Provision record
Steam · Steam Privacy Policy · View original document ↗

Data Privacy Framework (DPF) Certification for EU/UK/Swiss Data Transfers

Medium severity Rare · 1 of 352 platforms
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Document Record

What it is

Valve has certified under the EU-U.S. Data Privacy Framework, meaning it has committed to specific data protection standards when transferring your personal data from the EU, UK, or Switzerland to its US servers. If Steam's privacy policy ever conflicts with these Framework principles, the Framework principles win.

This analysis describes what Steam's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes Valve's regulatory certification status for transatlantic data transfers and creates a hierarchical governance structure where DPF Principles take precedence over the privacy policy in the event of inconsistency. This affects the legal framework applicable to personal data processing from EU, UK, and Swiss users.

Clause Stability Stable

0
Changes
4
Months Monitored
Apr 18, 2026
First Seen
Apr 18, 2026
Last Seen
This clause type exists across 1 other provision on other platforms.

Consumer impact (what this means for users)

EU, UK, and Swiss users' personal data is transferred to Valve's US infrastructure under the DPF certification framework, which provides some protections but remains subject to ongoing legal challenges regarding US surveillance law access to transferred data.

How other platforms handle this

Auth0 Medium

Okta operates globally and may transfer your personal data to countries outside of your home country, including the United States, which may not provide the same level of data protection as your home country. Where required by applicable law, we use Standard Contractual Clauses or other appropriate ...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Valve and its subsidiary TR Technical Inc. comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Valve has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.

Excerpt from Steam's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY FRAMEWORK: This provision directly implicates GDPR Art.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Steam Privacy Policy
Entity
Steam
Document last updated
May 5, 2026
Tracking information
First tracked
April 18, 2026
Last verified
April 18, 2026
Record ID
CA-P-002927
Document ID
CA-D-00182
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
63210b28892392d9dae07097221e6ab8458f850d4edd68ce4be0bc540f120bb5
Analysis generated
April 18, 2026 10:57 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Steam
Document: Steam Privacy Policy
Record ID: CA-P-002927
Captured: 2026-04-18 10:57:26 UTC
SHA-256: 63210b28892392d9…
URL: https://conductatlas.com/platform/steam/steam-privacy-policy/provision/CA-P-002927/data-privacy-framework-dpf-certification-for-euukswiss-data-transfers/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Steam's Data Privacy Framework (DPF) Certification for EU/UK/Swiss Data Transfers clause do?

This provision establishes Valve's regulatory certification status for transatlantic data transfers and creates a hierarchical governance structure where DPF Principles take precedence over the privacy policy in the event of inconsistency. This affects the legal framework applicable to personal data processing from EU, UK, and Swiss users.

How does this clause affect you?

EU, UK, and Swiss users' personal data is transferred to Valve's US infrastructure under the DPF certification framework, which provides some protections but remains subject to ongoing legal challenges regarding US surveillance law access to transferred data.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with Steam?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Steam.