Privacy Policy

Grown-Ups respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the California Consumer Privacy Act ("CCPA"), the European Union General Data Protection Regulation ("GDPR"), the UK GDPR, and the Swiss and EU Privacy Shield Frameworks.

1. Definitions

Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual ("Personally Identifying Information") or that can be connected to you indirectly by linking it to Personally Identifying Information. Grown-Ups also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Grown-Ups may share anonymous data, aggregated or not, with third parties (Developers & Payment Processors).

Other capitalized terms in this Privacy Policy shall have the meanings defined in the Steam Subscriber Agreement ("SSA").

2. Why Grown-Ups Collects and Processes Data

Grown-Ups collects and processes Personal Data for the following reasons:

a) where it is necessary for the performance of our agreement with you to provide a full-featured adult entertainment service and deliver associated Content and Services;
b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
c) where it is necessary for the purposes of the legitimate and legal interests of Grown-Ups or a third party (e.g. the interests of our other customers & developers), except where such interests are overridden by your prevailing legitimate interests and rights; or
d) where you have given consent to it.

These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).

3. The Types and Sources of Data We Collect

3.1 Basic Account Data

When setting up an Account, Grown-Ups will collect your email address and country of residence. You are also required to choose a user name and a password. The provision of this information is necessary to register a Grown-Ups User Account. During setup of your account, the account is automatically assigned a number (the "Grown-Ups ID", or “GUID” for short) that is later used to reference your user account without directly exposing Personally Identifying Information about you.
We do not require you to provide or use your real name for the setup of a Grown-Ups User Account.

3.2 Transaction and Payment Data

In order to make a transaction on Grown-Ups (e.g. to purchase Content and Services), you may need to provide payment data to Grown-Ups to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to Grown-Ups, which Grown-Ups will process and transmit to our chosen payment service provider (CentroBill) to enable the transaction and perform anti-fraud checks. Likewise, Grown-Ups will receive data from CentroBill for the same reasons.

3.3 Other Data You Explicitly Submit

We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others on Grown-Ups, e.g. in Grown-Ups Community Forums, chats, or when you provide feedback or other user generated content. This data includes:

  • Information that you post, comment or follow in any of our Content and Services;
  • Information sent through chat;
  • Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant or, in case of physical goods, shipping providers;
  • Information you provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details.

    3.4 Your Use of the Grown-Ups Website

    We collect a variety of information through your general interaction with the website, Content and Services offered by Grown-Ups. Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data.
    Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our services.

3.5 Your Use of Games and other Subscriptions

In order to provide you with services, we need to collect, store and use various information about your activity in our Content and Services. "Content-Related Information" includes your Grown-Ups ID, as well as what is usually referred to as "game statistics". By game statistics we mean information about your games' preferences.

3.6 Tracking Data and Cookies

We use "Cookies", which are text files placed on your computer, and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to help us analyze how users use our services, as well as to improve the services we are offering, to improve marketing, analytics or website functionality. The use of Cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our website.
When you visit any of our services, our servers log your IP address, which is a number that is automatically assigned to the network your computer is part of.

3.7 Content Recommendations

We may process information collected under this section 3 so that content, products and services shown on the pages of the Grown-Ups store and in update messages displayed when opening the Grown-Ups website can be tailored to meet your needs and populated with relevant recommendations and offers. This is done to improve your customer experience and provide you with handpicked content tailored to your tastes.
Subject to your separate consent or where explicitly permitted under applicable laws on email marketing, Grown-Ups may send you marketing messages about products and services offered by Grown-Ups to your email address. In such a case we may also use your collected information to customize such marketing messages as well as collect information on whether you opened such messages and which links in their text you followed.
You can opt out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the "unsubscribe" link provided in every marketing email. Alternatively, you can select what kinds of emails you wish to receive on the email setting page.

3.8 Information Required to Detect Violations

We collect certain data that is required for our detection, investigation and prevention of fraud, cheating and other violations of the SSA and applicable laws ("Violations"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on of such Violations and stored only for the minimum amount of time needed for this purpose. If the data indicates that a Violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such Violations.

4. How Long We Store Data

We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.

In particular:

  • If you terminate your Grown-Ups User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.
  • Please note that Grown-Ups is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
  • If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

5. Who Has Access to Data

Grown-Ups does not sell Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for the following business purposes.

5.1 Grown-Ups and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in section 2 above. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.

5.2 We may also share your Personal Data with our third party service providers that provide customer support services in connection with goods, Content and Services distributed via Grown-Ups. Your Personal Data will be used in accordance with this Privacy Policy and only as far as this is necessary for performing customer support services.

5.3 In accordance with internet standards, we may also share certain information (including your IP address and the identification of Steam content you wish to access) with our third party network providers that provide content delivery network services and server services in connection with the Grown-Ups Store. Our content delivery network providers enable the delivery of digital content you have requested, e.g. when using Grown-Ups Store, by using a system of distributed servers that deliver the content to you, based on your geographic location.

5.4 Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on servers in the United States.
On this website, IP anonymization has been activated. The IP addresses of users visiting Grown-Ups will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and shortened there. On behalf of the website operator, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Google will not associate the IP address transferred in the context of Google Analytics with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that in this case you may not be able to use the full functionality of this website. You can learn more about how Google Analytics collects and uses data at
Furthermore, you can prevent Google's collection and processing of data about your use of the website, by downloading and installing the browser plug-in through the following link:

5.5 We make certain data related to your Grown-Ups User Account available to other players and our partners through the Steamworks API. This information can be accessed by anyone by querying your Grown-Ups ID. At a minimum, the public persona name you have chosen to represent you on Grown-Ups and your Avatar picture are accessible this way, as well as whether you have received a ban for breaking the code of conduct. The accessibility of any additional info about you can be controlled through your user profile page; data publicly available on your profile page can be accessed automatically through the Steamworks API. In addition to the publicly available information, game developers and publishers have access to certain information from the Steamworks API directly relating to the users of the games they operate. This information includes as a minimum your ownership of the game in question. Depending on which Grown-Ups Store services are implemented in the Grown-Ups Store, this may also include leaderboard information, achievements you have completed, your Title and other information needed to operate the game and provide support for it. For more information on what Grown-Ups services a specific game has implemented, please review its store page.
While we do not knowingly share Personally Identifying Information about you through the Steamworks API such as your real name or your email address, any information you share about yourself on your public Steam Profile can be accessed through the Steamworks API, including information that may make you identifiable.

5.6 The Grown-Ups community includes message boards, forums and/or discord chat servers (area), where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available online; therefore, you are doing so at your own risk. If your Personal Data is posted on one of our community forums against your will, request its removal by contacting Grown-Ups support.

5.7 Grown-Ups may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.

6. Your Rights and Control Mechanisms

The data protection laws of the European Economic Area, United Kingdom, California, and other territories grant their residents certain rights in relation to their Personal Data. While other jurisdictions may provide fewer statutory rights, we make the tools designed to exercise such rights available to our customers worldwide. (When we talk about the GDPR in this section, we mean the version of the GDPR that applies to you in the EU or UK).

As a resident of the European Economic Area or United Kingdom you have the following rights in relation to your Personal Data:

6.1 Right of Access.

You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access your Personal Data through contacting support. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.

6.2 Right to Rectification.

If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided by counting support.

6.3. Right to Erasure.

You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion. For individual items of Personal Data please request the deletion via the Grown-Ups support page.

As a result of deleting your Grown-Ups User Account, you will lose access to the Grown-Ups Store services, including the Grown-Ups User Account, Subscriptions and game-related information linked to the Grown-Ups User Account and the possibility to access other services you are using the Grown-Ups User Account for.

We allow you to restore your Grown-Ups User Account during a grace period of 30 (thirty) days from the moment you request deletion of your Steam User Account. This functionality allows you not to lose your account by mistake, because of your loss of your account credentials or due to hacking. During the suspension period, we will be able to finalize financial and other activities that you may have initiated before sending the Grown-Ups User Account deletion request. After the grace period, Personal Data associated with your account will be deleted subject to section 4. above.

6.4 Right to Object.

When our processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR / section 2.c) of this Privacy Policy, you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.

6.5 Right to restriction of processing of your Personal Data

You have the right to obtain restriction of processing of your Personal Data under the conditions set out in article 18 of the GDPR.

6.6 Right to Personal Data portability

You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller under the conditions set out in article 20 of the GDPR.

6.7 Right to Post-Mortem Control of Your Personal Data

If French data protection legislation is applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of Personal Data after your death in accordance with article 40-1 of the Act No 78-17 of 6 January 1978 on Information, Technology, Data Files and Civil Liberties.

7. Children

Children are not allowed under any circumstances to create a Grown-Ups User account. The minimum age to create a Grown-Ups User Account is 18. Grown-Ups will not knowingly collect Personal Data from persons under this age. Grown-Ups encourages parents to instruct their children to never give out personal information when online.

8. Contact Info

You can contact Grown-Ups at the address below.

While we review any request sent by mail, please be aware that to combat fraud, harassment and identity theft, the only way to access, rectify or delete your data is through contacting Grown-Ups support.

Gonzagagasse 13
1010 Wien


9. Additional Information for Users from the European Economic Area, U.K., and Switzerland

We may transfer and store your personal information outside the European Economic Area or United Kingdom, in countries which may not have equivalent data protection law. If we do so, we will take steps to ensure your personal information is protected by appropriate legal safeguards, like EU or UK standard contractual clauses, and that it is treated securely and in accordance with this privacy policy.

Although the EU-U.S Privacy Shield and the Swiss-US Privacy Shield have been ruled invalid as a legal basis for data transfers to the U.S. Grown-Ups GMBH, continues to comply with the Privacy Shield Principles with respect to any Personal Data transferred from the EU, UK, and Switzerland to the United States in reliance on the Privacy Shield. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

10. Additional Information for Users from California

The CCPA grants California residents certain privacy rights regarding the Personal Data we collect. We are committed to respecting these rights and complying with the CCPA. The following explains these rights and Grown-Ups's practices with respect to them.

Right to Know. Under the CCPA you have the right to request that we disclose to you what Personal Data we collect, use, disclose, and sell.

Right to Request Deletion. You also have the right to request deletion of Personal Data that is in our possession, subject to certain exceptions. Please note that your request to delete data may impact your use of the Grown-Ups Store service in some cases, and we may decline to delete information for reasons set forth in this Privacy Policy or as permitted by the CCPA.

Other Rights. The CCPA also gives California residents a right to opt-out from the sale of their Personal Data. As described in section 5, we do not sell Personal Data and have not done so in the past 12 months. You also have a right to receive notice of our practices at or before collection of your Personal Data. Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

Exercising Your Rights. The primary means of accessing, managing or deleting your Personal Data is through contacting Grown-Ups support at, however, before providing access to, or deleting any, Personal Data, based on a request received via email, we will need to verify your identity utilizing the "Proof of Ownership" process described below:

Proof of Ownership is established by submitting payment information previously used on the account or providing retail product codes that have been activated through Steam.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

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