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Privacy Evaluation for Steam

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Overview

Steam is a video game digital distribution service and storefront by Valve with support for virtual reality headsets. The terms say the Steam community includes message boards, forums and chat areas, where users can exchange ideas and communicate with each other. In addition, the terms say Steam does not sell a user's data to third parties, but Steam may process anonymous data of users to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Steam's terms say they may share anonymous data, aggregated or not, with third parties. However, the terms do not say whether Stream may display targeted advertisements to users or whether Stream may track users across different applications and services on the internet for advertising purposes.

The terms say Steam recognizes how important it is to help protect their users' privacy and security. In addition, the terms say Steam understands that secure products and services are critical in establishing and maintaining trust with their users. The terms say Steam is not intended for children under 13 year of age and Steam does not knowingly collect personal information from children under the age of 13. Lastly, Steam's terms also say that users can access, modify, delete, and export their personal information from the Steam service at any time. However, the terms do not discuss student data privacy and potential use by students in K-12 institutions.

Steam can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Steam's website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Security Policy, and Steam Subscriber Agreement. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms say the Steam community includes message boards, forums and chat areas, where users can exchange ideas and communicate with each other. In addition, Steam will collect and process a user's personal data whenever they provide it as part of communication with others on Steam in Steam Community Forums, chats, or when a user provides feedback or other user generated content. The terms say that Steam does not require users to provide or use their real name for the setup of their Steam User Account. However, at a minimum the public profile name a user has chosen to represent themselves on Steam and their avatar picture are publicly accessible, as well as whether they have received a ban for cheating in a multiplayer game.

Privacy

The terms say Steam collects personal data from users through automated electronic interactions and application usage data which includes various information about a user's behavioral activity with Steam. The terms say content-related information includes a user's Steam ID, as well as what is usually referred to as game statistics. According to Steam, game statistics mean information about a user's game preferences, progress in the games, playtime, as well as information about the device they are using, including what operating system they are using, device settings, unique device identifiers, and crash data.

In addition, the terms say Steam does not sell a user's data to third parties, but Steam may process anonymous data of users to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Steam's terms say they may share anonymous data, aggregated or not, with third parties. However, the terms do not say whether Stream may display targeted advertisements to users or whether Stream may track users across different applications and services on the internet for advertising purposes.

Security

The terms say Steam recognizes how important it is to help protect their users' privacy and security. In addition, the terms say Steam understands that secure products and services are critical in establishing and maintaining trust with their users. Steam's terms also say they strive to consistently deliver secure and enjoyable experiences in all of their products and services. The terms say Steam uses reasonable security practices to protect personal data and will respond as soon as they can to fix any verifiable security issues. When notified of legitimate issues, the terms say Steam will begin investigating any security issue and will work to correct any vulnerabilities quickly. However, the terms do not say whether reasonable security practices such as encryption are used to protect a user's personal data while in transit or at rest, or whether notice is provided to users in the event of a data breach.

Compliance

The terms say Steam is not intended for children under 13 year of age and Steam does not knowingly collect personal information from children under the age of 13. However, the terms also say Steam requires parental consent before a Steam user account can be created for children and before any personal data associated with a child account is collected or shared. Steam encourages parents to instruct their children to never give out personal information when online. In addition, the terms say if a parent withdraws their consent Steam will delete the personal data of their child without undue delay. Lastly, Steam's terms also say that users can access, modify, delete, and export their personal information from the Steam service at any time. However, the terms do not discuss student data privacy and potential use by students in K-12 institutions.

Rating

This product received a Warning rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Unclear whether personal information are shared for third-party marketing.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 55%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are collected.
  • Data is automatically collected.
  • Opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 65%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • Unclear whether the categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
  • Unclear whether this product supports third-party login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 25%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • Unclear whether third-parties with access to information are required to provide the same security protections as the company.
  • Reasonable security practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 85%

What rights do I have to the data?

  • Users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access or review user data are available.
  • Processes to modify data are available for authorized users.
  • A data-retention policy is available.
  • Unclear whether authorzied users can delete data.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 45%

Is the data sold?

  • Personal information is not sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
  • Unclear whether users are notified if their information is transferred to a third party.
  • Unclear whether user information can be deleted prior to its transfer to a third party.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • User information that is shared is shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 45%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Users can control how their data are displayed to others.
  • Unclear whether user-created content is reviewed, screened, or monitored by the company.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 20%

Are there advertisements or tracking?

  • Unclear whether personal information are shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays personalised advertising.
  • Unclear whether data are collected by third-parties for their own purposes.
  • Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company can send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 60%

Can I provide parental consent?

  • Not intended for children under 13.
  • Personal information from children under 13 years of age is not collected.
  • Unclear whether intended for parents or guardians.
  • Company does not have actual knowledge that personal information from users under 13 years of age is collected.
  • The company does not provide a section, heading, or separate policy for children in their policies.
  • Parental consent is required before personal information is collected or disclosed.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Parents can withdraw consent for the further collection of their child's information.
  • Children's personal information is deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 0%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Processes to enter education records into the product are not described.
  • Unclear whether additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 35%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Unclear whether use of information is limited to the purpose for which it was collected.
  • The context or purpose for which data are collected is indicated.
  • Company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Unclear whether notice is provided if the context in which data are collected changes.
  • Unclear whether consent is obtained if the practices in which data are collected change.
  • A grievance or remedy mechanism is available for users to file a complaint.
  • Unclear whether users can request to know what personal information has been shared with third parties.
  • Unclear whether notice is provided in the event the company receives a government or legal request for a user's information.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.