PRIVACY POLICY

ISSUED BY KARMA PLAY LTD.

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by Karma Play Ltd. (“KP”/“we“/“us”). Our registered office is at 61A West Street, Fareham PO16 0AT, UK.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services, other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games, including our website, karmaplay.net, (the “Website”). Together the Game(s) and the Website are referred to herein as the “Online Services”.

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them.

They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Game and/or on the Website.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following information, which may include your personal data.

Information provided by you when using the Game (“Basic Information”)

We will collect the following information from you when you play our Games:

This may include:

• Steam ID
• Xbox Gamertag
• PSN Online ID
• Steam, Xbox or PSN Profile/Display Name
• your IP addresses
• the country in which you are playing our Games

We may ask you for, or you may submit, certain contact information to us or contact us through the Website (via the “Contact Us” form). This may include:

• your name
• your username
• your email address

Information on your device which you make available to us (“Content Information”)

Our Online Service may also collect information which you make available to us, and which is stored on your device, or in your Facebook or other social media profiles.

This may include:

• contact information
• images
• video or other digital content such as records of your gameplay
• characters and other in-game content you have created

How you use our Online Services (“Game Analytics”)

We may collect technical information about your use of the Online Services using tracking technologies and analytics.

Personal data we may collect includes the following:

• your Steam ID
• Xbox ID
• PSN Online ID
• Steam, Xbox or PSN Profile/Display Name
• your IP address
• the country in which you are playing our Games
• gameplay results (e.g. wins/losses, kills/deaths)
• gameplay progress
• gameplay time
• user interface usage (e.g., buttons clicked, screens viewed)
• hardware information (e.g., CPU, RAM, video card configuration)
• any purchases and spend you have made in the Game, and
• identification of crashes and bugs.

How you use our Website (“Website Analytics”)

Our Website uses cookies to collect analytical information, such as your internet protocol (IP) address, your browser and/or other internet log information, to help analyse how visitors use the Website.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Game and the Online Service to you

As applicable, we will use information about you (including Basic Information and Analytics) for delivering our Online Services to you under the terms of use agreed between us, as well as contacting you about matters requiring your attention.

The processing of information in this way is necessary for us to record your progress and status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games.

To help us improve the Online Services and fix any problems.

We may process information about you (including Basic Information and Analytics) so that we can analyse and improve the Game and Online Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Games and Online Services.

Prevent Fraud and Illegal Activity

We process personal data for the legitimate interests of ensuring that use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

We work with Steam (the Valve Corporation), Microsoft (Xbox) and Sony (PlayStation) to assist us with fraud prevention and the detection of any illegal activity (e.g., to verify in-Game purchases made through Steam, Xbox or PlayStation). We also implement anti-cheat measures to detect cheating.

4. DATA SHARING

Group members, personnel, suppliers, or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is

on the basis that they do not make independent use of the information and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Karma Play, our customers or others.

Digital Content Stores: The Game is made available to download via Steam (operated by the Valve Corporation), Xbox Live (operated by Microsoft) and PSN (operated by Sony) and we may disclose your personal information to Steam, Microsoft, or Sony (as appropriate) for the purposes of making the Game available and facilitating any in-Game payments made through Steam, Xbox Live or PSN.

5. DETECTING CHEATING

PLEASE NOTE: We do not use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

We do however process your personal information in order to identify users who are cheating in the Games. Our methods are designed to detect cheating by looking out for irregularities in gameplay behaviour.

If users are determined to be or suspected of cheating, the following actions may be taken:

• they will be temporarily or indefinitely suspended from playing the Game, although they will still have access to their Game account; and
• anything acquired relating to the Game, be it through credits or real-money purchase, will be lost.

Please also see our terms of use for each Game as applicable.

In this scenario, the user will be informed of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Game.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

Where you have linked your Steam, Xbox Live and/or PSN accounts to any of your social media accounts, you can unlink these at any time by changing your settings in Steam, Xbox Live or PSN (as applicable). You can also remove access in your account settings on Facebook, Twitter and/or YouTube.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
8. You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay and within one month at the latest.
9. To make a request, please let our Data Protection Officer know via info@karmaplay.net.

Ask for a copy of data we are processing about you and have inaccuracies corrected.

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you.

You can ask us to restrict, stop processing or delete your personal data if:

• you consented to our processing the personal data and have withdrawn that consent.
• we no longer need to process that personal data for the reason it was collected.
• we are processing that personal data because it is in the public interest or it is to pursue a legitimate interest of Karma Play or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it.
• the personal data was unlawfully processed;
• you need the personal data to be deleted in order to comply with legal obligations.
• the personal data is processed in relation to the offer of a service to a child.

You can delete your accounts by following the instructions in your account settings.

Obtain a machine-readable copy of your personal data, which you can use with another service provider.

• If (i) we are processing data to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
• If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

• If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
• If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

1. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal

information and whether we can achieve those purposes through other means, and the applicable legal requirements

If you decide to delete your Game account, we will delete your account information, unless we consider it necessary to retain, within 28 days. If your account is dormant for more than 10 years, we will delete your account information, unless we consider it necessary to retain. Please note that where you have purchased in-game items or perks you may no longer have access to these if you ask us to delete your personal information (this will be the case even where you have paid for these items or perks).

9. CHILDREN

We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. If we learn that we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at info@karmaplay.net.

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as Karma Play management or employees whose main role requires system access).

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can

prevent all potential security breaches.

11. INTERNATIONAL DATA TRANSFERS

Information we collected about you will be stored within the European Union (EU) and India on a secured server.

Your personal information may be transferred outside of the EU and India by Steam (i.e., Valve Corporation), Microsoft (Xbox Live), Sony (PlayStation Network) or Nintendo (Nintendo Switch).

CONTACT INFORMATION

All questions, comments or enquiries should be directed to Karma Play at info@karmaplay.net.

© 2023 Karma Play Ltd. All trademarks are the properties of the relevant owners. All rights reserved.