Twitch) and link your VTLog Account, we may receive information associated with your account on those platforms. Please review the notices presented to you when linking your accounts for details on the information VTLog receives.
E. Legal Basis for Processing
Our legal basis for processing your personal information varies depending on the type of information we collect, the context in which we collect it, as well as on your country of residence, as indicated when you are setting up your VTLog Account or, when not signed into an VTLog Account, your location as determined by your IP address and/or your device registration country.
If you are a resident of the European Economic Area (EEA) or of a jurisdiction where similar legal requirements may apply such as Brazil, Switzerland, and the United Kingdom, we rely on a number of legal bases to process information about you. We will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and/or where we have a legal obligation to process your information. For example, we typically rely on:
- consent when placing cookies on your device on the web (through our cookie consent manager), to send you email marketing, or to deliver third-party targeted advertising to you on our Services;
- our legitimate interests to process your information when providing you with customer service support, to serve targeted VTLog marketing of our Services, or for fraud prevention and security purposes; and
- on contractual necessity to process information when you create an VTLog Account or otherwise use our Services to enable us to provide you with our Services.
If you are a resident in a territory where our legitimate interests mentioned above are not recognized as a lawful basis under applicable law, we will identify and use other appropriate lawful bases to process your personal information such as contractual necessity or your consent.
2. How We Collect Your Information
We and third parties use technologies described below to collect information to deliver our Services.
A. Cookies and Similar Technologies
Cookies are small text files stored on your Internet browser. We and our third-party partners use cookies and similar tracking technologies to help us understand things like what web pages, features, or ads you view and what games you play. This information helps us keep track of your shopping cart, measure the effectiveness of our advertising, make sure you don't see the same ad repeatedly, and otherwise enhance your experience. Please refer to Section 8: Your Choices and Controls for information on how to manage your cookie preferences.
We may use tracking pixels or clear GIFs to collect information about your use of our Services and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud, and enforce our User Agreement.
We also use Analytics, Advertising, Anti-Cheat, and Anti-Fraud technologies in our Services. These technologies may utilize the same cookies or similar mechanisms as further described below.
B. Analytics Technologies
We use internal and third-party analytics technologies to collect information about how you use our Services, your computer or device and the health of our Services.
For instance, we may collect and store data from your computer or device when you use our Services. This information includes technical and related information about your computer, device, and operating and/or network systems (such as IP Address and device identifiers); information about your engagement with certain features and services; gameplay and usage statistics; as well as system interactions and peripheral hardware. We may also collect and store data from your device to create probabilistic identifiers for the purposes of analyzing the services accessed by our players across devices. If you play a game offline without connecting to the Internet, this data will be stored on your device and transmitted to us when your device connects to the Internet. If you participate in online Services, we may also collect, use, store, transmit and publicly display your personal and/or statistical data regarding your game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.
C. Anti-Cheat, Inappropriate Content, and Fraud Prevention Technologies
We strive to provide a safe and fair gaming environment for all players. When you use our Services, we or third parties may use cookies and similar technologies, collect data about or from your machine or device, which may include a machine "fingerprint" or "hash" of your machine components, and gather other evidence about your gameplay, machine state, or participation in our Services for fraud prevention, security, cheat detection, and authentication purposes. We may also monitor publicly-available information, third-party sites, and/or use anti-cheat technology within our Services, including automated anti-fraud and abuse algorithms. If you believe your access to our games and/or Services was blocked by this technology in error, please contact us at VTLog Discord.
We may also monitor, record, review, and retain voice or text communications, and other user-generated Content (“UGC”, as defined in our User Agreement), in our Services for purposes of moderating inappropriate Content that violate our policies (like our Positive Play Charter). Moderation includes detecting, investigating and removing inappropriate UGC, as well as potentially sanctioning those players whose activities we find as violating our policies.
3. How We Use Your Information
We use your personal information, both individually and combined together, in the following ways.
To operate our business and to enhance and personalize your game experience, including to:
- Operate, analyze, improve, and develop our games and Services;
- Undertake research and analysis to develop and demonstrate our technology, and to better understand our players;
- Populate online leaderboards, ranking or other matchmaking;
- Help you find your friends or tell your friends about an VTLog associated game or Service;
- Facilitate sharing on social networks;
- Measure the effectiveness and distribution of advertising, including understanding who engages with our Services and how they interact with our Services;
- Measure the health of our Services;
- Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
- Set up and maintain accounts for which you register;
- Provide experiences that you may like, including personalizing your experience;
- Set up and facilitate loyalty programs;
- Identify, fix, and troubleshoot bugs or functionality errors;
- Provide software updates;
- Authenticate your game-play data, including progress;
- Facilitate competitions and contests;
- Perform audits, transactions, and other compliance activities;
- Adhere to your preferences and to deliver content;
- Help keep our Services safe and fair, including for such purposes as described in Section 2(D) and to further our Content Moderation and Enforcement;
- Resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and enforce our agreements and policies; and
- Other purposes you consent to, are notified of, or are otherwise disclosed to you when you provide personal information.
To provide you support, including to:
- Help identify and troubleshoot problems with your account or Services;
- Facilitate surveys or questionnaires;
- Communicate with you and respond to your specific requests or questions; and
- Manage and send you confirmations and important information about your account, Services, purchases, subscriptions, and warranties.
To personalize our communications with you, including to:
- Provide you with relevant VTLog content, recommendations, information or offers; and
- Provide you with Service updates.
Retention. We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.
Where possible, we may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.
4. Who May Receive Your Information
Service providers. Vendors and other service providers that help us operate our business and provide you with Services may receive your personal information. We require that any service provider processing your personal information only do so on our behalf and for purposes consistent with this policy, such as the purposes described in Section 3: How We Use Your Information.
Business partners. We may provide personal information to business partners with whom we jointly offer Services. These partners include the companies that provide the platform on which you play our games, such as Steam, or others.
Affiliates and subsidiaries. We may disclose personal information to other companies in which we have an ownership interest as necessary for the purposes outlined in this policy.
Disclosures to protect us or others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. In particular, if we receive a report that you have violated our policies (like our Positive Play Charter), we may disclose that report and other relevant information to the platform on which you play our games.
Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.
Third-party plugins. When third-party technologies or social tools are integrated into our Services, those third parties may collect information about your use of our Services. An example is the Facebook "Like" button.
In certain instances (such as on our websites), our Services incorporate YouTube videos and use YouTube API Services. This integration is subject to the YouTube Terms of Service, and may result in the collection of your personal information by Google according to the Google Privacy Policy. If you have authorized us to receive your YouTube or other Google information, such as through logging in to our Services through your Google Account, you may manage your authorization (including revocation) through the Google Security Settings. You may also have other rights with respect to your personal information that we have collected, as described in Section 8: Your Choices and Controls.
With your consent. We may disclose your information to other recipients with your express consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions, or if you tell us that you want to link your VTLog Account with another company’s services. These recipients will process the information you agree to share according to their respective privacy notices.
5. Where We Hold Your Information
When you access VTLog Services, including when available on third-party platforms, your personal information is generally collected by VTLog directly and processed in Germany. Personal information we collect may be subsequently stored and processed for the purposes set out in this Privacy and Cookie Policy in Germany or any other country in which VTLog, its subsidiaries, or third-party agents operate. By consenting to the transfer of your personal data outside of your country of residence, you acknowledge that your personal information may be transferred to recipients in Germany and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.
6. How We Protect Your Information
Security of your information is a priority at VTLog and we take a range of technical and organizational measures to help protect it, including encryption of sensitive information. Even so, please be aware that no security measure is perfect. Thus we cannot guarantee the security of your information at all times. You should always be diligent when it comes to the protection of your personal information.
7. Children
Although the majority of VTLog Services are intended for adults, VTLog recognizes the importance of protecting the privacy of children who may access our Services online. We strive to ensure that children who access our Services receive age-appropriate experiences by employing data minimization, privacy by design, and default practices. We consider the best interests of children when determining the age-appropriate experience they receive and take into account the developmental maturity of children of different ages. When children reach the age of majority in their country or territory, they may receive the adult experience.
When players identify themselves as being children under the minimum age of digital consent guidelines set by the law of individual countries or territories, we will:
(1) obtain consent from parents for the use of their children's personal information, when required by applicable law. For example, we allow parents to create a child VTLog Account on certain Services, and with parental consent VTLog will collect and use certain children’s personal information to manage a child VTLog Account;
(2) disable features in certain Services that could allow a child to share information that directly identifies them, unless a parent has provided relevant consent to us or the third-party platform on which their child is playing. For example, we will respect third-party (console) parental controls as they apply to game features that could allow a child to provide personal information in online or multiplayer games (such as through chat or user generated content);
(3) collect and use certain information for limited purposes only. For example, we may send local in-app notifications, which do not rely on collecting personal information. Also, persistent device identifiers like IP address or advertising device identifier may be collected to support our internal operations, such as:
- Delivering the Services;
- Maintaining or analyzing the functionality of the Service;
- Serving contextual ads or frequency capping;
- Protecting the security or integrity of the user of Service; or
- Legal or regulatory compliance;
(4) not condition a child's participation in an activity (such as gaming contests) on the disclosure of more personal information than is reasonably necessary to participate in the activity. With certain Service-related activities, we may not permit children to participate at all, even if we have consent; and
(5) offer parental controls and choices. If you are a parent or guardian and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, please contact us via the options in Section 12: Contact Us. If we become aware that a child has provided us with personal information without parental consent, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child's account and/or revert them to the age-appropriate experience, as applicable.
If we make material changes to how we collect, use, share or otherwise process your child's personal information, we will notify parents as required by applicable law.
We encourage you to talk with your children about communicating with strangers and the risks of disclosing personal information online. You and your child should review the privacy settings applicable to their use of our Services.
8. Your Choices and Controls
We give you meaningful choices when it comes to our collection and use of your information.
Your right to deletion. You may deactivate your VTLog Account or delete the personal information associated with your account by contacting us at VTLog Help. If you do so, you will no longer have access to the VTLog Services associated with your account. Note that VTLog may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you with, create, and improve our Services, and to comply with the law.
Your right to access (or "know"). You can access the personal information we hold about you, including the categories of personal information collected, where we collect it from, why and how we use it, and who may receive this information (including to whom it may be sold or shared, as those terms are defined under applicable law). The generally applicable details about our processing are provided in this Policy.
Your right to correction. You can request correction of your personal information where it is inaccurate. In some cases, we may provide self-service tools, such as those on the VTLog Account profile settings, that enable you to update some of your personal information.
Your right to opt-out or object to certain processing. You may opt-out of targeted advertising, or object to processing of your data based on our legitimate interests, where applicable law provides for such rights.
Cookie Controls. If you are in a location whose laws may require additional choices, you can control cookies and similar technologies used on most VTLog sites for certain optional functional and advertising analytics and targeted advertising purposes via the banner that appears at the bottom of the webpage during your first visit. You can also disable some cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you'd like help in managing your cookie preferences.
Global Privacy Control. In certain regions, we recognize an opt-out preference signal sent by your web browser (sometimes referred to as the Global Privacy Control or "GPC") as a valid request to opt-out of the sale and sharing of the personal information processed via the browser you are using. In practice this controls whether your browser loads third-party cookies on our Services' websites that are used for targeted advertising, or may otherwise be considered a "sale" of personal information. We process this signal only based on browser settings, so you would need to set them separately for different browsers on the same device and across devices.
You have a right not to receive discriminatory treatment for the exercise of these privacy rights.
9. Third-Party Services
Our websites and Services may contain advertising or links to third-party services (such as the Facebook "Like" button or links to third-party websites). If you click on those links, including an advertisement, you will leave the VTLog Service and go to the third-party service or site that you selected. If you visit a third-party website or use a third-party service, you should consult that service's or site's privacy policy as your use of third-party sites or services is governed by their privacy policies.
10. Changes to Our Policy
We may occasionally update this privacy policy. When we do, we will revise the "last updated" date at the bottom of the policy. If there are material changes to this policy, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.
11. Contact Us
If you have questions about this policy, please use our VTLog Discord to contact VTLog Management.
If you have a concern about how we collect and use information, please contact us.