Open Playtest Privacy Notice

Effective date: 23.09.2026
Version: 2.2

This Privacy Notice explains how BRICKWORKS GAMES LTD (“Brickworks”, “we”, “us” or “our”) collects and uses information during the open Steam Playtest of Sublustrum.

It applies to participants worldwide. Depending on your location and the processing involved, applicable local law may provide additional privacy rights and protections. Nothing in this Notice limits those rights or protections.

It supplements our general Privacy Policy. If the two documents differ in relation to the processing described here, this Notice applies to that processing during the open playtest.

Reading this Notice or participating in the playtest does not, by itself, mean that you consent to gameplay analytics. We ask for that consent separately in the game.

1. Who is responsible for your data

The data controller is:

BRICKWORKS GAMES LTD
28 Oktovriou, 367, Mediterranean Court, 1st floor, Flat/Office A5, 3107, Limassol, Cyprus.

For questions about this Notice or our privacy practices, contact privacy@brickworksgames.com.

Sublustrum is published by Hypetrain Digital. We may share findings that have been aggregated and irreversibly anonymised with our publishing partners for production, release planning and quality assessment.

Access to the playtest is provided through Steam. Valve processes Steam account and platform information under its own Privacy Policy. Valve’s processing is separate from the in-game processing described in this Notice.

2. Optional gameplay analytics through devtodev

With your prior consent, we use devtodev to collect anonymous gameplay and performance data to understand how the game is played and how it performs.

The analytics data includes:

  • Playtime and progress: gameplay time, in-game locations visited, completed puzzle or quest steps and the time associated with gameplay events.
  • Interactions: interactions with objects and the environment, changes in the state of game objects, items added to or removed from the inventory, and use of menus and game functions.
  • Performance: frame rate, frame-rate limits and the in-game context of performance measurements.
  • Computer and graphics information: processor and graphics card models, RAM capacity, screen resolution, keyboard or controller usage, graphics settings and changes to those settings.
  • Technical context: the game and operating system versions and technical information used to deliver and process analytics events.

References to locations, objects, items and quests mean elements within Sublustrum. They do not mean your physical location or a personal identifier.

The gameplay analytics dataset is anonymous. It does not contain your Steam ID, Steam profile, name, email address, a persistent player, device or installation identifier, or other information that would allow the records to be attributed to you. We do not ask for your age, date of birth or gender for this purpose.

Neither we nor devtodev retain a link that allows the anonymous analytics records to be associated with a particular player. We therefore cannot determine which records came from you or single out your contribution for individual removal.

Network infrastructure may process connection information, such as an IP address, to deliver data. This technical handling is separate from the anonymous gameplay dataset; connection information is not retained in a form that allows it to be linked back to your analytics records.

We use gameplay analytics for internal analysis and to improve Sublustrum, including identifying confusing or difficult parts of the game and improving puzzles, the interface and performance. We do not use it for advertising or advertising profiling.

3. Your analytics choice

Gameplay analytics is disabled until you choose “Allow analytics and continue” in the consent window.

You can choose “Continue without analytics” and retain full access to the playtest and its gameplay features.

Before you give consent, and whenever analytics is disabled, gameplay analytics events are not collected, stored for later transmission or sent to devtodev. Enabling analytics later does not cause us to upload a history of gameplay from periods when analytics was disabled.

You can withdraw your consent at any time by turning off “Share gameplay analytics” in the game settings. The change takes effect immediately. No additional confirmation or restart is required.

When you turn analytics off, your choice is saved, collection and transmission stop, and queued analytics events that have not been sent are discarded. Those events are not sent when the game closes, connectivity returns or you launch the game again. Analytics remains disabled on subsequent launches unless you choose to enable it again and give consent.

Turning off analytics prevents future collection. It does not remove previously collected anonymous information, because that information cannot be attributed to you. We may continue to use it for the purposes and retention periods described in this Notice.

Your analytics choice and information about it, such as the date and time and the version and language of the consent text, are stored locally to remember and apply your preference. These records are not sent to devtodev as gameplay events or used to identify your contribution to the analytics dataset.

The analytics setting controls devtodev gameplay analytics. Automatic crash reporting is described separately below.

4. Bug reports and automatic crash diagnostics

We use Unity Cloud Diagnostics and Unity Cloud User Reporting to investigate bugs, crashes and stability issues. Reports are sent from the game client to Unity’s infrastructure and reviewed by authorised Brickworks personnel through Unity Dashboard.

Manual bug reports

If you choose to submit a report through the in-game bug report form, we collect your description, the screenshot previewed in the form where available and included, the diagnostic information described in the form, and report metadata. Submission is voluntary and requires the confirmation provided in that form.

Please do not include passwords, Steam credentials, payment information, health information, other sensitive information or personal information about other people in your report.

Automatic crash reports

If the game crashes, a technical report may be sent automatically through Unity Cloud Diagnostics. These reports help us investigate crashes and identify problems associated with a particular build, device or hardware configuration.

Diagnostic information

Bug reports and crash reports may include:

  • game build, package, Unity version and platform information;
  • operating system and system language;
  • display settings, resolution and graphics settings;
  • device, memory and graphics hardware information;
  • the active game scene;
  • camera position and direction and the object or location being viewed in the game;
  • approximate country and technical report metadata.

We use this information to reproduce and fix problems, improve stability and performance, and protect the security of the playtest and reporting systems. We do not use these reports for advertising.

The description of anonymous gameplay analytics does not mean that information you voluntarily type into a bug report or send to us by email is necessarily anonymous.

5. Applicable law and legal bases

Brickworks is established in Cyprus. The EU General Data Protection Regulation (GDPR) and applicable Cyprus data protection law govern our processing of personal data. Other privacy laws may also apply depending on your location and the processing involved.

Anonymous information that cannot be linked to an identifiable person is not personal data under the GDPR. We nevertheless collect optional gameplay analytics only after your permission in the game.

Where personal data is processed in the technical delivery or anonymisation process, in diagnostics, or in correspondence, the following GDPR legal bases apply as relevant. References to Articles below are to the GDPR:

  • Personal data processed for optional gameplay analytics before effective anonymisation or in associated technical operations: your consent under Article 6(1)(a).
  • Voluntary manual bug reports: your consent when you confirm and submit the report under Article 6(1)(a).
  • Automatic crash diagnostics: our legitimate interests under Article 6(1)(f) in investigating technical faults and maintaining the stability and security of the playtest, subject to your rights and applicable legal requirements.
  • Compliance with legal obligations: Article 6(1)(c), including handling applicable data protection requests and keeping evidence of consent where required.
  • Establishing, exercising or defending legal claims: our legitimate interests under Article 6(1)(f), limited to the information and period necessary for that purpose.

These legal bases do not override additional requirements under applicable local law, including requirements concerning consent and access to or storage of information on a device. We obtain any additional permission required for the relevant processing before it begins.

6. Who receives the data

Access is limited to authorised employees and contractors who need the information for development, analytics, testing, technical support, security or legal duties.

We use:

  • devtodev for optional gameplay analytics;
  • Unity for crash diagnostics and manual bug reports.

These providers process data on our behalf under the applicable service and data processing arrangements and may use subprocessors to deliver their services. We remain responsible for the purposes of the processing we instruct them to carry out.

devtodev’s Privacy Policy also describes its use of anonymous aggregated information for research and for improving and promoting its services. Such information must not identify an individual player.

We may disclose information to public authorities where required by law, or to professional advisers where necessary to establish, exercise or defend legal claims.

We do not sell personal data collected through the playtest or share it with advertising networks for targeted advertising.

7. International transfers

Brickworks is established in Cyprus. Our service providers and their subprocessors may process information in other countries, including countries outside the European Economic Area or your country of residence. Data protection laws in those countries may differ from the laws where you live.

Where required, international transfers of personal data are covered by an applicable adequacy decision or appropriate safeguards, such as approved standard contractual clauses or other transfer mechanisms recognised by applicable data protection law, together with supplementary measures where necessary.

You can request information about the safeguards applicable to your data and a copy of the relevant safeguards by contacting privacy@brickworksgames.com. Copies may be redacted where necessary to protect confidential information.

8. Retention

We keep information for the following periods:

  • Detailed anonymous devtodev gameplay analytics: no more than 180 days from collection.
  • Bug reports and crash reports: normally up to 90 days, subject to the limited exceptions below.
  • Local analytics preferences: for as long as needed to remember and apply your choice on the installation.
  • Privacy request correspondence: for as long as necessary to handle the request and demonstrate that it was handled appropriately.
  • Anonymous aggregate statistics: may be retained longer for the purposes described in this Notice.

These periods also apply to copies and exports under our control. Detailed analytics records are removed after the applicable period; anonymous aggregate statistics may remain. Other information is deleted or irreversibly anonymised when no longer needed.

Limited personal information may be retained longer where required by law or necessary for a specific legal claim or a documented, ongoing security investigation. Such retention is restricted to what is necessary. It does not permit further collection of gameplay analytics after it has been disabled.

9. Anonymous data and your privacy rights

We cannot identify which anonymous gameplay analytics records belong to a particular player. Accordingly, we cannot retrieve or remove a particular player's contribution from that dataset. Disabling analytics stops future collection; previously collected anonymous information remains subject to the retention periods above.

We do not collect additional identifying information to reconnect anonymous statistics to individual players.

This does not limit your statutory rights in relation to any personal data that we do process, such as information you voluntarily provide in correspondence. Depending on applicable law, you may have the right to:

  • access your personal data and receive a copy;
  • correct inaccurate personal data;
  • request deletion or restriction of processing;
  • receive eligible data in a portable format;
  • withdraw consent at any time;
  • object to processing based on legitimate interests on grounds relating to your particular situation;
  • lodge a complaint with a competent data protection authority.

If you object to processing based on legitimate interests, we will stop that processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for legal claims.

You may have additional rights under the laws applicable where you live. We respect those rights and do not restrict them through this Notice.

You can lodge a complaint with the competent data protection authority as provided by applicable law. Under the GDPR, this includes the supervisory authority in the EU Member State of your habitual residence, place of work or the alleged infringement. The supervisory authority in Cyprus, where Brickworks is established, is the Commissioner for Personal Data Protection.

We do not use the data described in this Notice for solely automated decisions that produce legal or similarly significant effects on you.

10. Children and young people

We do not ask for a date of birth or age confirmation in the gameplay analytics consent window.

Additional legal protections may apply to children’s personal data. Participation in the playtest does not override those protections or any applicable requirements for parental authorisation.

Parents and guardians can raise privacy concerns using the contact details below. We will investigate and take the action required by applicable law.

11. Security

We use technical and organisational measures appropriate to the nature of the information and the risks involved, including access restrictions and confidentiality obligations for people authorised to work with the data.

12. Changes to this Notice

We may update this Notice when the playtest, our services or legal requirements change. We will update the effective date and version shown above.

We will communicate material changes through appropriate channels before the relevant new processing begins. If a change requires new consent, we will request it before starting that processing. Continuing to play does not, by itself, provide consent to additional gameplay analytics.

13. Contact

BRICKWORKS GAMES LTD
28 Oktovriou, 367, Mediterranean Court, 1st floor, Flat/Office A5, 3107, Limassol, Cyprus.
Email: privacy@brickworksgames.com