Ultimate Games S.A. respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation („GDPR”) and the Swiss and EU Privacy Shield Frameworks.

Privacy Policy – Microsoft Store & Xbox

Last Updated: March 30, 2020

Ultimate Games S.A., a Polish corporation, with registered and business offices at Marszałkowska 87/102, 00-683 Warsaw, Poland (“Ultimate Games S.A.”), is the data controller. Ultimate Games S.A. respects your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you understand the ways in which we do and do not use the personal data you transmit when accessing and playing one of the below-listed games, accessing and using the websites, platforms and related services (hereinafter the “Game”).


  • Car Mechanic Simulator Classic
  • Robot Squad Simulator X
  • Selma and the Wisp X
  • Ultra Off-Road 2019: Alaska
  • Vampire’s Fall: Origins
  • Bug Academy
  • Commander ’85


Please note that this Privacy Policy applies only to personal data submitted and collected online through or in relation to the Game and game platforms, and does not apply to personal data that may be collected by Ultimate Games S.A. or its affiliates offline.

To provide the Game, we will share your personal data with some or all of the following third parties depending on how you use the Game:

  1. The personal data processors, which will process personal data on Ultimate Games S.A. behalf (“Third Party Processor(s)”):
    • Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA
    • Ultimate Games S.A., st. Marszałkowska 87/102, 00-683 Warsaw, Poland,
  2. When connecting our Game to certain third-party services (“Connected Service Provider(s)”):
    • Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA
    • Facebook, Inc. 1601 Willow Road, Menlo Park, CA 91025, USA,
  3. Depending on the platform you use to play the Game (“Platform Service Provider(s)”):
    • Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA
  4. To provide payment services for purchases made within the context of the Game (“Payment Service Provider(s)”):
    • Google Pay is known as Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, for storing and processing personal data; and/or
    • Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA
  5. To provide sales and marketing services (“Sales Service Provider(s)”):
    • Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, for storing and processing personal data; and/or
    • Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA
  6. To ensure the proper performance of the game experience and provide technical support. By signing up to use online Services on Microsoft’s Xbox Live Service, you agree that Microsoft may provide us with your Microsoft user account information. From Microsoft, we receive information including your Gamertag, email address, state or province, country, language, and age. We do not receive your credit card number or other financial information.

No one under the age of 16 should send any personal data about himself/herself through the Game to Ultimate Games S.A. without the permission of his/her parent or guardian. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 16 has accessed and/or played the Game and provided personal data to us, please contact us at [email protected] or one of the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personal data.

1. Personal data that Ultimate Games S.A. collects

In order to access and play the Game, you must create an account on the Game’s web page or on the Platform Service Provider(s) platform that hosts the Game. To create an account, you are required to provide certain mandatory personal data such as your name, your email address and account login. This is mandatory in order to be able to establish an account.

Ultimate Games S.A. and/or the Payment Service Provider(s) collects personal data relating to financial information on the terms and conditions set out in this Privacy Policy. Ultimate Games S.A. does not use this financial information for any purpose other than processing payments.

Legal basis for using personal data related to financial information

We collect and process this personal data in order to provide you with the Game and fulfill our contractual obligation to you.

Further, you may, but are not required to, provide certain voluntary personal data such as date of birth, screen name, your personal profile in the Game, interests in and use of various products and services, and any other personal or preference data which you may choose to voluntarily provide.

Ultimate Games S.A. will also collect and process other types of personal data when you interact with the Game online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifiers such as a device identifier of your computer(s) or device(s) that are used to access the Game. Such personal data will be collected and processed irrespective of whether you only access the Game or if you actually play the Game.

Legal basis for using personal data related to your technical use

We collect and process this personal data in order to provide you with the best user experience possible and the legal basis for this is legitimate interest.

Ultimate Games S.A. will also collect and process certain personal data when you as an account holder interact with the Game. The personal data is then derived from your personal profile, the relationships you form in the Game, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit through various channels.

Legal basis for using personal data related to your account

We collect and process this personal data in order to provide you with the best user experience and the legal basis for this is legitimate interest.

If you choose to use any invitation service to tell a friend about the Game, Ultimate Games S.A. will ask you to provide personal data needed to send the invitation, such as your friend’s email address, etc. Ultimate Games S.A.  will automatically send your friend a one-time email or instant message inviting him or her to visit the Game. Ultimate Games S.A.  stores this personal data to send this one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact Ultimate Games S.A. at [email protected] to request that Ultimate Games S.A.  remove this personal data from its database.

Legal basis for using personal data of referrals

We collect and process this personal data in order to provide our services to referrals. The legal basis for this processing is legitimate interest.

If you have purchased the Game through a Platform Service Provider, it will provide us with your unique Player-ID.

Ultimate Games S.A. is always looking for ways to improve your experience in the Game. Ultimate Games S.A.  may at times solicit additional personal data to offer new games, products, and services that may be of interest to you.

2. Use and Disclosure of Personal Data

When you register an account in the Game, you create your own profile and privacy settings. Your name, email and profile picture may be displayed to others in the networks, depending on your privacy settings.

Ultimate Games S.A. will from time to time send you Game related announcements through the general operation of the Game, including product placements in the Game. Further, we may occasionally use your name and email address to send you information that we think is of interest to you, including information regarding the Game, new products and services, updates, campaigns, promotions, faults, issues relating to technical aspects and/or the usability of the Game and payment methods offered. This includes sales offers and advertising regarding our games, products and services and/or business. We may also send out surveys.

Regardless of your setting for email announcements, Ultimate Games S.A.  will send you notices about changes to your account.

Generally, the personal data collected by Ultimate Games S.A.  will only be used for the particular purpose for which it was collected. However, Ultimate Games S.A. may also transfer, disclose and/or share your personal data with partners, affiliates and other third parties who facilitate the operations of the Game (e.g. processing orders and payments). These third parties only have access to personal data as needed to perform their work.

In the event of a corporate reorganization (if, for example, all or substantially all of the assets relating to Ultimate Games S.A. are transferred or sold to another entity), personal data submitted to Ultimate Games S.A. will be transferred to the acquiring entity.

Ultimate Games S.A. will also disclose personal data to third parties in order to comply with international, national and regional laws and regulations, in response to requests by law enforcement agencies, to enforce its End User License Agreement, or to protect the rights, property or safety of Ultimate Games S.A., the Game and End Users. We will use personal data and records for defense of any lawsuit, investigation or other actions if such personal data, records or profiles are relevant to a lawsuit, investigation or action.

Ultimate Games S.A. will only keep your personal data as long as necessary for the purposes of which the personal data was collected. This means that we will keep your personal data as long as you have an active account with us. If you have not used your account for more than 36 months, or your account has been terminated by you or us, all personal data will be deleted.

3. Sharing Your Personal Data with Third Parties

We do not share your contact information with third party marketers without your permission. We only share your personal data with third parties in limited circumstances where we believe such sharing is 1) necessary to provide the Game and related services, 2) where legally required or 3) when permitted by you.

When using the Game, your personal data will be processed by the Third Party Processor(s). We will enter into a data processing agreement prior to sharing your personal data with such Third Party Processor(s). As we are a global company and are using Third Party Processor(s) working outside of the EU/EEA, personal data will be processed in the US and other countries. We are committed to protecting your personal data and where local laws do not provide an adequate level of protection of that data we have signed data processing agreements and included the EU Commission approved standard contractual clauses as necessary.

You may connect your Game account to certain connected third-party services, for example, Steam, as available. If you connect your Game account to such connected services, the Connected Service Provider(s) will process your personal data. The Connected Service Provider(s) may require you to sign up to their own license agreements/user terms, privacy policies or other policies, which may give the Connected Service Provider(s) additional rights or impose additional obligations on you.

We may be required to disclose your personal data and other information pursuant to legal requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal information until we have a good faith belief that an information request by law enforcement or private litigants etc. meets applicable legal standards. Additionally, we may share account or other information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Game or misuse of the Games name, or to prevent imminent bodily harm, etc. This may include sharing information with other companies, lawyers, agents or government agencies, etc.

Like many other websites interacting with third party sites, we may receive some personal data or information even if you are logged out from the Game, or that pertains to non-game users, from those sites in conjunction with the technical operation of the system. In cases where Ultimate Games S.A. receives personal data or information on users that are not logged in, or on non-game users, we do not attempt to associate it with individual End User accounts and will discard it.

When you use the Game, certain information you post or share with third parties (e.g., a friend or someone in your social network), such as personal data, comments, messages, photos, videos, or other information, may be shared with other End Users in accordance with the privacy settings you select. All such sharing of information is done at your own risk. Please keep in mind that if you disclose personal data in your profile or when posting comments, messages, photos, videos, or other items, this information may become publicly available.

4. Cookies, Logs, and Web Beacons


A cookie is an information a website places on your computer so that the website is able to remember your preferences and/or which pages you visited on the website and make your visit more efficient and enjoyable. Ultimate Games S.A. uses cookies to determine the number of unique visitors to the Game over a given period or to remember user account details so that the need for multiple logins is reduced.

Ultimate Games S.A. will combine information collected through cookies with your personal data submitted online when using the Game, to help personalize your experience when accessing and playing the Game.

Cookies may be disabled on your computer by indicating this in the preferences or options menu in your browser. Please note, however, that by disabling cookies some features might not work as intended.


Log files are files that log actions that have occurred on a website.