Do I need to disclose Steamworks in my privacy policy?

Yes. Because Steamworks collects and processes personal data through Steam account integration, authentication, and gameplay tracking, you must disclose it in your privacy policy. This includes explaining that user data is transmitted to Valve Corporation and how Steam IDs, profile information, and playtime data are used.

What specific data does Steamworks collect?

Steamworks collects Steam ID, profile data, achievements, playtime metrics, friends list information, Workshop and user-generated content data, and purchase and DLC history. This data is automatically collected when users link their Steam accounts or play games integrated with Steamworks.

Does Steamworks require a cookie consent banner?

No dedicated cookie consent is required for Steamworks itself, as Steamworks primarily uses Steam account authentication rather than cookies. However, you must still obtain consent for any other tracking technologies on your website per GDPR or CCPA requirements, and disclose Steamworks data processing in your privacy policy.

Who processes Steamworks data and where is it stored?

Valve Corporation, a United States-based company, is the data processor. User data collected through Steamworks is transferred to and processed by Valve's servers in the US. Valve's privacy terms govern this processing, and you should link to https://store.steampowered.com/privacy_agreement/ in your policy.

Gaming

Privacy policy clauses for Steamworks

Steamworks is Valve's backend platform for PC game distribution, player authentication, and community features. Websites integrate Steamworks to enable Steam account login, track player achievements, manage in-game purchases, and facilitate user-generated content sharing through the Steam Workshop.

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What data Steamworks collects

Your privacy policy must disclose each of the following data types when you use Steamworks.

Steam ID and profile data

Achievements and playtime

Friends list and social features

Workshop and UGC data

Purchase and DLC history

When does Steamworks trigger privacy obligations?

Installation and activation

Steamworks integration triggers data protection obligations the moment you initialize the Steamworks SDK or embed Steam authentication on your game or application. At that point, Valve begins collecting Steam ID, profile data, playtime metrics, and achievement data through your application. If you use Steam's social features (friends lists, multiplayer lobbies), workshop functionality, or link to the Steam store, additional personal data flows activate immediately.

Applicable regulations

Common compliance pitfalls

Pitfall 1: Unclear data subject rights mapping between Steam ID and user identity

Many indie teams integrate Steamworks but fail to map Steam IDs back to identifiable individuals in their own systems. This creates a compliance crisis under GDPR Article 17 (right to erasure) and CCPA Section 1798.105 (deletion). When a user requests deletion, teams cannot reliably identify which playtime records, achievements, or UGC submissions belong to that user across their backend logs. Consequence: regulators classify this as failure to honor deletion requests, risking fines and enforcement action. Mitigation requires maintaining a clear audit table linking Steam ID ↔ internal user account ↔ email, and testing deletion workflows before launch.

Pitfall 2: Missing DPA with Valve or misclassifying Valve's role

Many teams treat Valve as merely a "third party" and fail to execute a Data Processing Agreement (GDPR Article 28), or they incorrectly assume Valve is a joint controller rather than a processor. Steamworks' privacy agreement (https://store.steampowered.com/privacy_agreement/) documents Valve's processing, but does not substitute for a formal DPA specifying processor obligations: data location, sub-processor approvals, deletion timelines, and security measures. Consequence: DPA breach (a GDPR Article 32 violation), exposing you to direct fines even if Valve's security is sound.

Pitfall 3: Insufficient disclosure of workshop/UGC data flows

Workshop uploads and user-generated content (mods, screenshots, profile data) create secondary data flows that are frequently omitted from privacy notices. Players upload content expecting privacy, but Steamworks transmits this to Valve's servers and may display it publicly. If your privacy notice does not explicitly name "workshop uploads" or "UGC data" as collected, you violate GDPR Article 13 (transparency) and CCPA Section 1798.100 (category disclosure). Consequence: transparent breach of transparency requirements; regulators often flag this as a first finding.

Privacy policy clauses for Steamworks

What data Steamworks collects

When does Steamworks trigger privacy obligations?

Installation and activation

Applicable regulations

First concrete step

Where data goes

Common compliance pitfalls

Pitfall 1: Unclear data subject rights mapping between Steam ID and user identity

Pitfall 2: Missing DPA with Valve or misclassifying Valve's role

Pitfall 3: Insufficient disclosure of workshop/UGC data flows

Legal note

Sample privacy policy clause

What regulators look for

GDPR enforcement priorities

CCPA enforcement priorities

FTC (US federal)

Frequently asked questions

Do I need to disclose Steamworks in my privacy policy?

What specific data does Steamworks collect?

Does Steamworks require a cookie consent banner?

Who processes Steamworks data and where is it stored?

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