Crayta Legals - Terms of Service and Privacy Policies

CRAYTA TERMS OF SERVICE

ISSUED BY UNIT 2 GAMES LIMITED ("UNIT 2", or "we" or "us").

Last updated 1st June 2021

Welcome to Crayta! Crayta is a game platform where you can play games and work collaboratively with other members of the Crayta community to create, share, play and publish your own games, content and other interactive experiences.

Crayta is a creation of Unit 2 Games Limited, a company registered in England and Wales located at 2 Jephson Court, Tancred Close, Leamington Spa, Warwickshire, CV31 3RZ, United Kingdom ("we" or "us"). We have set out below, in these Terms of Service ("Terms"), the terms on which we make Crayta available to you.

1. APPLICABLE TERMS

1.1 By downloading or streaming Crayta (as defined in clause 4.1.1), visiting the Crayta website and/or using any element of Crayta, you agree to these Terms. If you do not agree to these Terms, please do not register an account with Crayta or use Crayta.

1.2 In addition to these Terms, your use of Crayta will be governed by:

1.2.1 our Crayta Community Guidelines;

1.2.2 depending on which platform you access Crayta from, either Google Stadia's terms, rules and policies, available at https://stadia.google.com/tos and https://policies.google.com/terms or the Epic Games Store's terms, rules and policies, available at https://www.epicgames.com/store/en-US/eula and https://www.epicgames.com/site/en-US/community-rules; and

1.2.3 any other additional terms, policies or guidelines applicable to Crayta that we may give notice of to you.

2. AGE AND OPERATING REQUIREMENTS

2.1 You must be 13 or over to accept these Terms and to play Crayta.

2.2 Crayta can be accessed via a TV, laptop, desktop PC, mobile phone or certain other devices (handheld or otherwise) with video capabilities and access to the internet.

2.3 Crayta has not been developed to meet your individual requirements. Please check that the facilities and functions of Crayta (as described in these Terms and any supporting documentation and on Google Stadia or the Epic Games Store) meet your requirements.

3. ACCESSING AND PLAYING CRAYTA

3.1 Crayta is installed on Google Stadia's and the Epic Games Store's cloud-based servers and also uses servers operated by us. To access Crayta you need to log in (using your valid Google Stadia or Epic Games Store account, which must have permission to play Crayta) via any capable device.

3.2 If you download or stream Crayta onto any device not owned by you, you must have the owner's permission to do so. You will be responsible for complying with these Terms, whether or not you own the device.

3.3 You may not transfer your account to someone else, whether for money, for anything else or for free.

3.4 If you have reason to believe that your account is no longer secure, another Crayta user asks you to disclose details about your account or another user gains access to your account or your account details then please notify both Google Stadia or the Epic Games Store (as applicable) and our customer support team at crayta.com/support or support@crayta.zendesk.com.

4. GRANT OF LICENCE, UPDATES AND CHANGES

4.1 By downloading or streaming Crayta and agreeing to be bound by these Terms, we grant you a licence to:

4.1.1 use:

(a) (to the extent we have made it available to you) the Crayta platform and software, the data supplied within that software and any updates or supplements to it;

(b) the related online or electronic guidance and other documentation relating to Crayta; and

(c) the online game play, game creation, game development and game streaming functionality which you connect to via the Google Stadia, the Epic Games Store and Crayta software and the content we provide to you through it,

referred to collectively as "Crayta";

4.1.2 use or stream Crayta via your personal devices (including on platforms such as YouTube) and view, use and display Crayta on such devices for your personal purposes only;

4.1.3 play games and/or enjoy experiences available on Crayta;

4.1.4 interact and work together with other users of Crayta;

4.1.5 use Crayta to create, develop, modify, change, make derivative works of and/or grant licences of all types of content, including but not limited to games and/or experiences (and all assets, characters, names and other items in such games and/or experiences), avatars and other characters, digital clothing and other digital assets for avatars and other characters, software, scripts, graphics, gameplay, game design, photos, images, artwork, music, video, sound, audiovisual combinations, reviews, text, models (2D, 3D or otherwise), interactive features, names, usernames, logos, game/experience passes, digital content, items or abilities for use in games/experiences and other materials, works, items or content (standalone or in combination) ("Content") and any such Content created, modified, changed or otherwise developed in Crayta by you or any other user shall be referred to as "User Generated Content" or "UGC";

4.1.6 use pre-existing Content made available by us within Crayta ("Creation Assets") to interact with the Crayta platform and/or create, develop and modify games in Crayta;

4.1.7 use our virtual currency ("Crayta Credits") to purchase assets, consumables and cosmetic items for your avatars and other characters in the Crayta Store;

4.1.8 use any documentation to support your permitted use of Crayta;

4.1.9 receive and use any supplementary software code or update of Crayta incorporating "patches" and corrections of errors as we may provide to you.

4.1.10 copy, amend and share (within and outside the Crayta platform) Crayta tutorials solely in order to advertise, market and/or promote games or experiences you have created or set up on Crayta or to advertise, market and/or promote Crayta more generally; and

4.1.11 copy and use the Crayta trade mark and/or logo solely in order to advertise, market and/or promote games or experiences you have created or set up on Crayta or to advertise and/or promote Crayta more generally, provided that you will, where required by us in our sole discretion, cease to use the Crayta trade mark and/or logo and delete or otherwise remove any advertisements and marketing and promotional material which makes use of the same.

4.2 Crayta is provided for general entertainment and educational purposes only. Crayta does not offer advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of information obtained from Crayta. Although we make reasonable efforts to update the information provided by Crayta, we make no representations, warranties or guarantees, whether express or implied, that such information is accurate, complete or up to date.

4.3 We recommend that you back up any account login data used in connection with Crayta, to protect yourself in case of any issues you may experience with Crayta.

4.4 From time to time we may automatically update and/or change Crayta or make it temporarily unavailable in order to improve performance, enhance functionality, introduce new features, reflect changes to the operating system or address security issues.

5. Third Party Materials, Links and Services

5.1 Crayta may:

5.1.1 include Content, data, information or materials from third parties as advertising and promotional content; and/or

5.1.2 contain links or allow you to link to independent websites which are not provided by us (such as YouTube and social media platforms),

collectively referred to as "Third Party Content".

5.2 Such Third Party Content is not under our control, and we are not responsible for and have not checked and approved such Third Party Content or the privacy policies (if any) of the third parties providing such Third Party Content.

5.3 You will need to make your own independent judgement about whether to use any such Third Party Content, including whether to buy any products or services offered by them.

5.4 If you see any Third Party Content that appears to you to be inappropriate in any way, you can report such Third Party Content via the "Report a Game" section of the Help tab of the Settings menu within Crayta.

6. Licence Restrictions

6.1 You agree that you will::

6.1.1 not rent, lease, sub-license, loan, provide, or otherwise make available, Crayta in any form, in whole or in part to any person without prior written consent from us;

6.1.2 not copy Crayta, except as part of your permitted use of Crayta;

6.1.3 not translate, merge, adapt, vary, alter or modify, the whole or any part of Crayta, permit Crayta or any part of it to be combined with, or become incorporated in, any other programs, except as necessary to use Crayta on devices as permitted in these terms;

6.1.4 not disassemble, de-compile, reverse engineer or create derivative works based on the whole or any part of Crayta nor attempt to do any such things, except to the extent that (by virtue of sections 50B and 296A of the Copyright, Designs and Patents Act 1988) such actions cannot be prohibited because they are necessary to decompile Crayta to obtain the information necessary to create an independent program that can be operated with Crayta or with another program ("Permitted Objective"), and provided that the information obtained by you during such activities:

(a) is not disclosed or communicated without our prior written consent to any third party to whom it is not necessary to disclose or communicate it in order to achieve the Permitted Objective; and

(b) is not used to create any software that is substantially similar in its expression to Crayta;

(c) is kept secure; and

(d) is used only for the Permitted Objective; and

6.1.5 comply with all applicable technology control or export laws and regulations that apply to the technology used or supported by Crayta.

6.2 You must:

6.2.1 comply with our Crayta Community Guidelines;

6.2.2 not use Crayta in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with these terms, or act fraudulently or maliciously, for example, by hacking into or inserting malicious code, such as viruses, or harmful data, into Crayta;

6.2.3 not infringe our intellectual property rights or those of any third party in relation to your use of Crayta, including by the submission of or inclusion of any material or Content (to the extent that such use is not licensed by these Terms);

6.2.4 not transmit or include any material that is defamatory, offensive or otherwise objectionable in relation to your use of Crayta;

6.2.5 not use Crayta in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other users; and

6.2.6 not collect or harvest any information or data from Crayta or our systems or attempt to decipher any transmissions to or from the Crayta servers.

7. Crayta Credits

7.1 In accordance with clause 4.1.7, you will be entitled to use Crayta Credits within Crayta to enhance your user experience.

7.2 You may purchase Crayta Credits from Google Stadia and the Epic Games Store. Your Crayta account will be credited with any Crayta Credits you purchase from Google Stadia or the Epic Games Store.

7.3 We, Google Stadia and the Epic Games Store shall set the value of Crayta Credits and you acknowledge that we may, from time to time, engage in actions which impact the perceived or acquired price of Crayta Credits, for example by running flash sales or offering discounts on bulk purchases of Crayta Credits.

7.4 Crayta Credits:

7.4.1 do not:

(a) have an equivalent value in real currency;

(b) act as a substitute for real currency;

(c) act as legal consideration under any contract; or

(d) earn interest;

7.4.2 are not redeemable or exchangeable for real currency, monetary value, or convertible virtual currency from us or any other third party; and

7.4.3 must not be transferred, assigned, gifted or otherwise exchanged except within Crayta in accordance with these Terms.

7.5 Transactions involving the use of Crayta Credits to purchase items within Crayta are not legally enforceable.

7.6 We reserve the right to impose additional provisions on the ways in which you and other users are able to use Crayta Credits within Crayta in the future.

7.7 At present, you are not able to use Crayta Credits to purchase UGC within games from other users. However, if this changes in the future we will update our Terms accordingly to reflect this.

8. Payments

8.1 When you use Crayta Credits to purchase digital assets, consumables and cosmetic items for your avatars and other characters in the Crayta Store, you will be making payment for those items directly to us. We will debit your Crayta account with the relevant number of Crayta Credits at the time of purchase.

8.2 You may reverse up to three purchases of items from the Crayta Store where you make a purchase by accident or you change your mind about a particular purchase. If you wish to reverse a fourth or subsequent purchase, then you will need to do this via the "Refund" section of the Help tab of the Settings menu within Crayta.

9. Intellectual Property Rights

9.1 In this clause 9, "Intellectual Property Rights" or "IPRs" shall mean patents, utility models, rights to inventions, copyright and neighbouring and related rights, moral rights, trade marks and service marks, business names and domain names, rights in get-up and trade dress, goodwill and the right to sue for passing off or unfair competition, rights in designs, rights in computer software, database rights, rights to use, and protect the confidentiality of, confidential information (including know-how and trade secrets), and all other intellectual property rights, in each case whether registered or unregistered and including all applications and rights to apply for and be granted, renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world.

9.2 With the exception of UGC, all IPRs in Crayta itself (including but not limited to Creation Assets) belong to us (or our licensors) and the rights in Crayta are licensed (not sold) to you. You have no IPRs in, or to, Crayta, other than the right to use it in accordance with these Terms.

9.3 In respect of IPRs in any UGC which you create or develop:

9.3.1 (or help to create or develop) within another user's game or experience on Crayta ("Non-Owned UGC"), such IPRs will vest in the user in whose name the relevant game or experience was originally created or set up (the "Game Owner") and you therefore assign all IPRs in such Non-Owned UGC to the Game Owner;

9.3.2 (a) outside of Crayta which you subsequently import into Crayta; and/or (b) within your own game or experience in Crayta ("Owned UGC"), such IPRs will vest in you.

9.4 If you wish to make Owned UGC available for other users to use within their own games and experiences via the Community Content Browser, then you agree and acknowledge that by doing so you grant all other users a fully paid-up, worldwide, non-exclusive, royalty-free, perpetual and irrevocable licence to copy, modify and otherwise use such Owned UGC within their own games or experiences on Crayta.

9.5 You grant to us a fully paid-up, worldwide, non-exclusive, royalty-free, perpetual and irrevocable licence to copy, modify and otherwise use for our own purposes:

9.5.1 where you are a Game Owner, any and all Non-Owned UGC and all other IPRs in all games and/or experiences registered in your name; and

9.5.2 in all other circumstances, any and all Owned UGC vested in your name.

10. Privacy

10.1 Under data protection legislation, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data and how to exercise them. This information is provided in our Crayta Privacy Policy and Website Privacy Policy and it is important that you read that information.

10.2 Please be aware that internet transmissions are never completely private or secure and that any message or information you send using Crayta may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted.

10.3 By using Crayta, you agree to us collecting and using technical information about the devices you use Crayta on and related software, hardware and peripherals to improve Crayta and how we provide Crayta to you.

11. Our Liability to You

11.1 Crayta is provided to you on an "as is" basis and all warranties, representations, conditions and all other terms of any kind whatsoever implied by statute or common law are, to the fullest extent permitted by applicable law, excluded from these Terms.

11.2 We are responsible to you for foreseeable loss and damage caused by us. If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our failure to comply with these Terms or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time you accepted these terms, both we and you knew it might happen. Subject to clause 11.3, our total aggregate liability to you shall not exceed an amount equal to the total sum you have spent within Crayta (including purchases of different forms of Crayta and Crayta Credits).

11.3 We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors or for fraud or fraudulent misrepresentation.

11.4 Subject to clause 11.3, we shall not be liable whether in tort (including for negligence or breach of statutory duty), contract, misrepresentation, restitution or otherwise for any loss of profits, loss of business, depletion of goodwill and/or similar losses or loss or corruption of data or information, or pure economic loss, or for any special, indirect or consequential loss, costs, damages, charges or expenses however arising under these Terms.

11.5 If defective digital content that we have supplied damages a device or digital content belonging to you, we will either repair the damage or pay you compensation. However, we will not be liable for damage that you could have avoided by following manufacturer's advice or for damage that was caused by you failing to correctly follow installation instructions or to have in place the minimum system requirements advised by us or Google Stadia or the Epic Games Store.

11.6 Crayta is for domestic and private use. If you use Crayta for any commercial, business or resale purpose, we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

11.7 If our provision of Crayta or support for Crayta is delayed by an event outside our control then we will take steps to minimise the delay and will post information about the delay on our website at Crayta.com. Provided we do this we will not be liable for delays caused by the event but if there is a risk of substantial delay you may cancel your Crayta account.

12. We may end your Rights to use Crayta if you do not comply with these Terms

12.1 We may, at any time, by posting a message on your account inside Crayta:

12.1.1 end your rights to use Crayta;

12.1.2 suspend/delete your account; and/or

12.1.3 delete/remove any UGC created by you.

12.2 If we exercise any of our rights under clause 12.1:

12.2.1 all rights granted to you under these Terms shall immediately end; and

12.2.2 you must stop all activities authorised by these Terms, including your use of Crayta.

13. Changes to these Terms

13.1 We may need to change these Terms to, for example, reflect changes in law or best practice or to deal with additional features which we introduce.

13.2 We will give you notice of any major change by notifying you of a change when you next use Crayta.

13.3 If you do not accept the notified changes you will not be permitted to continue to use Crayta.

14. Support

14.1 If you want to learn more about Crayta please search for information about it on YouTube and social media channels.

14.2 If you have any problems using Crayta which cannot be reported inside Crayta then please contact our customer support team at crayta.com/support or support@crayta.zendesk.com.

14.3 If you think Crayta is faulty or misdescribed or wish to contact us for any other reason then please contact our customer support team at crayta.com/support or support@crayta.zendesk.com.

14.4 If we have to contact you we will do so by the means of communication you have indicated to us and using the contact details you have provided to us.

15. Other Terms

We may transfer this Agreement to someone else. We may transfer our rights and obligations under these Terms to another organisation. We will inform you via messaging inside Crayta and on Crayta.com if this happens and we will ensure that the transfer will not affect your rights under these Terms.

You need our consent to transfer your rights to someone else. You may only transfer your rights or your obligations under these Terms to another person if we agree in writing.

No rights for third parties. These Terms do not give rise to any rights to any third party under the Contracts (Rights of Third Parties) Act 1999 to enforce of these Terms.

If a court finds part of this contract illegal, the rest will continue in force. Each of the paragraphs of these Terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.

Even if we delay in enforcing this contract, we can still enforce it later. Even if we delay in enforcing these Terms, we can still enforce them later. If we do not insist immediately that you do anything you are required to do under these Terms, or if we delay in taking steps against you in respect of your breaking these Terms, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.

Which laws apply to these Terms and where you may bring legal proceedings. These terms are governed by English law. You may bring legal proceedings in respect of Crayta and/or these Terms in the English courts or the courts of your own jurisdiction.

Alternative dispute resolution. Alternative dispute resolution is a process where an independent body considers the facts of a dispute and seeks to resolve it, without you having to go to court. If you are not happy with how we have handled any complaint, you may want to contact the alternative dispute resolution provider we use. You can submit a complaint to the European Online Dispute Resolution platform ("ODR") via their website at ec.europa.eu/consumers/odr. The ODR will not charge you for making a complaint and if you are not satisfied with the outcome you can still bring legal proceedings.

© 2021 Unit 2 Games Limited. All trade marks are the property of the relevant owners. All rights reserved.

Crayta Game Privacy Policy

ISSUED BY UNIT 2 GAMES LIMITED ("UNIT 2", or "we" or "us").

Last updated: 3 June 2021

Welcome to Crayta's privacy policy. Crayta is owned and licensed by Unit 2 Games Limited.

Unit 2 Games Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use Crayta and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Unit 2 Games Limited collects and processes your personal data through your use of Crayta, including any data you may provide through Crayta or we may receive via Google Stadia or the Epic Games Store when you register an account, purchase Crayta Credits or otherwise use Crayta.

Crayta is not intended for anyone under the age of 13 and we do not knowingly collect data relating to anyone under this age.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. In particular, if you use our website (https://www.crayta.com/) or any of its sub-sites such as the play and create sub-site (https://play.crayta.com/ and https://create.crayta.com/), the forum sub-site (https://forum.crayta.com/) or our support sub-site (https://support.crayta.com/) (our "Website"), please refer to the Website Privacy Policy available here.

Controller

Unit 2 Games Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Unit 2 Games Limited

Email address: dataprotectionofficer@unit2games.com

Postal address: 2 Jephson Court, Tancred Close, Leamington Spa, Warwickshire, England, CV31 3RZ, United Kingdom

If you are located in the European Economic Area ("EEA") or United Kingdom ("UK"), you have the right to make a complaint at any time to your local supervisory authority, which in the UK is the Information Commissioner's Office (ICO), (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority, so please contact us in the first instance.

Changes to the privacy policy

We keep our privacy policy under regular review. If we make changes, we will update the "Last Updated" date at the top of this privacy policy. If we make material changes to this privacy policy, we will take any steps as required by applicable law. The updated privacy policy will be effective as of the time of posting, or such later date as may be specified in the updated privacy policy.

Third-party links

Crayta may include links to third-party websites, plug-ins and applications, including but not limited to Google Stadia and the Epic Games Store. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Crayta, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may process different kinds of personal data about you which we have grouped together as follows:

"Identity Data" includes title, first name and last name.

"Contact Data" includes your email address, mobile number and telephone number.

"Transaction Data" after you purchase in-game Crayta Credits (our in-game currency) through Google Stadia or Epic Games Store, we collect details about your use of those in-game Crayta Credits. For example, we collect details of items you have purchased from the Crayta Store using Crayta Credits and their cost. We do not process payment card information. Instead, you can make payments through Google Stadia and Epic Games Store and they will process your payment card information.

"Account Data" includes your unique Crayta account ID, Crayta username, your Google Stadia account ID/Epic Games Store account ID and username.

"Financial Data" includes your PayPal email address (please note this will only be processed as part of providing you with a prize when you partake in and win a prize draw or competition).

"Player Usage Data" includes information about how you use Crayta (e.g. what games within Crayta you have played and are playing, what players you have played with, etc.) and your IP address and general geographical region (e.g. Europe-West, US-Central, Asia-East) that you last played in.

"Gameplay Data" includes player data such as in-game performance, leaderboards, level and scores, character customisation, battle-pass and other platform entitlements.

"Settings Data" includes all in-game user settings such as settings relating to your preferences for: visual display, volume settings, voice chat and microphone, language and your chosen privacy setting for receiving group invites (i.e. whether everyone, only friends or no-one can send you group invites). It also includes your colour-blind mode and strength setting ("Accessibility Settings Data").

"Reports Data" includes any information in communications you make to us via in-game reports.

"Quickchat Data" includes pre-determined message phrases and pre-determined emojis which players can send to other players and your Crayta username.

"Creator Data" includes your Crayta ID and Crayta username, any images uploaded to our Website (see our Website Privacy Policy here for further details), names and descriptions of player created games and any other user generated content including packages (creations made by the player in a game).

"Technical Data" includes information used for authentication and details about technical issues in the game.

Other than Accessibility Settings Data, which could possibly be considered health data, and self-reported information submitted by applying for our Black Creators Prize Fund and Mentoring Programme, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the Crayta Terms of Service, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to Crayta). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data, Transaction Data, Reports Data, Quickchat Data and Creator Data by using Crayta, accessing our support service, giving us feedback, submitting a report, signing up for our marketing communications or when you otherwise correspond with us by phone, email or otherwise. By selecting your preferences in settings, you provide us with your Settings Data and Accessibility Settings Data.

Information automatically collected about you when you use Crayta. We create your Crayta ID when you first use Crayta. As you use Crayta, we will automatically collect Player Usage Data, Gameplay Data and Technical Data.

Third parties. We will receive personal data about you from Google Stadia / Epic Games Store. We collect your Google Stadia account ID/ Epic Games Store account ID and usernames as part of our account authentication process (where we also generate and provide you with a Crayta account ID).

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform our obligations under our Terms of Service, which form the contract between you and us when you create a Crayta account via Google Stadia or the Epic Games Store.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Where we have obtained your consent.

Where it is necessary to protect your vital interests or those of others.

Where it is necessary in the public interest.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user

Account

Performance of a contract with you

To enable you to use Crayta in accordance with our Terms of Service, for example by using your Account Data in high score tables within games

Transaction

Account

Player Usage

Gameplay

Settings (incl. Accessibility Settings)

Quickchat

Creator

Performance of a contract with you other than for Accessibility Settings Data where we rely on explicit consent.

To manage our relationship with you, including providing you with customer support in respect of Crayta

Identity

Contact

Account

Player Usage

Gameplay

Reports

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how our users use Crayta)

To enable you to use Crayta Credits to purchase items in the Crayta Store

Transaction

Account

Gameplay

Performance of a contract with you

To administer and protect our business and the Crayta platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Player Usage

Gameplay

Reports

Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To use data analytics to understand how you use and interact with Crayta, to improve Crayta, user relationships and your experiences of Crayta including recommending other Crayta games to you

CraytaID

Player Usage

Gameplay

Technical

Necessary for our legitimate interests (to define types of users of Crayta, to keep the Crayta platform updated and relevant, to develop our business and to inform our marketing strategy)

If you partake in/apply for our $25,000 monthly prize funds or our Black Creators Prize Fund and Mentoring Programme

Identity

Contact

Account

Financial (only if you win)

Name of your game created within Crayta

Confirmation that you are over 18

Self-reported information which is racial origin personal data

Performance of a contract with you

Necessary for our legitimate interests (to study how users use Crayta, to develop Crayta and grow our business)

For self-reported information which reveals your racial origin personal data, we rely on explicit consent

To provide you with special items to use within the Crayta platform where you have requested this.

Identity

Contact

Profile

Account

Gameplay

Performance of a contract with you

Necessary for our legitimate interests (for running our business, provision of administration and IT services, to develop Crayta and grow our business)

To deliver relevant marketing communications to you and measure or understand the effectiveness of the advertising we serve to you.

Identity

Contact

Consent

Necessary for our legitimate interests (to study how users use Crayta, to develop them, to grow our business and to inform our marketing strategy)

Marketing

Where you have provided us with your Contact Data in order for us to send marketing communications to you in return for us providing you with special items to use within the Crayta platform, you will receive marketing communications from us via our third party marketing email delivery service provider Twilio Inc. operating as SendGrid (based in the USA) unless you opt out of receiving such marketing.

Opting-Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Note that we may still send you announcements in relation to security, privacy or other administrative related communications that are not marketing orientated if you have opted-out to marketing, as we do not rely on consent for these communications so you may not opt-out.

Do Not Track

"Do not track" signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. Crayta does not respond to "do not track" signals in your web browser.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below including for the purposes set out in the table above.

Other users of Crayta (based globally), including those who are playing or have played the same games on Crayta as you or who you have otherwise connected with, will see your Crayta username and the game you are currently playing. If you are on any leaderboards, other players of Crayta will see your Crayta username and your game score.

Third party service providers (based both inside and outside the EEA/UK) who provide services to us such as IT and system administration services in respect of Crayta and our business, including, but not limited to:

Zendesk Inc. and BugSplat LLC (based in the USA) which provide customer support services on behalf of Crayta.

Keywords International (based in the USA) which provides content moderation services on our behalf.

Twilio Inc. operating as SendGrid (based in the USA) which provides marketing email delivery services on our behalf.

Google Stadia and Google Inc. (both based in the USA), Google Ireland Limited and Google Commerce Limited (both based in Ireland), all of which may provide the platform on which Crayta is provided to you.

Epic Games, Inc. (based in the USA) which may provide the platform on which Crayta is provided to you.

Google Cloud (based in the USA) which provides hosting services on behalf of Crayta.

Atlassian Pty Ltd (based in Australia) which provides Jira, a bug-tracking management software on behalf of Crayta.

Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may access, preserve, and disclose information associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We are based in the United Kingdom. If you are based in the EEA/UK our processing of your personal data will involve a transfer of data outside the EEA.

Some of our third party services providers as well as Google Stadia and Epic Games Store are also based outside the EEA/UK so their processing of your personal data will also involve a transfer of data outside the EEA/UK.

With respect to the degrees of protection we afford your personal data when we process it, please see section 7 "Data Security" below.

Whenever we transfer your personal data out of the EEA/UK to our external third parties, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us via dataprotectionofficer@unit2games.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA/UK.

7. Data security

We process your personal data in accordance with applicable data protection laws. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention – How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We retain your personal data until we or you decide to close or delete your Crayta account, at which time we will delete or anonymise all personal data we hold about you within 30 days.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at dataprotectionofficer@unit2games.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

© 2021 Unit 2 Games Limited. All trade marks are the property of the relevant owners. All rights reserved.

CRAYTA WEBSITE PRIVACY AND COOKIE POLICY

ISSUED BY UNIT 2 GAMES LIMITED ("UNIT 2", or "we" or "us").

Last updated: 22 June 2021

INTRODUCTION

Welcome to Crayta's website privacy policy. Our corporate website (https://unit2games.com/) and Crayta website (https://crayta.com/) including any sub-sites, such as the play and create sub-sites (https://play.crayta.com/ and https://create.crayta.com/) (our "Play/Create Website"), our forum sub-site (https://forum.crayta.com/) (the "Forum"), our developer sub-site (http://developer.crayta.com) (the "Developer Website"), our API sub-site (http://api.crayta.com) (the "API Website") and our support sub-site (https://support.crayta.com/) (the "Support Website") (together our "site(s)") are owned by Unit 2 Games Limited.

Unit 2 Games Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our site and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Unit 2 Games Limited collects and processes your personal data through your use of our site.

Crayta is not intended for anyone under the age of 13 and we do not knowingly collect data relating to anyone under this age.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. In particular, if you use play or create on Crayta, you are subject to the Crayta Privacy Policy available here.

CONTROLLER

Unit 2 Games Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

If you are located in the European Economic Area ("EEA") or United Kingdom ("UK"), you have the right to make a complaint at any time to your local supervisory authority, which in the UK is the Information Commissioner's Office (ICO), (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority, so please contact us in the first instance.

CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review. If we make changes, we will update the "Last Updated" date at the top of this privacy policy. If we make material changes to this privacy policy, we will take any steps as required by applicable law. The updated privacy policy will be effective as of the time of posting, or such later date as may be specified in the updated privacy policy.

THIRD PARTY LINKS

Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Crayta, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you and how we collect it

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may process different kinds of personal data about you which we have grouped together as follows:

Information you give us.

Forum: If you choose to register for an account on our Forum, we collect your name, email address, language preferences and profile picture from Google, as well as your Forum username. When you post or interact on our Forum, we receive and store these communications and details of your activity.

Support: When you send us a support request, we collect your name, email address, username you provide, platform (e.g. Epic Games Store or Google Stadia), and any other information you choose to include in your communication with us including any files you upload.

Play/Create Website: When you log-in to the Play/Create Website via your Google Stadia or Epic Games Store account, we obtain your Google Stadia or Epic Games Store account details. We receive and store any information that you provide associated with the games you have created on Crayta (e.g. game name, description, tags and any images uploaded). If you "like" a game on Crayta via the Play/Create Website, we also receive and store that information.

Prize Fund applicants and winners: If you win our $25,000 monthly prize funds, or apply for our Black Creators Prize Fund and Mentoring Programme we will request your full name, email address, confirmation that you are over 18, your Google Stadia username / Epic Games Store username / Crayta username, Google Stadia ID, Epic Games ID and Crayta ID and name of your game. If you win, we will collect your PayPal email address so that you can receive your prize. By applying for our Black Creators Prize Fund and Mentoring Programme, you self-report information which is racial origin personal data, which is a special category of personal data.

Other enquiries. We collect your name, email address, job title and the contents of any communications you send us, for example if you communicate with us on third party sites, or for press enquiries, or if you are a representative of one of our vendors/suppliers, or if you communicate with us in relation to job vacancies.

Information automatically collected about you when you use our site. As you use our site, we automatically collect, use, store and transfer different kinds of personal data about you relating to how you use our site ("Usage Data"). This includes your IP address, your town/country, and device information including name and type of operating system, mobile service information and standard web information such as your browser type and the pages you access on our site. Please see the ‘Cookies' section below.

Information from third parties and related companies. Google Analytics provides us with Usage Data about you, including if you visit other website employing our cookies. We also receive personal data about you from Epic Games Store and Google, if you choose to log-in to the Play/Create Website via those accounts or if you choose to create a Forum account using your Google account (the types of personal data collected from Google and Epic Games Store are as specified above).

Other than self-reported information submitted by applying for our Black Creators Prize Fund and Mentoring Programme, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Purposes for which we will use your personal data

We use the personal data you give us to:

We use your Usage Data in order to use data analytics to:

We process your Usage Data in these ways on the lawful basis that this is necessary for our legitimate interests (to define the types of visitors to our site, understand how visitors interact with our site, to keep our site updated and relevant, to develop our business and to inform our marketing strategy).

MARKETING

Where you have provided us with your Contact Data in order for us to send marketing communications to you in return for us providing you with special items to use within the Crayta platform or where you enter a competition or prize fund, we will use your personal data for marketing communications. You can ask us to stop sending you marketing communications at any time by following the opt-out link on the marketing communication or by contacting us at any time.

DO NOT TRACK

"Do not track" signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. Our site does not respond to "do not track" signals in your web browser.

Cookies

Our Crayta website uses cookies. This helps us to provide you with a good experience when you use our site and also allows us to improve it.

A cookie is a small file of letters and numbers that we, subject to your approval, store on your browser or the hard drive of your computer or other device with which you are accessing our site. Cookies contain information that is transferred to your computer's or other device's hard drive.

When you visit our site for the first time, we will provide you with a notice which lets you know how we use cookies, why we use them and how you can change which cookies you accept.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You may find additional information about controls offered by popular browsers at the links below: Google Chrome, Internet Explorer, Firefox, Safari, Safari Mobile, Opera. If you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly. If you have disabled one or more cookies, we will still use information collected from cookies prior to your disabled preference being set; however, we will stop using disabled cookies to collect any further information.

The types of cookies used by us in connection with each of our sites are set out below.

Our landing site (crayta.com):

Essential/Strictly Necessary cookie: We use "cc_cookie" cookie allows us to remember whether a user has granted cookies consent on the site (expires after 365 days).

We use "personalization_id" cookie which is a cookie placed by Twitter to track the use of the Twitter buttons on our site and is used by Twitter to record your actions and interactions with the Twitter buttons. If you are logged into your account with Twitter, Twitter will be able to link information about you with your actions via this cookie (expires after 365 days).

We use the cookies listed below to track Reddit users on our site. Reddit will use the information collected via these cookies to record and monitor how Reddit users use our site. If you are logged into your Reddit account whilst using our site, Reddit will be able to link information about you from your Reddit account with your use of our site via these cookies.

" __gads"

"csv"

"d2_token"

"edgebucket"

"eu_cookie_v2"

"loid"

"pc"

"reddaid"

"reddit_session"

"show_anouncements"

"session_tracker"

"token_v2"

"USER"

Our Play/Create Website:

Essential/Strictly Necessary cookies: We use a "crayta-auth-token" cookie which allow us to authenticate users on the site (this is a session cookie).

We use a "cookie_consent" cookie which allows us to remember whether a user has granted cookies consent on the site (expires after 365 days).

Our Support Website:

Essential/Strictly Necessary cookies:

We use "__zlcmid" cookie which authenticate the user for the use of the chat widget (expires after 365 days);

We use "__cf_bm" cookie which is a Cloudflare cookie which helps us manage incoming traffic to our site (expires after 30 minutes);

We use "_zendesk_shared_session" cookie which is an authentication cookie (expires after 8 hours);

We use "_zendesk_session" cookie which stores accountIDs and routes for internal service calls (expires after 8 hours);

We use "_help_centre_session" cookie which stores unique session keys for the use of our Help Centre product (this is a session cookie); and

We use "_zendesk_authenticated" cookie which helps us remember that a user is authenticated in order to display the most up-to-date content (this is a session cookie).

Finally, we use "_ga", "_gali", "_gid", "_gat_UA-11380299-2" and "_gci_au", which are analytical cookies deployed by Google Analytics across all our sites. Google Analytics is a web analytics tool that helps us understand how users engage with the website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our website. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above.

Service providers. We share the information we collect with vendors, service providers and other partners who work under our direction to support our site (such as hosting our site, providing services such as customer service and sending electronic communications for us, and analysing the way in which people use our site) including, but not limited to:

Google Analytics, who provides cookies and analytics services to our site.

Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

To protect us and others. We may access, preserve, and disclose information associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Certain information you post to the Forum and Forum profile information (such as your username and avatar) will be public and visible to people accessing the Forum (whether or not they are logged in). Your username is a unique identifier you choose to identify yourself with on the Forum. If you post information to the Forum, it will be publicly available. Certain information associated with your public posts such as the month and year of your post, will be published and publicly available.

5. International transfers

We are based in the United Kingdom. We share information globally with our third party service providers.

Personal data controlled by us will be transferred or transmitted to, or stored and processed, in the United States or other countries outside the UK/EEA for the purposes described in this privacy policy. These data transfers are necessary to provide you with the services as set forth in our Terms of Service and to globally operate and provide the site to you. We use standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the EEA/UK to other countries.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention – How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by emailing us at dataprotectionofficer@unit2games.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.