Privacy Policy & End User License (EULA) Agreement for Twisted Works Game (TWG)

 

TWG - Privacy Policy

 

Version: v0.1 - Pre-Announce
Effective Date: 8 September 2025

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Platforms: PlayStation Store (PS5), Steam Store
Applies to: The TWG platform store presence only, no playable build available. Excludes twistedworks.com, which is covered by Website Privacy Policy.
Regions: Worldwide

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Key Points at a Glance

• No in-product personal data is collected; the game is not playable yet.

• Platform account data and wishlists are controlled by the platform providers as independent controllers, Sony Interactive Entertainment for PSN, and Valve for Steam.

• No telemetry, crash reports, analytics, user-generated content, or account linking at this stage.

• No sale of data, no advertising SDKs, no ad profiling.

• UK GDPR rights apply, including access and deletion.

• An EU or UK representative will be appointed if legally required.

• Contact: dataprotection@twistedworks.com

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1. Who we are, controller and contact

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Controller: Twisted Works Ltd
Registered company number: 15791216
Registered address: 3rd Floor, 86 to 90 Paul Street, London, United Kingdom, EC2A 4NE
Privacy contact: dataprotection@twistedworks.com
DPO or Privacy Lead: [Not applicable]
EU Representative, Article 27, if required: [●]
UK Representative, if required: [●]

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If we begin collecting personal data from individuals in the EEA while not established there, we will appoint an EU representative under Article 27 GDPR and update this policy. If we begin collecting from the UK without a local presence, we will appoint a UK representative.

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2. What we collect

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Negative collection, pre-launch: TWG is not yet playable. Twisted Works does not collect any in-product personal data. Platform account data, wishlists, follows, and store interactions are handled by the platform providers as independent controllers under their terms and privacy notices, Sony Interactive Entertainment for PSN and Valve for Steam.

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Excluded scope: this policy does not cover websites or cookies. For website processing, see Website Privacy Policy. Future in-game categories, to be added before any playable build: gameplay telemetry, crash or diagnostics logs and performance metrics, user-generated content and in-game reports, online identifiers received from platforms where provided, server and security logs, and support tickets.

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3. Sources of data

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• Platform providers, independent controllers, SIE manages PSN account and wishlist data, Valve manages Steam account and wishlist data

• Twisted Works, in product, none collected pre-launch

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4. Purposes and legal bases

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No in-product processing is carried out pre-launch. If we begin any processing for tests or a playable build, we will update this policy and present a clear table of purposes and legal bases before processing begins.

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Legal and regulatory requests: To the extent we receive a lawful request relating to platform data, we handle it in accordance with our legal obligations, coordinating with SIE or Valve as appropriate.

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5. Sharing and disclosure

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• Independent controllers, PSN data is controlled by Sony Interactive Entertainment, Steam data is controlled by Valve

• Processors, none engaged for in product data pre-launch

• Legal disclosures, we may disclose information where required by law

• No sale, no third-party advertising SDKs

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6. International transfers

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Not applicable pre-launch, no in-product transfers. Suppose gameplay processing involves transfers in the future. In that case, we will use appropriate safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the EU Standard Contractual Clauses, and we will describe them here.

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7. Retention

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Not applicable pre-launch, no in-product personal data is retained. Retention schedules for telemetry, crash logs, user-generated content, and support data will be published before any playable build.

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8. Your rights

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UK GDPR rights apply, including access, rectification, erasure, restriction, portability, objection, and withdrawal of consent where consent is used. We may need to verify your identity. We aim to respond within one month.

You can complain to the UK Information Commissioner’s Office: https://ico.org.uk/make-a-complaint/

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9. Children and teens

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We rely on platform age gates. We do not knowingly collect data directly from under-18s pre-launch. We do not profile under-18s for marketing. We will continue to consider the UK Age Appropriate Design Code as features evolve.

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10. Security

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We maintain organisational and technical measures appropriate to the risk, including access controls and encryption in transit. Absolute security cannot be guaranteed. We will extend controls and transparency before any gameplay processing begins.

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11. Changes to this policy

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We will update this page and the changelog below. For material changes or when gameplay begins, we will provide clear notice and update platform store links.

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12. Contact us

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E-mail: dataprotection@twistedworks.com
Post: Twisted Works Ltd, 3rd Floor, 86 to 90 Paul Street, London, United Kingdom, EC2A 4NE

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13. Annexes

 

Annexe A, data map, pre-launch

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No in-product personal data is processed pre-launch.

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Annexe B, record of processing summary, pre-launch

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No in-product processing activities.

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Annexe C, Glossary

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• PSN Online ID: Your PSN account name is controlled by SIE

• Steam Account: Your Steam account identifiers are controlled by Valve

• User-generated content: content created by players, for example, text, media, or reports

• Telemetry: technical performance measurements

• Controller: the entity that decides why and how personal data is used

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14. Changelog

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• v0.1 - Pre-Announce, 8 September 2025

  • Initial pre-launch policy, platform-only scope, negative collection statement. Game Name redacted for TWG.​

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TWG - End User License Agreement 

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Version: v0.1 - Pre-Announce

Effective Date: 8 September 2025

Platforms: PlayStation Store (PS5), Steam Store

Applies to: Excludes twistedworks.com, which Website Privacy Policy covers.

Regions: Worldwide

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Key Points at a Glance

• No playable build is available; this EULA becomes effective when a build is supplied.

• Until then, platform terms govern the store pages, wishlists, and any pre-release interactions, PSN Terms of Service for PlayStation, and Steam Subscriber Agreement for Steam.

• Trailers and marketing assets are informational only and may change

• When effective, your licence will be personal, limited, revocable, non-transferable, and subject to platform rules

• Statutory consumer rights are preserved

• Privacy follows our game Privacy Policy and platform privacy policies

• Export control and sanctions compliance apply in all regions

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Acceptance
Installing, accessing, or using a playable build indicates acceptance of this EULA. If you do not agree, do not install or use the game. Access, purchases, subscriptions, and refunds are handled under the applicable platform terms and policies.

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1. Future effective licence grant

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Pre-launch, no licence is granted because no playable build or purchasable product is supplied. When a playable build or purchasable product of TWG is made available, Twisted Works Ltd grants you a personal, limited, revocable, non-transferable, non-sublicensable licence to download and use one copy on supported platforms linked to your platform account, including PlayStation systems via PSN and PCs via Steam, subject to the applicable platform terms and this EULA.

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2. Use restrictions

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You must not reverse engineer or decompile except where permitted by law. You must not use cheats, bots, exploits, or circumvent security or anti-cheat. You must not use the game or assets for commercial purposes, rentals, or pay-to-play venues without written permission. You must not engage in unlawful, harmful, or infringing behaviour.

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3. Online services and availability

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Online features may require a platform account and internet access. Availability is not guaranteed. Servers, online features, and content may be modified, suspended, or retired with reasonable notice where practicable.

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4. User generated content and community

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If features allow user-generated content, you must follow community standards and reporting rules. You grant Twisted Works a non-exclusive, worldwide, royalty-free licence to host, use, reproduce, modify, adapt, publish, and display your user-generated content in connection with operating and promoting the game and community, to the extent permitted by platform rules. You warrant that you own or have rights to your content. We may remove content that breaches this EULA, platform rules, or law.

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5. Gameplay capture and streaming

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Platform features may allow recording and streaming. Other users may see your platform identifiers and user-generated content. Respect others’ rights and comply with platform rules.

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6. Health and safety

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Review platform health and safety guidance. Stop playing if unwell. Take regular breaks. Photosensitive players may experience seizures.

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7. Data and privacy

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This EULA incorporates the Twisted Works Game Privacy Policy, and the applicable platform terms and privacy notices, including PSN Terms of Service and Steam Subscriber Agreement. Platform providers control platform account data and wishlists. This EULA does not govern Twisted Works websites. For website processing, see Website Privacy Policy.

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8. Third-party content and open source

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The game may include third-party components. Notices will be provided at a later date. Third-party services are provided by their owners without warranties from Twisted Works.

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9. Updates, patches and changes

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Client and server updates may be required. Features and content may change. Continued use after changes indicates acceptance of the updated terms.

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10. Termination

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You may terminate by uninstalling the game. We may suspend or terminate access for breaches of this EULA, platform terms, cheating, or unlawful activity. On termination, you may lose access to online features. We are not obliged to keep copies of user-generated content except where required by law.

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11. Warranty

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The game and related materials are provided as is and as available, subject to your statutory rights—no guarantee of error-free or uninterrupted service.

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12. Limitation of liability

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Nothing in this EULA limits or excludes liability for death or personal injury caused by negligence, fraud, or other liabilities that cannot be limited by law. To the extent permitted by law, we exclude indirect or consequential losses. For direct losses, our liability is capped at the amount you paid for the game, if any, or a reasonable sum where no price was paid, subject to mandatory consumer laws. For consumers in Australia, the Australian Consumer Law provides guarantees that cannot be excluded, restricted, or modified, and this EULA is to be read subject to those guarantees. For consumers in New Zealand, your rights under the Consumer Guarantees Act 1993 are preserved.

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13. Governing law and venue

This EULA is governed by the laws of England and Wales. Courts of England and Wales have jurisdiction, without affecting any mandatory local consumer protections.

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14. General

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If a term is unenforceable, the rest remains in force. No failure to enforce is a waiver. You may not assign this EULA except where required by law. We are not liable for events outside our reasonable control, force majeure. This EULA constitutes the entire agreement regarding the use of the game. Order of precedence: for PlayStation, the PSN Terms of Service control access, purchases, subscriptions, and refunds. For Steam, the Steam Subscriber Agreement controls access, purchases, subscriptions, and refunds. This EULA governs game use. English controls where a translation differs, subject to mandatory local consumer protections.

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15. Export and sanctions compliance

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You must comply with applicable export control and sanctions laws, including UK export controls, United States Export Administration Regulations, and UK, United States, and EU sanctions. You must not access or use the game where prohibited by law and must not make it available to persons or entities subject to sanctions or in embargoed territories.

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16. Contact details

Company: Twisted Works Ltd

Address: 3rd Floor, 86 to 90 Paul Street, London, United Kingdom, EC2A 4NE
Email: hello@twistedworks.com

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17. Changelog

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• v0.1 - Pre-Announce, 8 September 2025

  • Initial pre-launch launch EULA, future effective licence, platform precedence, website excluded. Game Name redacted for TWG.

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