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2. Policy Statement

ATF will use Legitimate Interest as one of the bases of its GDPR compliance, for processing PII from customers and suppliers.

The Legitimate Interest justification is based on the following excerpt from the General Data Protection Regulation which outlines where Legitimate Interest can be used:

• Under Article 6(1)(f) — “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of Personal Data, in particular where the data subject is a child.” Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks.
• Under Recital 47 — “The legitimate interests of a controller, including those of a controller to which the Personal Data may be disclosed, or of a third party, may provide a legal basis for processing, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller.”

Further, the GDPR states that “the processing of Personal Data for business activities and purposes may be carried out for a legitimate interest. An organization may wish to rely upon Legitimate Interests where consent is not viable or not preferred and the balance of interests condition can be met.” ATF has thus carried out a Legitimate Interest Assessment.

Legitimate Interest Assessment

Where required, ATF will undertake a Legitimate Interest Assessment. This has been identified as a 3-step process:

1. Identifying a Legitimate Interest
2. Carrying out a Necessity Test
3. Carrying out a Balancing Test

All Assessments will be available to the relevant data subjects and formal notification of the processing activities and justification will be provided.

ATF User Personal Information

Identifying a Legitimate Interest

ATF has a legitimate interest in processing the personal data of data subjects that are likely to use ATF products or services. The only personal data that is held, stored, and processed by ATF is Steam ID64, in-game display name and Steam avatar URL, gameplay statistics, and live roster presence when connected to an ATF server. All the services provided by ATF have direct relevance to the data subject.

Necessity Test

The processing is necessary in pursuit of the interests above. ATF has examined alternatives and the only alternative available — unambiguous opt-in — was reviewed and rejected as impossible to implement given the range of our services. Our users and equipment are in use 24 hours a day.

Balancing Test

ATF has conducted a balancing test to ensure that our interests do not override those of data subjects.

We believe that the data subjects will have a reasonable expectation of being contacted by ATF because of their activities on our servers.

All data subjects are given notice that their data is being collected by connecting to our servers. They are informed about the legal basis of our processing, and the purpose of this (for use by ATF and its partners). They will have access to the data we store about them and it will be kept accurate and secure.

All data subjects will provide their PII directly to ATF representatives via electronic communication. Their information will be added to the users database. Data subjects reserve the right to inform ATF directly during this process to be excluded from our user database. All contacts are informed about the legal basis of our processing, and the purpose of this (for use by ATF and its partners). They will have access to the data we store about them and it will be kept accurate and secure.

3. Responsibility and Authority

This policy is produced by the Atom Task Force Generals Team. The objectives are set by the Atom Task Force Generals Team and the policy is approved by the General of ATF.

4. General

This policy aligns to the requirements and expectations defined within ISO 27001:2022 and ISO 9001:2015.

For and on behalf of ATF.

Related pages: Privacy Notice · Terms of Use