Background flare animation
Single page background image

Privacy Policy


Last Updated: 21 April 2020

We are committed to respecting your privacy and protecting your personal data. This privacy and cookie policy (“Policy”) sets out how we use data relating to you and applies to all use of your personal data by STUDIO ZA/UM LTD a company registered in England and Wales under company number 12394671 with its registered office at 24 Rivington Street, London, England, EC2A 3DU (“we”, “us” or “our”).

This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our game Disco Elysium (including, where each is applicable, on PC, Mac, iOS and Android) (the “Game”). This Policy also applies for our websites where we make this Policy available (the “Website”). Our Games and Websites are together the “Services”. Please read the Policy carefully to understand our views and practices regarding your personal data.

We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including the EU General Data Protection Regulation 2016 (“GDPR”) and the UK Data Protection Act 2018. Where we decide the purpose or means for the processing of the personal data that you provide when using our Services, we are the “data controller” for the purposes of the GDPR.

You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.

If you have any concerns over privacy, or this Policy contact us at

  1. how we collect and use your personal data
    1. The table below explains what data we collect, how we use it, and which recipients it might be shared with.
      Your dataHow we use itThird Party Recipients
      Support / enquiry information (information we receive when you get in touch with us for support):

      • Name;
      • Contact details (address, phone number, email);
      • Other personal data you send to us.
      We process this information in accordance with the terms of our contract with you (where we need this information to provide our services to you such as under our applicable EULA / terms of use) and in pursuit of our legitimate interests in responding to your enquiry and in order to improve our services.None.
      Game analytics and usage information (collected automatically when you play the Game, or which may be available to us from Game platforms / stores):

      • IP address;
      • Device ID; and
      • ‘Events’ related to Game usage, such as progress, achievement of a milestone and the occurrence of other particular events during your Game usage (such as Game installation/uninstallation, play session durations and choices/selections for different parts of the Game, interactions with Game content).
      We may collect this data so that we can understand usage of our Game, analyse and improve our Game and develop new services or new parts thereof. In some cases it may also help us to identify problems (e.g. bugs or problems preventing in-Game progression).
      In many cases the data would be aggregated and/or anonymised so that it would not identify you.
      To the extent personal data is included in this data, its processing is necessary for us to pursue our legitimate interests, being our commercial interests in: (i) ensuring that our Game functions properly and users have the best experiences; (ii) improving the quality of our Game; (iii) identifying and correcting any bugs or problems; and (iv) developing and creating new games and parts of the Game or additional content.
      Website analytics (collected from your device and interaction with our Website):

      • how often you use our Website;
      • which pages you go to;
      • your IP address;
      • device and browser operating system, version, make and model.
      This processing is necessary for us to pursue our legitimate interests of understanding how you use the Website so we might identify problems and improve the Website.We use Google Analytics to help us understand how our Services are used.
      Your content:

      • any other content you submit to us via the Services, such as Website comments and marketing preferences (where applicable) and other information concerning your use of the Services and any other user-generated content you send to us.
      We process this information in accordance with the terms of our agreement with you (such as our terms of service governing our Website) and also in pursuit of our legitimate interests in responding to your enquiries and in order to improve or deliver our products or services.None.
      Email newsletters (if we operate them):

      • your email address; and
      • other information collected and clearly identifiable to you at the point of your signing up to our email newsletter.
      Consent-based mailing lists
      We may process your data to make suggestions and recommendations to you and other users of our Services about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest.To the extent required by law, we rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us.
      ‘Soft opt-in’ mailing lists
      In some instances (such as with some of our existing customers) the law may permit us to process your personal information in order to send information to you by email that we think is of interest for you on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and our websites, content, products and services. We may process your information for this purpose. If the information is not of interest for you, you can opt-out at any time by letting us know, including by emailing us.
      • Competition and promotion related entry data – where you may enter a competition / prize promotion with us (such as over email or over social media):
      • your entry contact information (e.g. social media username or email);
      • information submitted as part of your entry; and
      • information submitted so we can process your entry (such as your address, if we need to send you a prize).
      We may from time to time operate prize promotions and competitions (without any obligation to do so). If we do, your personal data processed in connection with that activity would be processed on the basis of performance of a contract (being the competition / prize promotion terms of entry).None.
  2. Your Rights In Relation To Your Personal Data
    1. You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
      • for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
      • to restrict, stop processing, or to delete your personal data;
      • for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
      • to make a complaint to a data protection regulator. You may contact them at:
    2. To make a request in relation to any of the aforementioned rights, please send your request to
    3. You may request deletion of your personal data by sending an e-mail to Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.
    1. We will share your personal data with third parties only in the ways that are described in this policy.
    2. Group, suppliers, subcontractors, service providers, game / application stores. We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
    3. Government authorities. In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
    4. Potential acquirers or investors. If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your personal data, as well as any choices you may have.
    5. Enforcement. We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
    6. Stores. We may also disclose your personal data, to the extent necessary, to game / application stores or platforms if that is required, for example, for fulfilment of an order you make (e.g. if needed to fulfil a mobile game DLC order) or in order to investigate or prevent fraud.
    7. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.
  4. Data Retention
    1. We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy.
    2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
  5. Security
    1. We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Service visitors and customers.
    2. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
  6. International Data Transfers
    1. We are a UK Company and our servers are located in the EEA and your personal data will be stored in these servers.
    2. There are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses.
    3. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at
  7. General
    1. If you follow a link from the Service to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
    2. We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.
    3. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.