Last Updated: 2026-10-20
1. INTRODUCTION
With this information text ("Privacy Policy"), Embark Studios AB ("Embark"/"we") intends to fulfill our transparency obligations under the General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act/California Privacy Rights Act ("CCPA/CPRA"). An important aspect of these obligations is to inform individuals of how we process their personal data.
This Privacy Policy describes the personal data that Embark collect when you enter the Speranza Security Recruitment Community Competition (the “Promotion”), including through the Submission Form. It applies only to personal data collected in connection with the Promotion and should be read together with the Promotion's Official Rules, available at /arc-raiders/support/faq/285-speranza-security-recruitment-community-competition---official-rules/ (the “Official Rules”). Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Official Rules.
2. CONTROLLER
Controller: Embark Studios AB
Corporate identification number: 559172-3019
Address: Kungsträdgårdsgatan 16
111 47 Stockholm
Sweden
Email: privacy@support.embark-studios.com
3. WHAT CATEGORIES OF PERSONAL DATA WILL WE PROCESS?
When you submit an Entry, we collect the following categories of personal information:
Identifiers: your Embark ID, your Credit Name, your email address and other contact details you provide.
Audio information: your Recording(s), which contain your voice, and, for Category B, the text of your original line.
Characteristics of protected classifications: your age being 18+, collected only to confirm eligibility.
Internet or other electronic network activity: technical information about your files, such as file type, length, and metadata.
We do not collect sensitive personal information in connection with the Promotion. We do not use your voice to identify you or to create a voiceprint.
The provision of the personal data is necessary for us to be able to manage your Entry and the Promotion.
4. FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS PERSONAL DATA?
We use the personal data to:
administer and judge the Promotion;
verify your eligibility and check that Entries comply with the Official Rules, including that a Recording is a genuine, unaltered recording of your own voice;
contact winners and fulfill prizes;
implement winning Recordings in ARC Raiders, where they will be heard by other players;
use, edit, and promote Entries as licensed under Section 9 of the Official Rules, and identify winners by their Credit Name; and
comply with legal obligations and establish, exercise, or defend legal claims.
We do not sell your personal information or share it for cross-context behavioral advertising.
We carry out this processing in response to your request to participate in the Promotion. If you are located in the EEA, the legal basis for this processing is Art. 6 (1) (b) GDPR (performance of a contract).
5. FOR HOW LONG DO WE KEEP THE PERSONAL DATA?
We will process the personal data only as long as necessary for the purposes set out above.
Non-winning Entries are deleted within 14 days after the winners are announced.
Winning Recordings and related Entry information are kept for as long as the Recording is used in ARC Raiders or related materials, and afterward as needed to document our rights and meet legal obligations.
Prize and eligibility records are kept for 1 year.
6. WHOM DO WE SHARE PERSONAL DATA WITH?
In order for us to be able to fulfill our commitments, we transfer personal data to suppliers of Embark, in particular our service providers of various IT services. The suppliers to which Embark discloses personal data will only process the personal data for the purposes mentioned in this Privacy Policy. Embark has entered into data processing agreements with its suppliers that meet the requirements of applicable data protection legislation.
7. TRANSFERS TO THIRD COUNTRIES
Embark always seeks to process personal data within the EU/EEA, but in the event of a transfer of personal data outside the EU/EEA, Embark will observe applicable data protection legislation regarding transfers to third countries. Embark will only transfer personal data to a country outside the EU/EEA provided that (i) the third country ensures an adequate level of protection of personal data under a decision issued by the European Commission, (ii) Embark ensures that appropriate safeguards and security measures are in place according to applicable data protection legislation; or (iii) if any other exception exists under applicable data protection legislation.
8. RIGHTS
According to the GDPR you have the right to request:
A confirmation from Embark about how we process personal data, and in such case request access to the personal data in the form of an extract from the register
Correction of incorrect or incomplete personal data
Deletion of your personal data in some cases, e.g. if your personal data is no longer necessary for the purposes for which they were collected
Objection to processing that relies on legitimate interests
Restriction of the processing of your personal data, meaning that you request Embark to limit its processing of your personal data under certain circumstances
Receipt and transfer of personal data to another controller in some cases (data portability)
You also have the right to lodge complaints regarding the processing to a supervisory authority within the EU. When requesting access to your personal data, please contact Embark by email: privacy@support.embark-studios.com