Reto Moto – Dismissed (Denmark, 2022)

The data subject is a computer gamer. The controller Reto Moto ApS, a Danish game developer. During the game experience, the data subject displayed an undesirable behaviour and was accused of breaking the game's code of conduct. In other words, according to the controller, the data subject was suspected of cheating. It is not clear from the decision if the data subject was banned from the game. On 30 May 2019, the data subject filed an access request at the controller pursuant to Article 15 GDPR. It is not clear from the decision what the data subject specifically requested. In its response, on 26 June 2019, the controller clarified that data about game replay, anti-cheat related information, server logs and in-game chat messages would not be disclosed to the data subject. On 28 June 2019, the data subject informed the controller that the reply was incomplete in his opinion. According to the data subject, anti-cheat information was usually really private information, since anti-cheat software usually contains techniques that are used to get an exceptional level of access to a computer. The data subject had no control over the software once it was installed. The data subject was also of the opinion this anti-cheat information contained personal data, and was therefore subject to the GDPR. On 26 June 2019, the controller confirmed that it had answered to the access request. The controller also confirmed that it did not provide the Game replay data, Server logs, anti-cheat information and In-game chat messages. The controller stated that it did not provide a copy of the game replay data and the server logs because the controller had deleted these before receiving the data subject's access request. The controller also explained that it did not provide access to the anti-cheat information, because this could harm the controller and other players. This information, it was argued, constituted a technical log with data explaining why the data subject should be