Breachers Privacy Policy

Last update: 28/02/2024

1.    ABOUT THIS PRIVACY POLICY

1.1    Introduction

When you visit the Breachers website (“Breachers Website”) or when you make use of the Breachers products, software, virtual/augmented reality application or mobile application (“Breachers Products”), Triangle Factory bv (“Triangle Factory”, “we”), who is the owner of this Breachers Website and the developer of the Breachers Products, collects, stores, and uses your personal information. This privacy policy sets out which personal information we collect from you, for which purposes, how we use your personal information and what measures we take to protect it.

Triangle Factory is committed to protecting your privacy and personal data and would like to be as transparent as possible in explaining how it processes your personal information. Therefore, we have tried to keep this policy as simple as possible, and we advise you to take the time to read it thoroughly. We will not process your personal data beyond what is set out in this privacy policy.

1.2    Who does this privacy policy apply to?

This privacy policy applies to every user of the Breachers Website and the Breachers Products (“you”, “data subject”). This privacy policy only applies to our Breachers and Breachers Universe related products and services and not to the other products, websites and services offered by Triangle Factory. If you would like to receive more information on how Triangle Factory manages your personal data when you use our other products, websites and services, please visit http://privacy.triangle-factory.be.

1.3    Who is responsible for personal data processed in accordance with this privacy policy?

Triangle Factory bv, a private limited liability company headquartered at Dublinstraat 35/007, 9000 Ghent, Belgium and registered under company number BE0822.717.673 is the controller of the personal data that is collected and processed when making use of the Breachers Website and Breachers Products. If you have any questions or concerns about this privacy policy, please contact us by making use of the aforementioned address or send us an e-mail via the following e-mail address:  privacy@triangle-factory.be.

1.4    Updates to this privacy policy

Triangle Factory can revise this privacy policy at any time, for example, in the context of changes to our Breachers Website or Breachers Products, regulatory updates or feedback from our users. The adapted conditions apply from the moment they are published on this page, so we advise you to regularly visit this page for the latest information on our privacy practices. If any significant changes are made to this privacy policy, we will notify you personally when possible, and if the processing of personal data is based on your consent, request your permission.

2.    WHICH PERSONAL DATA DO WE COLLECT?

When you use the Breachers Website or the Breachers Products, we collect the following personal information from you:

  • Identification, contact and location information such as your name, e-mail address, address, user name, avatar and user ID;
  • Information about your professional qualifications and/or academic background (should you contact us with an application for employment);
  • Information about physical characteristics, movement and certain biometric data, including voice and audio recordings;
  • Information about how you interact with our Breachers Website and Breachers Products such as information regarding the length and frequency of use, crash reports, popular items and features and your achievements; and
  • Information associated with the device you use when making use of the Breachers Website or Breachers Products such as IP address, brand, type, operating system, hardware information and screen resolution.

3.    HOW DO WE COLLECT YOUR PERSONAL DATA?

3.1    You provide us with your personal data by submitting a contact form, registering, creating an account, a profile or an avatar

When you make use of our Breachers Website or Breachers Products, it is possible that you create an account, profile, or avatar. You can also contact us by e-mail or through our contact form on the Breachers Website. When you choose to do so, we may sometimes ask you to provide certain personal data, such as your e-mail address, name, date of birth, sex and/or postal code. After registration, we can also request additional information that can help us provide more customized services.

3.2    We receive your personal data from third parties

If you log into the Breachers Products using a social media account or make use of the social networking functions present in the game, you grant permission for the social networking website to share certain, clearly identified personal data with us. Usually, this includes the basic data associated with your profile on the social networking website (name, e-mail address, date of birth, postal code, and sex). Furthermore, it can also include certain data related to your behaviour on the social networking website, such as likes, for example. This can only include personal data that you have shared publicly on the social networking website, and only to the extent to which your personal settings on the social networking website allow. If you do not wish such information to be shared, we advise you to adjust your settings on the relevant social networking website.

Furthermore, we also receive information from other reliable sources, including both online and offline data providers. Triangle Factory shall only do so insofar as this data was collected by the third party legally and insofar as it can be shared with us legally. If necessary, Triangle Factory will also request your explicit permission to use this data.

Further, in order to analyse the Breachers Website and Breachers Products and improve our products, we make use of analytics tools and third parties, who help us get a better understanding of the use of our Breachers Website and Breachers Products. These third parties may collect information, for example by using applications that you have installed, mobile websites you have visited.

Lastly, when you are making use of our Breachers Products via a platform provider such as Oculus, Steam, Viveport…, these platform providers share certain personal data about you and your activities on the platform with us. We advise you to review the privacy policies of these platform providers to get a better insight in which information these platforms collect and share with their partners.

3.3    Personal data is collected automatically when making use of the Breachers Website and Breachers Products

Regardless of whether you register, create an account, a profile or an avatar, we collect user information when you make use of the Breachers Website and Breachers Products. This may include, but is not limited to, information regarding the length and frequency of use, crash reports, popular items and features, your achievements, biometric data, data about movements, voice recordings… We use this information to improve the performance of our Breachers Website and Breachers Products, adapt it based on your requirements and interests, and better understand how our products are being used.

3.4    Other sources

Our Breachers Website and Breachers Products are dynamic and innovative operating tools, which means that we are constantly looking for ways to serve you better and meet your personal needs. This can also mean that new applications are added that cause us to collect and process your data differently. We will always communicate about this as transparently as possible in this privacy policy.

4.    WHY DO WE COLLECT YOUR PERSONAL DATA?

We collect personal data in order to offer and improve our products and to provide better services to our users. More in particular, we collect and process personal data for the following purposes:

4.1    To make the Breachers Website and Breachers Products available to you

We use your personal data for the provision and maintenance of our services. For example, when making use of our Breachers Products, we use the user name you have provided to keep your scores and identify you amongst other users. We also use your personal data to notify you when there are changes to or planned maintenance of our Breachers Website and Breachers Products or to process your feedback. Your personal data is likewise processed to receive and answer any queries you may have about the Breachers Website and Breachers Products.

4.2    To recognize you as a user

When you use a profile or account to log in to our services, we apply technology that recognizes you as a registered user and immediately grants access to the relevant service. This means that you don’t need to provide your log-in information every time you visit the relevant Breachers online service(s) or wish to take part in interactive features of our services, like contests, for example.

4.3    To enhance the community experience

We also collect and share your user name, user ID, avatar and performance metrics with community members wishing to keep track and/or to publish scoreboards in respect of the Breachers Products. This collection and sharing is intended to foster a sense of community and friendly competition among players.

4.4    To analyse and improve the Breachers Website and Breachers Products

We use personal data to understand which Breachers Website or Breachers Products features and items are most popular among our users. To understand the preferences of our users better, we may also invite you to take part in a survey. We do this to continually improve our Breachers Website and Breachers Products and develop new products and services, to make our offer as suitable as possible for our users.

4.5    To personalize the Breachers Website and Breachers Products to you

Triangle Factory strives to make its Breachers Website and Breachers Products as relevant as possible for every user. By using personal data that indicates what a user is likely interested in, Triangle Factory can work towards the provision of more personalized services. That way, Triangle Factory could, for example, recommend content that matches your profile.

4.6    To stay apprised of new products and services

Triangle Factory can use your contact details and other data collected to inform you of news, upcoming activities or events, promotions, new services, and so forth. We will only do this if you have granted permission for us to do so. You can opt out of this type of communication at any time. To do so, you can use the “unsubscribe” link that you see at the bottom of all of our electronic communications.

4.7    To prevent and detect abuse or fraud

We can also use personal data to prevent, detect and investigate illegal or suspected illegal activity, such as fraud (for example, with payment methods), and adherence to our Terms of Use , in the interests of both Triangle Factory and our users.

5.    ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

5.1    Necessary for the conclusion and performance of a contract with you

Some of the personal data that we collect (e.g. platform account, username, unique identifier) are necessary to be able to make use of the Breachers Products. We process the personal data that fall within this category in order to perform the agreement we have with you.

5.2    Based on our legitimate interests of those of third parties

Sometimes, we process your personal data based on our legitimate interests, for example, our legitimate interests in ensuring the integrity, safety and functionality of our Breachers Website and Breachers Products. The legitimate interests that we pursue include also those of third parties, such as platform providers, in order for these platform providers to receive information on the behaviour of users on their platforms. If we process your personal data based on our legitimate interests of those of a third party, we have made sure that your fundamental rights and freedoms are not compromised by pursuing these legitimate interests, in particular, when you are a minor. Note that we also collect and share your user name, user ID, avatar and performance metrics with community members on the basis of our legitimate interest in building a dynamic Breachers community. You can always object to the personal data we process on the basis of our legitimate interests or those of a third party by contacting us as set out in Section 11.

5.3    Based on a legal obligation

We also process personal data if the law requires us to do so, for example, to detect fraud or illegal activity.

5.4    Based on your consent

We ask your consent before placing cookies that are not strictly necessary for the functioning of the Breachers Website (e.g. for analytics or third-party cookies). We also ask your consent in order to send you promotional updates about the Breachers Products or for Breachers Products functions that interact with your device. Whenever the processing of your personal data is based on your consent, you may opt out at any time.

6.    WHO ARE THE RECIPIENTS OF MY PERSONAL DATA?

Triangle Factory shares your personal data with its partners, financial and other advisors and service providers in order to provide and optimize the Breachers Website and Breachers Products. We will never sell your personal data  or share your personal data with third parties if we have no legal grounds to do so. In particular, we share your personal data with the following categories of recipients:

6.1    Triangle Factory suppliers

In order to offer you the Breachers Website and Breachers Products, we call on a number of independent companies and service providers. Such third parties aid us, for example, in securing our infrastructure and IT services, carrying out payment transactions through our services, conducting surveys… It is possible that such suppliers gain access to your personal data in the context of their work for Triangle Factory. Triangle Factory only allows this to extent that access is necessary for carrying out the work that such suppliers perform for Triangle Factory and only insofar as the suppliers provide the necessary assurances regarding access and potential use of your personal data and information.

6.2    Social media networks

Certain Triangle Factory online services integrate social media “buttons” that interact with social media networking websites such as Facebook, Twitter, Instagram… These buttons allow you to share information about your achievements on these platforms. The buttons are provided and managed by the social media websites. If you wish to receive more information on how your personal data is shared when making use of such button, we advise you to read the privacy policies of the relevant social media network.

6.3    Authorities

In certain circumstances, we will be required to share your data with the authorities. We may, for example, do so in order to satisfy the law or a court order, to detect and address fraud, or to protect Triangle Factory’s rights.

6.4    Other users

When you are making use of the Breachers Products, certain personal data, such as your user name, will be visible to the other users playing in the game server (up to 10 players).

6.5    Community members requesting access to scoreboards

As set out above, we share your user name, user ID avatar and performance metrics with interested community members wishing to keep track of and/or publish about Breachers’ scores. Such community members are obliged to use your personal data in accordance with this privacy policy and only for the purposes as mentioned herein. Note that we are not responsible for the content of any websites created by community members.

7.    WILL MY DATA BE TRANSFERRED OUTSIDE OF THE EEA?

Some of the recipients named above are located outside the European Economic Area. If we transfer your personal data to parties outside the EEA, we will make sure that such transfer is accompanied by appropriate safeguards to ensure your personal data is adequately protected.

8.    HOW IS YOUR DATA SECURED?

It is important to Triangle Factory that your data is handled securely. Therefore, we make use of various security technologies and measures, to suitably protect your data against unauthorized access, use, loss or publication. Unfortunately, the exchange of information over the Internet is never 100% secure. Although we do our best to guarantee that your data remains secure, we cannot guarantee this absolutely.

9.    HOW LONG IS YOUR DATA RETAINED?

We will retain your personal data for as long as is needed to pursue the purposes as set out in this privacy policy. For example, Triangle Factory will store your personal data for as long as it has an ongoing relationship with you or for as long as needed to ensure compliance with its legal or contractual obligations.

10. MONITORING OF YOUR PERSONAL DATA AND PROFILING

We are committed to creating a positive and respectful community for all of our users.  As part of our efforts to ensure the safety and well-being of our users, we monitor chats, audio recordings and other data when you make use of the Breachers Products to detect and prevent abusive, offensive or inappropriate behavior within the Breachers environment. 

Recordings may be collected during in-game communication, such as multiplayer interactions, voice chat, or other features where users may communicate. For this purpose, we collect your language preference/location, chats, audio logs and the context in which such interactions take place (e.g. game events, timeline…). We rely on third party service providers to assist us in managing this moderation. Such third parties will only gain access to your personal data in a pseudonymized manner (i.e. through a unique identifier). Logs will be monitored through an AI system to detect any offenses to our Code of Conduct as laid down in our Terms of Use. If the algorithm determines that a potential offense has been committed, such log is then reviewed by a community manager who decides whether any action, such as excluding the offender from our community, must be taken. From time to time, the algorithm may make such decisions without human intervention. The algorithm may also make certain predictions about you (such as your age or other demographic data) in order to make a proper assessment of whether or not an event constitutes an offense and store certain aggregated training data about you to improve the efficacity of voice monitoring.

We process this personal data on the basis of our legitimate interest in providing our users with a secure and inclusive environment when they make use of the Breachers Products and on the basis of our legal obligation to detect and report any offenses. Your personal data will therefore be shared with our third party service providers as set out above and with the relevant authorities if we believe your behavior contravenes applicable laws. Such third party service providers may operate in a country providing a different level of data protection as your own country. We have therefore implemented the necessary safeguards to provide you with adequate data protection. 

Your recordings will only be stored for as long as necessary to detect offenses, report them to the community manager and/or the authorities, make a decision and to maintain the evidence as may be needed to support such decision.

Please note that, in the event you are subject to automatic decision-making (i.e. a decision based solely on automated means), this will be done solely on the basis of your explicit consent. Furthermore, you always have the right to request that a person reviews such decision. 

11.    HOW CAN YOU MANAGE YOUR DATA?

You, as a data subject, have certain rights with regard to your personal data. You can consult the personal data that Triangle Factory collects about you at any time, and correct any incomplete or incorrect information about you. You can request data portability, erasure and object to the processing of your personal data. You also have the right not to be subject to profiling or automated decision-making.

Some of these rights can be exercised by making use of the relevant features on the Breachers Website or the Breachers Products. If you are unsure how to exercise your rights or you have a request that is not covered on the Breachers Website or the Breachers Products, you can contact Triangle Factory in writing by sending your request to Dublinstraat 35/007, 9000 Ghent, Belgium, for the attention of legal department or by sending an e-mail to privacy@triangle-factory.be. If you want to exercise your rights, we ask that you be as specific as possible, so that we can address your request thoroughly and appropriately. We also remind you that we must be able to reasonably verify your identity in order for you to exercise your rights, so that we can prevent someone else doing so in your name.

You also have the right to lodge a complaint with a supervisory authority. The contact details of the Belgian data protection authority can be found on https://www.dataprotectionauthority.be/citizen or you can contact the supervisory authority in the country where you live.