Privacy Policy

Updated on June 24, 2025:

At Keen Software House s.r.o., with registered office at Na Petynce 213/23b, Břevnov, 169 00 Prague 6, ID No.: 052 64 561 (hereinafter referred to as “Keen“, “we“, “our” or “us“), we pay due attention to the protection of your personal data (hereinafter referred to as the “Personal Data“). This document provides you with information about the processing of your Personal Data in connection with your use of our game “Space Engineers 2” (hereinafter referred to as the “Game“), related Keen’s website and/or other Keen’s platforms used for operation and promotion of the Game (collectively with the Game hereinafter referred to as the “Services”). We process all Personal Data with the utmost attention to security and use appropriate available technical, procedural and organizational means to protect it. In case of any uncertainties or questions, you may contact the contacts listed in Section 1 of this document.

1. Data controller

Keen is the controller of your Personal Data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “Regulation”).

You may contact us for any matters relating to the processing of your Personal Data:

• by email to the email address: info@keenswh.com;
• in writing by post to the address: Keen Software House s.r.o., Na Petynce 213/23b, Břevnov, 169 00 Prague 6.

2. Personal Data we process and their sources

a/ Personal Data you provide to us

We process personal data provided to us directly by you. For example, you may share Personal Data with us when you fill out a form, interact with us via third-party platforms, request customer support or otherwise communicate with us. We process the following categories of your personal data:

• Contact data, such as email address;
• Information on your use of the Services and your interaction with us, such as content of your communication with us or feedback that you provide to our Services.

b/ Personal Data provided by a third party

Since you need to set up and maintain a user account via one of the dedicated third-party platforms (e.g. Steam) to buy, log into and play the Game, we process Personal Data related to your user account provided to us by such third party for this purpose, such as your user ID, IP address, game analytics data and/or other related data. You might also purchase Steam keys via our partner Xsolla. In such case, Xsolla provides us with the reports on purchases including your user ID, email and IP address (we hereinafter refer to all such personal data provided to us by third party collectively as “Personal Data provided by a third party“). Please note that the processing of personal data by such third party, including its provision to us, is governed by the applicable terms of such third party.

c/ Personal Data we receive automatically from your use of the Services

When you visit, use, and interact with the Services, we may receive certain information via cookies and other analytics tools used within the Services. We only use cookies and other analytics tools if you granted us your consent to do so or if these are necessary for the operation of our Services.

Cookies are small text files containing short data that can be stored on the user’s device when visiting a website. We use cookies to operate and administer our Services and improve your experience on it. You can accept all or selected cookies or to reject all cookies via setting of your browser or cookie bar on the website through which you enter the Services. Cookies may in some cases affect the display or function of a website or certain areas or features of a website. We also use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

Through cookies and other analytics tools, we gather information from the following categories:

• Log data, i.e., information that your browser automatically sends whenever you use our website. Log data includes your IP address, browser type and settings, the date and time of your request, and how you interacted with our website;
• Usage data, i.e., information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, IP address, and others;
• Device information, i.e., name of the device, operating system, and browser you are using.

The above stated Personal Data are being processed manually as well as by automated means. During our processing of your Personal Data, you are not subject to profiling and/or automated decision making with the exception referred to in the following sentence. Please note that you may be subject to automated decision making with regard to the termination of the agreement with you in case you breach contractual terms stipulated between us, such as End User License Agreement available at https://2.spaceengineersgame.com/eula/ ; in such a case, you have the right to obtain human intervention as described in Section 6 below.

3. Why we process your Personal Data

We process your Personal Data for the following purposes:

1. Providing and maintaining our Services based on the performance of a contract (established by the End User License Agreement) with you within the meaning of Article 6 (1) (b) of the Regulation; within this purpose, we process your Personal Data in order to provide you our Services, authenticate you when you log in or operate and maintain our Services;
2. Monitoring and analyzing trends, usage, and activities to improve your experience and our Services on the basis of our legitimate interests within the meaning of Article 6 (1) (f) of the Regulation; we are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of our Services.
3. Providing customer support and communicating with you about our Services on the basis of our legitimate interests within the meaning of Article 6 (1) (f) of the Regulation; we process your Personal Data to send you communications via email and within  the Services, including responding to your comments, questions, reports and  requests, providing customer support, sending you technical notices, updates, security alerts, and administrative messages or requesting feedback and sending customer experience surveys. Depending on your settings, we send you email notifications when you or others interact on our Services. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases, you cannot opt-out of them. If an opt-out is available, you will find that option within the communication itself or in your account settings;
4. Creating and further using of de-identified, anonymized, aggregated or statistical information on the basis of our legitimate interests within the meaning of Article 6 (1) (f) of the Regulation; we use such data, that cannot be further connected to your personal data, to improve and fine-tune our Services;
5. Securing our Services, debugging to identify and repair errors in our Services on the basis of our legitimate interests within the meaning of Article 6 (1) (f) of the Regulation; in order to keep our Services safe and secured for you, we process your Personal data for detecting, investigating and preventing security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Keen and others. We also process Personal Data to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
6. Complying with our legal obligations on the basis of compliance with a legal obligation within the meaning of Article 6 (1) (c) of the Regulation; for this purpose, we need to process and store your personal data to comply with various legal obligations, such as obligations in area of taxes and accounting;
7. Protecting and defending our legitimate interests and rights on the basis of our legitimate interests within the meaning of Article 6 (1) (f) of the Regulation; where necessary to protect our legal rights, interests and the interests of others, we process  personal data in  connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business; please note that we do not link your in-game activities to your Personal Data until it is necessary for the activities performed within this purpose of processing;
8. Public presentation of our Services on the basis of our legitimate interests within the meaning of Article 6 (1) (f) of the Regulation; our websites offer publicly accessible blogs, forums, bug trackers, wikis and videos from your play of our Game that you provide or make accessible to us. You should be aware that any information you provide in these websites may be read, collected, and used by any member of the public who accesses the websites. We urge you to consider the sensitivity of any information you input into our Services. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why;
9. Sharing your Personal Data with our partners for the marketing purposes on the basis of your consent within the meaning of Article 6 (1) (a) of the Regulation; if you consented to it and you have reached the legal age for consent (at least 15 years of age in the Czech Republic), we may share your Personal Data with our partners specified in each individual consent for the marketing purposes, such as dissemination of promotional and marketing communication about new features, projects, games, survey requests, newsletters or events of our partners.

For the above-mentioned purposes, we process your Personal Data as listed in more detail in Section 2 above, in the following extent:

In some cases, we may also process your Personal Data for other purposes, for example, when we obtain a consent from you to process your Personal Data. In such cases, the purpose of the processing and other related information is provided to you through a separate consent document.

4. Retention period

We generally store Personal Data as long as necessary to fulfill the respective purpose of the processing. We will process your Personal Data depending on the legal basis of the processing and the purpose of the processing:

1. for the duration of the contract (i.e. the period you use the Services) with you and then for a period of 6 months from the end of the contract with you in case of purposes under Section 3 letters a), b), c), d), e);
2. for the duration of relevant legal obligation in case of purpose under Section 3 letter f);
3. for the period for which the Personal Data is published in the respective channel, i.e. until their removal is requested by you or decided by us in case of purpose under Section 3 letter h);
4. until the relevant claims are time-barred, however, no later than 10 years in the case of purpose under Section 3 letter g) above;
5. until the consent is withdrawn in case of purpose under Section 3 letter i).

5. Personal Data Recipients

Personal data will be accessible only to our employees, processors of Personal Data and other controllers whom we might engage during provision of our services only to the extent necessary to achieve the above-mentioned purposes of processing, such as:

• Vendors and service providers: We may share your Personal Data with our vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, and web analytics services. In accordance with our instructions, these parties will access, process, or store Personal Data as our data processors only in the course of performing their duties to us. The updated list of these data processors may be requested from us at any time. Additionally, we need to share data with Elastic to ensure that our Game can function properly. To know more about how Elastic treats the data received from us, please visit: and  https://www.elastic.co/trust/security-and-compliance.
• Affiliates: We may disclose Personal Data to our affiliates, meaning the entities that control, are controlled by, or are under common control with Keen, especially GoodAI Research s.r.o., GoodAI Games s.r.o. and Oranzerie s.r.o., for the internal administrative purposes within our group. Our affiliates process the Personal Data we share in a manner consistent with this Privacy Policy.
• Partners: We may share your Personal Data with our partners specified in each individual consent in case you consented to it as described in Section 3 letter i).

Furthermore, we may also share your Personal Data with third parties in following cases:

• Business transfers: In case we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (hereinafter referred to as the “Transaction“), your Personal Data may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal requirements: We may share your Personal Data e.g., with courts, law enforcement authorities or other public authorities in case we are required to do so by law or when we are in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

6. Your rights

Any data subject and other natural person whose Personal Data may be processed within the framework of the Services has the following rights which may be exercised at any time:

• The right to access your Personal Data: if you wish to know whether, how and to what extent we are processing your personal data you have the right to require such information from us. If we are processing your Personal Data, you have the right to access your Personal Data. In cases of unjustified, disproportionate or repetitive requests we may be entitled to charge you an adequate fee or to decline such request (this applies also to exercising your other rights below);
• The right to rectification of your Personal Data: if you feel that we are processing your Personal Data which is inaccurate or incomplete, you have the right to require the rectification or completion of such personal data. We will do so without undue delay with regard to our technical capabilities;
• The right to erasure of your Personal Data: in case you will request the erasure of your Personal Data we will do so where (i) the data is no longer necessary for the purposes for which it was collected or otherwise processed, (ii) the processing is unlawful, (iii) you will object to the processing and no overriding reasons for the processing of such Personal Data exist or (iv) further processing of the Personal Data is not required by a provision of law;
• The right to restriction of the processing of your Personal Data: where you will request the restriction of processing of your Personal Data we will make such data inaccessible, temporarily remove or retain the data or undertake other steps of processing which will be necessary in order to duly exercise your right;
• The right to data portability: if you want us to hand over your Personal Data to a third party you can exercise you right to data portability. Where the exercise of this right would adversely affect the rights and freedoms of other persons we are entitled to limit or refuse your request.
• Right to withdraw consent: you have the right to withdraw your consent with processing of Personal Data at any time. However, the withdrawal of consent does not affect the lawfulness of processing based on consent given before the withdrawal.
• The right to object: the right to object the processing of your Personal Data concerns any Personal Data processed for the performance of a task carried out in the public interest or in the exercise of official authority or for the purposes of our legitimate interests. Where we will not be able to provide a legitimate ground for the processing which overrides your interests or fundamental rights and freedoms we will terminate the processing of Personal Data on the basis of the objection without undue delay.
• Right to obtain human intervention in case of automated decision making: in case of automated decision making, you have a right to obtain human intervention on our part and to express your point of view and to contest the decision.
• Right to file compliant: if you want to file a complaint regarding the processing of your Personal Data by us, you can do so with the local data protection authority which is:

Úřad pro ochranu osobních údajů
Pplk. Sochora 27, 170 00 Praha 7, the Czech Republic
Email: posta@uoou.gov.cz
Webpage: www.uoou.gov.cz

If you want to exercise any of your rights please feel free to contact us via contacts stated in Section 1 of this document. At instances where you want to exercise the above outlined rights we are reserving the right to verify your identity in a suitable manner.

7. Links to other websites

The Service may contain links to other websites that are not operated or controlled by Keen, including social media services (hereinafter referred to as the “Third Party Sites“). The information that you share with Third Party Sites will be processed by Third Party Sites and the processing will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. When we do, we will post an updated version on our website. Please pay attention to the new version of Privacy Policy and learn about the changes to always have accurate information about processing of your Personal Data.