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OFF THE GRID PRIVACY NOTICE

Last updated: May 9, 2024

This Privacy Notice describes how POSEIDON 133 PTE. LTD (“we”, “us”, “our”) collects, uses and processes personal data about you (“you”, “player”) received via the Off The Grid game (the “Game”). This Privacy Notice covers the personal data that is provided, collected, or generated when you access, use or subscribe to our Game, except where separate privacy policies or terms and conditions apply. This Privacy Notice applies to our Game and also explains the rights and choices you have with respect to this data, and how you can communicate with us. We are committed to safeguarding the privacy of our users.

Controller details:

POSEIDON 133 PTE. LTD

Registration number: 201502546D

Registered address: 39 Robinson Road #14-01 Robinson Point Singapore 068911

1. What information do we collect and for what purposes?

We process your personal data as described below:

  • Name and surname: we use this information to personalize user experience, verify the user's identity, and manage account details.
  • Email address: we use email addresses for contacting the user, sending transactional notifications, and marketing emails.
  • Login name: these details are used for securing and authenticating user access to their accounts. We do not process player passwords, players login via Epic Games and use their passwords there.
  • Country flag/geolocation data: this information helps provide localized content, enforce regional restrictions, and improve targeting for marketing campaigns.
  • Gaming statistics: we process gaming statistics to enhance user experience, provide personalized game recommendations, and improve game design.
  • Communication data: data from customer support interactions, surveys, and chats are used for responding to user inquiries, improving customer service, and gathering feedback to enhance services.
  • Automatically collected data/usage data: this includes activities on our Game and analytics; we use this data to optimize the Game and game performance, enhance security, personalize content, and analyze user behavior for business insights.
  • Payment information: payment information is processed to facilitate in-game purchases and subscriptions while ensuring transaction security. Please note that we do not process your credit card details as this information is processed by third-party payment service providers.
  • Device information: information about the type of device, operating system, IP addresses, and unique identifiers is used to optimize game performance for different systems and ensure compatibility, prevent, detect, and identify fraud and cheating.
  • Gameplay information: player progress, choices, avatars, and interactions are monitored to personalize gaming experiences, provide adaptive challenges, and manage in-game rewards.
  • Social media data: data from linked social media accounts is used to enhance user engagement, facilitate social features within the game, and cross-promote content across platforms.
  • Usage data and logs: access patterns and crash reports are used for troubleshooting, improving system stability, and refining game features based on user interaction.
  • Preference settings: custom settings are processed to remember user preferences for a tailored gaming experience.
  • Analytics data: metrics on user behavior and game performance are analyzed to guide product development decisions and marketing strategies.
  • Performance and diagnostic data: we collect device performance and error reports to maintain and improve the quality of our Game, ensuring optimal functionality and user satisfaction.

2. Sources of personal data

We obtain personal data from such sources:

  • Data subjects themselves: direct player data like account details, gameplay actions, and communications.
  • Third-party sources: data from advertisers, data brokers, social media, and marketing partners providing demographic and behavior patterns.
  • Partner service providers: data collected by partners handling payment processing, cloud hosting, customer support, and analytics.
  • Publicly available sources: data from public databases, social media profiles, and government databases.
  • In-game behavioral tracking: data on player movements, decisions, and interactions captured by game technologies.
  • Cross-platform integration: data from linking multiple gaming platforms and services.
  • Competitions and events: data from events, including contact information, gameplay stats, and images.
  • User surveys and polls: player data from surveys and polls for feedback and preference assessment.
  • Co-registries or co-marketing partnerships: data shared with partners during co-promotions.
  • Indirectly from interactions: data from interactions with digital services like forums and online communities.
  • Physical event attendance: data from physical event participants, like conventions and expos.

3. Purposes and legal bases of processing (Art. 6 GDPR)

1) Performance of the contract (Art. 6.1(b) GDPR)

We use the performance of the contract as a legal basis for the following processing activities:

  • to create and maintain your user account and public profile;
  • to allow you to connect and interact with other users and provide other social network features;
  • to allow you to review and manage your gaming statistics;
  • to communicate you about significant announcements about the Game or any user account you may create;
  • to process payments that you do for the use of the Game. Without this information, we will be unable to provide you with the Game functionality.

2) Consent (Art. 6.1(a) GDPR)

We collect your consent as a legal basis for the following processing activities:

  • to provide you with a smart matchmaking feature based on the information from your profile, location, and activity in the Game;
  • cookie or similar forms of tracking for marketing and analytics purposes;
  • to provide you with email and in-app newsletters and announcements, and to contact you about other products and service offers from us. You can withdraw your consent at any time. You can usually do it on the profile page. The withdrawal of consent will not affect the lawfulness of processing based on consent before.

Please note that for publishing other people’s personal data in your feed or otherwise in the Game you should obtain their consent or another applicable legal basis in accordance with Art. 6 GDPR.

3) Legitimate interests (Art. 6.1(f) GDPR)

We do the following processing activities in our legitimate interests:

  • improving the matchmaking algorithm based on user data;
  • analyzing our Game traffic and our marketing efficiency;
  • to improve your experience by personalizing the Game;
  • to allow you to manage your log session and prevent fraud activities;
  • to improve the Game’s usability;
  • to comply with the laws of non-EEA countries that apply to our activities, in particular those of the country where we are registered in, such as tax or accounting laws;
  • for fraud and cheating prevention.

4. Access to personal data by third parties

Your personal data will be disclosed to third-party services (providers) that we use:

  • Discord: Services – communications. Categories of personal to which data providers have access:
    • Communication data: handles in-game and platform communication data
    • Social media data: accesses linked account data for community management
  • Zendesk: Services – player support. Categories of personal to which data providers have access:
    • Communication data: manages customer support communications
    • Name and surname: for personalized support services
  • Epic Games: Services – store/accounts. Categories of personal to which data providers have access:
    • Name and surname: for account identification
    • Email address: for account management and communications
    • Login name and password: for account security
    • Credit card details or other payment information: processes transactions
  • Google Forms: Services - user data, feedback. Categories of personal to which data providers have access:
    • Communication data: collects user feedback through surveys and forms
  • Azure Data Explorer + PowerBI: Services - data analysis. Categories of personal to which data providers have access:
    • Automatically collected data/usage data: analyzes web and gameplay analytics
    • Gaming statistics: analyzes for performance and user engagement insights
    • Analytics data: metrics and performance analysis
  • PlayFab: Services – player data. Categories of personal to which data providers have access:
    • Gameplay information: manages player data including progress and statistics
    • Gaming statistics: stores and processes game performance data
  • Unity: Services – game servers. Categories of personal to which data providers have access:
    • Gameplay information: processes data related to player actions and in-game behavior
    • Device information: utilizes device capabilities for game performance
  • Digital Ocean: Services - hosting. Categories of personal to which data providers have access:
    • Automatically collected data/usage data: hosts services that process IP addresses and device information
  • Avalanche Subnet Fuji: Services – hosting. Categories of personal to which data providers have access:
    • Automatically collected data/usage data: involved in processing and hosting data related to user interactions on decentralized platforms
  • Azure: Services – hosting. Categories of personal to which data providers have access:
    • Automatically collected data/usage data: hosts servers that store user IP addresses, device information, and usage data
    • Analytics data: hosts data analysis tools
  • Brevo: Services – email marketing. Categories of personal to which data providers have access:
    • Automatically collected data/usage data: hosts servers that store user IP addresses, device information, and usage data
    • Analytics data: hosts data analysis tools
  • Xsolla: Services – payment provider. Categories of personal to which data providers have access:
    • Credit card details or other payment information: handles transactions and payment data
    • Email address: for transaction confirmations and billing issues
  • Easy Anti-Cheat: Services – anti-cheat service. Categories of personal to which data providers have access:
    • Device information: for fraud and cheating prevention

We will share your personal data, such as your avatar and other game-related data, with other POSEIDON 133 PTE. LTD’s services and apps:

We have contractors and subsidiaries in other countries, including those outside the European Economic Area, who may have access to your personal data. At the same time, in the cases when we pass your personal data to other persons, we ensure that your personal data is being protected and used only within the purposes specified in this Privacy Notice. This is achieved by using only certified services and products, signing data processing agreements for the protection of personal data with contractors and partners (including the Standard Contractual Clauses adopted by the European Commission and compliant with the EU data protection laws), as well as taking technical measures to ensure the information is protected when stored, used and while being processed and transferred.

Other disclosures

In addition to the disclosures for the purposes identified elsewhere in this Privacy Notice, we may disclose information about you:

  • if we are required to do so by law;
  • in connection with any legal proceedings;
  • to establish, exercise or defend our legal rights (including providing information for the purposes of fraud and cheating prevention);
  • to the purchaser or seller of any business or asset which we are selling or purchasing. Except as provided in this Privacy Notice, we will not sell, share or rent your information to third parties.

Third-party services

Our Game contains links to third-party services and platforms. We are not responsible for the content, terms and conditions or privacy policies of third-party websites.

We encourage users to be aware when they leave our Game and to read the privacy statements of the websites that collect personally identifiable information. Third-party websites may contain their own cookies. We are not responsible for their usage of cookies.

5. Retaining your personal information

We will store your personal information till it is necessary to carry out our obligations to you regarding the Game. We will not store your information if you delete your account or if we do not use it anymore for the purposes listed in this Privacy Notice. If you become inactive, we will delete your account and data 2 years after your last log session.

We may be subject to statutory laws that require us to retain data about payments we received from the users. To comply with such requirements, we will retain relevant information for the period of statutory obligations.

6. Your rights

You may exercise certain rights regarding your personal data, depending on your jurisdiction.

6.1. If you are a European Economic Area resident, you have the rights as follows:

  • The right to object against the processing of your information. If we process your information for our legitimate interests (e.g. for direct marketing emails or for our marketing research purposes), you can object against it. Let us know what you object against and we will consider your request. If there are no compelling interests for us to refuse to perform your request, we will stop the processing for such purposes. If we believe our compelling interests outweigh your right to privacy, we will clarify this to you.
  • The right to access your information. You have the right to know what personal data we process. As such you can obtain the disclosure of the data involved in the processing and you can obtain a copy of the information undergoing processing.
  • The right to verify your information and seek its rectification. If you find that we process inaccurate or out-of-date information, you can verify the accuracy of your information and/or ask for it to be updated or corrected;
  • Restrict the processing of your information. When you contest the accuracy of your information, believe we process it unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will stop processing your data (other than storing it) until we are able to provide you with evidence of its lawful processing;
  • The right to have your personal data deleted. If we are not under the obligation to keep the data for legal compliance and your data is not needed in the scope of an active contract or claim, we will remove your information upon your request.
  • The right to have your personal data transferred to another organization. Where we process your personal data on the legal basis of consent you provided us or on the necessity to perform a contract, we can make, at your request, your data available to you or to an organization of your choosing.

If you have given us your express consent to process your personal data, you can withdraw this consent at any time without penalty. Please note that this does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

You can complete requests by contacting us at [email protected].

If you believe that our use of your personal information violates your rights, you can lodge a complaint with your national data protection authority.

6.2. Notice to residents of Colorado, Connecticut, Utah, and Virginia

If you are a resident of Colorado, Connecticut, Utah, or Virginia, we have certain obligations, and you have certain rights with respect to your personal information, including:

  • the right to confirm whether the controller is processing the consumer’s personal information and the right to access such information;
  • the right to correct inaccuracies in personal information;
  • the right to delete personal information;
  • the right of data portability;
  • the right to opt out from targeted advertising;
  • the right to opt out from the sale of personal information.

In certain states, you also have the right to opt out from profiling in furtherance of decisions that produce legal or similarly significant effects on the consumer (such as Virginia, Colorado, and Connecticut) and appeal a decision regarding a request to exercise your rights.

If you wish to exercise one or more of these rights, please contact us at [email protected].

6.3. Notice to residents of California

In addition to the information described in the Privacy Notice, the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2021) (the “CCPA”) also requires us to provide California consumers with some additional information related to how we collect, use, retain, and disclosed personal information, as well as describe additional rights, which are summarized below.

How we collect, use, and share your personal information under the CCPA

Categories of personal information which we may collect, use, and disclose for our business and commercial purposes are described in Section 1 of the Privacy Notice.

The sources from which we collect information are described in Section 2 of the Privacy Notice.

The business and commercial purposes for which we collect and use this information are described in Section 3 of the Privacy Notice.

The categories of third parties to whom we “disclose” the information for a business purpose are described in Section 4 of the Privacy Notice.

California privacy rights

California consumers have certain rights with respect to their personal information. These rights include the following:

  • Right to opt out of “selling” or “sharing” certain personal information. You have a right to opt out from future “sales” or “sharing” of personal information. The CCPA requires us to describe the categories of personal information we sell to or share with third parties and how to opt out of future sales or sharing. The CCPA defines personal information to include internet or other electronic network activity information which includes identifiers, such as IP addresses, cookies IDs, and mobile IDs. The law also defines a “sale” or “share” broadly to include simply making data available to third parties in some cases. We do not sell your personal information and have not done so in the past 12 months. However, please note that we may share or provide access to third-party services as described in Section 4 of the Privacy Notice as necessary for the specified purposes.
  • Right to know or request categories of personal information. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information such as a list of the categories of personal information collected about you, and other related information such as the source of the information, categories of information shared or sold to third parties, and the purpose for such sharing. We have provided this information in this Privacy Notice.
  • Right to correct. You have a right to request correction of inaccurate personal information.
  • Right to request deletion. You also have a right to request that we delete personal information under certain circumstances, subject to certain exceptions.
  • Right to designate an authorized agent. You may designate an authorized agent to exercise some of your rights; however, in order to help protect the security of your personal information, the authorized agent must follow the same authentication procedures that are required if you exercise your rights without using an agent. We will verify requests made through authorized agents to help ensure the safety of your account and to comply with our policies and procedures.
  • Right against discrimination. You have a right to not be discriminated against for exercising your rights set out in the CCPA.
  • Right to notice. You have a right to receive notice of our practices at or before collection of personal information.
  • Additional information on exercising your rights. You have the right to exercise the rights listed above and in this Privacy Notice free of charge or penalty, but we may limit the number of requests you make or charge reasonable fees as legally permitted. You may exercise many of these rights yourself by adjusting your profile, or you can get in touch with us at [email protected].

Privacy contact. Please see our Privacy Notice for details on how to contact us if you have a privacy question, concern, or request.

7. Security of your personal data

We take necessary and sufficient organizational measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

The third-party tools and our team members are located in different countries, including those that are outside of the European Economic Area. When transferring personal data to third countries, we will ensure that appropriate safeguards for such transfers, such as Standard Contractual Clauses, are in place. To learn more, please contact us via the contact email [email protected].

Immediate access to the personal information is allowed only to our authorized employees involved in maintaining the Game. Such employees keep strict confidentiality and prevent unauthorized third-party access to personal information.

8. Changes to the Privacy Notice

We may update this Privacy Notice from time to time by posting a new version in our Game. We advise you to check this page occasionally to ensure you are happy with any changes. However, we will endeavor to provide you with the announcement about any significant changes.