Steam processes your personal data based on four legal justifications: because it needs to in order to run the service, because the law requires it, because it or a third party has a legitimate business interest, or because you consented. The 'legitimate interests' basis is the broadest and can be invoked without your explicit consent.
Valve can share and process your personal data under 'legitimate interests' without obtaining your explicit consent, meaning behavioral tracking, content recommendations, and third-party sharing can occur by default unless you actively object.
Cross-platform context
See how other platforms handle Legal Bases for Personal Data Processing and similar clauses.
Compare across platforms →The 'legitimate interests' basis (option c) allows Valve to process your data without your consent for a wide range of purposes — including sharing with third parties — as long as Valve determines its interests aren't overridden by yours, which gives the company significant discretion over your data.
REGULATORY FRAMEWORK: This provision directly engages GDPR Art. 6(1)(a) (consent), Art. 6(1)(b) (contractual necessity), Art. 6(1)(c) (legal obligation), and Art. 6(1)(f) (legitimate interests). For legitimate interests, GDPR Art. 6(1)(f) requires a three-part balancing test (purpose, necessity, balancing) documented in a Legitimate Interests Assessment (LIA). Recital 47 GDPR provides guidance. UK GDPR mirrors these requirements. Enforcement authority: EU DPAs and UK ICO.
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