PRIVACY POLICY

Right of Access – You have the right to request information concerning if we process your Personal Data and if we do, you have the right to know what kind of Personal Data;

Right of Rectification – You have the right request that we correct and rectify any inaccurate or incomplete Personal Data concerning you;

Right to Erasure – You have the right to request that we delete your Personal Data. Note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights and comply with technical and legal requirements and constraints related to the security and operation of our Properties;

Right to Restriction of Processing – You have the right to request that we temporarily or permanently cease processing of some or all of your Personal Data;

Right to Data Portability – You have the right to receive a copy of your Personal Data for the purpose of transferring them to another service provider;

Right to not be the subject of Automated Decision Making – You have the right not to be subject to a decision based solely on automated processing. Including profiling, which produces legal effects on you or otherwise significantly affect you;

Right to Withdraw Consent – You may at any time withdraw your consent to the processing of any Personal Data based on your consent, without it affecting the lawfulness of any processing done before you withdrew your consent; and

Right to Object – You have the right to object to our processing of your Personal Data for a certain purpose or to object to your Personal Data being used for direct marketing.

We collect Identity Data. This includes your names, usernames, or similar identifiers as well as your titles and preferred genders.

We collect Contact Data. This includes your home address, email address, phone number and other data you provide Systemic Reaction with for the purpose of enabling contact.

We collect Transaction Data. This includes Details about payments you have made in or in association with the Properties and other details of products and services you have accessed or used throughout the Properties as well as purchases or orders made by you.We do not process or store any credit or debit card information or details on our servers. Such payments and information are processed by our trusted third parties on their payments servers and their privacy policy applies.

We collect Technical Data. This includes your internet protocol (IP) address, your login data, browser type and version, hardware information, time zone setting and location, browser plug-in types and versions, operating system and other technology on the device you use to access the Properties or communicate with us. In cases of the Properties malfunctioning on your device, technical data may also include specific device information, such as the location of the file on your device.

We collect Profile Data. This includes your username, password, preferences, feedback and survey responses.

We collect Usage Data. This includes information about how you use the Properties, such as time spent playing and which games.

We collect Marketing and Communication Data. This includes your preferences in receiving marketing and communications from us and our third-party partners.

We collect Aggregated Data. This includes statistical or demographic data derived from all users’ Personal Data, but which is not considered Personal Data in the eyes of the law due to the fact that this data no longer can be used to directly or indirectly reveal your identity. May comprise information from the other data categories, but in an aggregated and anonymized fashion.

We process your Identity, Contact, Transaction, Profile, Usage, Marketing and Communications and Technical Data for the Purpose of delivering relevant Properties’ content as well as related advertisements to you and measure or understand the effectiveness of the advertising we serve you. Our legal basis for this processing is: Necessary for our Legitimate Interests (to define types of users and to keep the Properties updated and relevant and to develop our business and inform our marketing and growth strategy).

We process your Identity and Contact Data for the Purpose of registering you as a user of the Properties. Our legal basis for this processing is: Performance of a contract with you.

We process your Identity, Contact, Transaction, Technical, Usage, Profile and Marketing and Communications Data for the purpose of making suggestions and recommendations to you about games, new content and other services available through the Properties that may be of interest to you. Our legal basis for this processing is: Necessary for our legitimate interests (to develop the Properties and its related products and services).

We process your Identity, Contact, Transaction and Marketing and Communications Data for the purpose of processing payments, fees and charges, verifying your identity and details of your payment method or credit card account, communicating with you regarding related information. Our legal basis for this processing is: Performance of a contract with you, Necessary for our legitimate interests (to process payments and verification purposes).

We process your Identity, Contact, Profile and Marketing and Communications Data for the purpose of managing our relationship with you including providing you access to the Properties, notifying you about changes to our terms of use or privacy policy, asking you to leave a review or take a survey and investigating complaints. Our legal basis for this processing is: Performance of a contract with you, Necessary to comply with our legal obligations, Necessary for our legitimate interests (to communicate with you for the purpose of measuring user satisfaction, interest and marketing).

We process your Identity, Contact, Technical and Usage Data for the purpose of administrating and protecting our business and our services such as support, reporting and hosting data, data analysis, system maintenance, testing and troubleshooting. Our legal basis for this processing is: Necessary to comply with a legal obligation, Necessary for our legitimate interests (for running our business, administering our CRM, providing administration and IT services, network security and to prevent fraud and in the context of a business reorganization or group reconstructing exercise).

We process your Identity, Contact, Usage, Marketing and Communications and Aggregate Data for the purpose of providing third party game developers with information about who engaged with their games and to what extent and to increase the value for both developers and players. Our legal basis for this processing is: Necessary for our legitimate interests (to provide increased value to exhibitors and attendees), Consent.

We process your Identity, Technical and Usage Data for the purpose of improving and correcting the Properties, bug-fixing, improving performance for different devices and operating systems, and to ensure optimal use.Our legal basis for this processing is: Necessary for the performance of a contract with you, Necessary for our legitimate interest (to ensure the functioning of the Properties which we provide, and ensure reasonable performance).

Other members of the Avalanche Group, or our affiliated companies, which may use this data to offer products and services to you consistent with the purposes identified in the Privacy Policy;

With vendors and partners engaged by Systemic Reaction to provide you with goods or services you have requested or online advertising selected by us;

To show to other users of the Properties such as usernames, leaderboards, and chat messages;

Third party service providers who have been appointed as data processors to perform functions and services on our behalf and who will be provided only with the necessary data to perform those services on our behalf, but who are not authorized to use such data for any other purposes (e.g. web hosting services, payment processing, information technology systems, customer relationship management, crash report analysis, publisher or developer revenue calculation and reporting, marketing, auditing and administration);

To our advisors or insurers in the event of a claim, dispute or otherwise when deemed necessary;

If we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations (including, but not limited to, stock exchange market rules), or in response to a request from a law enforcement authority or other government official; and

We reserve the right to transfer your Personal Data if we sell or transfer all or a portion of our business assets, in accordance with applicable law. We shall use reasonable efforts to direct the transferee to use your Personal Data in a manner consistent with this Privacy Policy, should such a transfer occur. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of the data.