Last Updated: February 6th 2023
Digital Extremes Ltd.’s Privacy Policy
Digital Extremes Ltd., located at 250 York Street, London, Ontario in London Ontario, N6A 6K2, (“we” or “us”) provides this website and is the controller of your personal data.
Our data privacy team may be contacted at privacy@digitalextremes.com.
We strive to be transparent about how we collect and use your information. The following policy outlines how we collect, use, share, and protect your information.
This policy applies to the https://www.soulframe.com website (the “SERVICE”).
Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.
If you choose, you can provide certain information to us in order to participate in the Serviceand the launch of the Soulframe game, for example to join our Soulframemailing list and to reserve your envoy title. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.
We use your information to maintain the Service and to provide you with support and opt-in marketing communications. We do not share your information with any third parties, except where we need to in order to provide the Service (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Service) or monitor the success of our marketing programs, or we are instructed to by a court, authority or compelled by law. More Information.
We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Service and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.
Our servers are located in Canada, the Netherlands, Singapore, France or the United States of America. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the United States, Canada and the Philippines. More Information.
We will retain your information for the length of time until the launch of the Soulframe game and after that period for the period during which you maintain an account for the game, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws.Once your account has been created, we will only delete your account at your explicit request. More Information.
Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.
Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.
Contact |
Name |
Contact details |
Data Controller |
Digital Extremes Ltd | privacy@digitalextremes.com |
EU Representative |
Bird & Bird GDPR Representative Ireland |
eurepresentative.digitalextremes@twobirds.com Key contact: Vincent Rezzouk-Hammachi |
UK Representative |
Bird & Bird GDPR Representative Services UK |
ukrepresentative.digitalextremes@twobirds.com Key contact: Vincent Rezzouk-Hammachi |
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection withthe https://www.soulframe.com website (the “SERVICE”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging our rules regarding your personal information as described in this Privacy Policy.
This Service has been developed by Digital Extremes Ltd. (“we”, “us”, “our”).
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Digital Extremes Ltd.The registered address of Digital Extremes Ltd. is 250 York Street, London, Ontario, N6A 6K2.
If you are located in the EEA or the United Kingdom and have questions about your personal data or would like to request to access, update, or delete it, you may contact our representative at:
Jurisdiction |
Name |
Address |
Contact details |
EU |
Bird & Bird GDPR Representative Ireland |
Deloitte House, 29 Earlsfort Terrace, Dublin 2, D02 AY28 |
eurepresentative.digitalextremes@twobirds.com Key contact: Vincent Rezzouk-Hammachi |
UK |
Bird & Bird GDPR Representative Services UK |
12 New Fetter Lane, London, EC4A 1JP, United Kingdom |
ukrepresentative.digitalextremes@twobirds.com Key contact: Vincent Rezzouk-Hammachi |
Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at privacy@digitalextremes.com.
As you engage with our Service, sometimes you will be asked to provide us with personal information. The information that you are asked to provide and the reasons why you are asked to provide it will be made clear to you at the point we request it. Providing us with this information is entirely voluntary but if you choose not to provide it you may not be able to access aspects of the Service. Here are examples of when we directly ask you to provide us with information:
We also collect a variety of information from you automatically as a result ofyour interaction on our website. Some of this information is collected anonymously while at other times it is collected and associated with other information you’ve already provided. In cases where this information is linked to your account information, or if the info collected can be used to trace back to a specific person, then we consider this information to be personal data. Here is the information that is collected automatically when you use our services:
This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area, Switzerland, Thailand, Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.
(either directly or through a third party).
Personal Information |
Use |
Legal Basis (only relevant if you are located in a Relevant Jurisdiction) |
Account Setup Information: email, envoy title, IP address. |
We use this information to create your account in order to reserve your envoy title and enable you to claim your Alca’s Eye on launch of Soulframe, in accordance with your request. |
Necessary to perform our contract with you to provide the Service. |
Customer Support: Any information voluntarily provided to customer support including email address and content of support request. |
We use this information to help provide support to you in relation to the issue you’ve contact us about. |
Necessary to perform our contract with you to provide support for the Service. |
Opt-in Marketing: email, envoy title. |
We use this information when you voluntarily provide it for the purposes of providing you with update and promotional emails. |
We collect this information with your consent. |
Data Subject Request Information: envoy title, email address, proof of user's identity. |
If a data subject request is submitted, we use this information to confirm the requestor’s identity, your rights and to process the request. |
Necessary to comply with a legal obligation. |
Contests, Rewards, Giveaways and Sweepstakes Information: name, email address, envoy title, mailing address, view/claim data. |
If you participate in a contest, giveaway, or sweepstakes event, we use this information to send you your prize if you win. |
We collect this information with your consent. |
Personal Information |
Use |
Legal Basis (only relevant if you are located in a Relevant Jurisdiction) |
IP Address |
We use this information to determine your country of origin. |
Necessary to perform our contract with you to provide the Service. |
Advertising Effectiveness Information: Advertising ID and select device information (IP address, ad source, engagement data and search terms). |
If you click on a link that advertises the Service, we store the Advertising ID for that advertisement with your profile. |
Necessary to perform our contract with you to provide the Service. |
We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
Some of the data processing operations about which we inform you in this Privacy Policy require that we or third parties use cookies. Please see our Cookie List for further information.
Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the Service are located in:
In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Canada, the Philippines and the USA.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.
We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.
Personal Information |
Retention Policy |
Account Setup Information: email, envoy title, IP address. |
Stored until launch of the game and then for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. |
Customer Support: Any information voluntarily provided to customer support including email address and content of support request. |
Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy). |
Opt-in Marketing: email, envoy title. |
Your voluntary participation in marketing emails and promotions can be revoked at any time. Otherwise it is stored until launch of the game and then for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Opt out requests may take up to 48 hours to process. Where you do not request for account deletion, such data will be retained for 1 year after the Service is shut down, before it is deleted. |
Data Subject Request Information: envoy title, email address, proof of user's identity. |
Stored until launch of the game and then for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. |
Contests, Rewards, Giveaways and Sweepstakes Information: name, email address, envoy title, mailing address, view/claim data. |
Stored for up to 1 year following the contest, giveaway or sweepstakes. |
IP Address |
Stored until launch of the game and then for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Service is shut down, before it is deleted. |
Advertising Effectiveness Information: Advertising ID and select device information (IP address, ad source, engagement data and search terms). |
Stored until launch of the game and then for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Service is shut down, before it is deleted. |
If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.
Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.
This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.
The sub-sections entitled “Right Of Access”, “Right To Rectification”, and “Right To Erasure” also apply to users that are located in Canada.
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have provided as part of your account by submitting a request through our Support page.
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., opt-in marketing) or pursuant to our contract with you (e.g., customer support), as described above in the section “How we use your personal information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
At any time you can update the personal information we hold about you by notifying us through our Support page or by using the “How to contact us” section below. In addition, if for whatever reason you believe the personal information we have about you is inaccurate or incomplete and requires changes, please notify us through our Support page or by using the “How to contact us” section below.
You have the right to request that we delete personal information that we store on you. You can do this by contacting our Support page on our website and requesting your personal informationto be deleted. We ensure that all deletion requests are satisfied within one month upon receipt of your request. Some information may be retained by us to the extent we need to satisfy a legal requirement or for security purposes. Some information will also be retained anonymously.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Some of our processing is based on your consent. You can withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question.
Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
YOU HAVE THE RIGHT TO OBJECT TO US PROCESSING YOUR PERSONAL DATA AT ANY TIME WHEN THE PROCESSING IS BASED ON OUR LEGITIMATE INTERESTS (AND NOT, FOR EXAMPLE, A LEGAL OBLIGATION) ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION. IF YOU OBJECT WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS THERE ARE COMPELLING AND PREVAILING LEGITIMATE GROUNDS FOR THE PROCESSING OR THE DATA IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS. IF YOU DO NOT WANT US TO PROCESS YOUR PERSONAL DATA FOR MARKETING ACTIVITIES, YOU CAN MAKE THOSE CHANGES ON YOUR DATA PERMISSIONS PAGE HERE OR CONTACT US ANY TIME VIA E-MAIL AT privacy@digitalextremes.com.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws
You also have the right to take legal actions in relation to any breach of your rights regarding the processing of your Personal Data.
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
You may choose to stop receiving marketing promotions from us when using the Service by unsubscribing from the communications you receive, or you can contact us by using the “How to contact us” section below.
Where processing of your Personal Data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, you have the right to receive the Personal Data you have provided in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible (data portability).
Further, you have the right not to be subject to any automatic individual decisions which produce legal effects on you or similarly significantly affects you.
You can exercise your rights by contacting our Support Page or by using the “How to contact us” section below. We satisfy these requests within one month upon receipt of your request. If the request affects the rights and privacy of others we reserve the right to refuse to act on the request. If your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or to refuse to act on the request.
Please note that we may need to request information from you to confirm your identity and establish your entitlement to these rights.
None of our services or content on our website is designed or intended for children under 16 years of age. Our content is in compliance with the Children's Online Privacy Protection Act (COPPA) and will never be directed at children under 16 years of age. If you are under 16 years of age, you are not permitted to access the websites or games unless your parent or guardian has provided express consent and accepts this Agreement along with all applicable end-user or similar license agreements on your behalf prior to your use of the websites or games.
We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at privacy@digitalextremes.com and we will delete such information.
From time to time we may update this policy for various reasons, including regulatory changes, changes in the scope of our services and advancements in our processes. We will take appropriate measures to inform you in the event of a significant change to this policy. Please refer to the date at the top of the page to see when the policy was last updated.
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.
If you have any questions or would like to make a request in connection with your rights listed above, please contact our Support Team through our websites or send us an email at privacy@digitalextremes.com.
Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.
If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
This section applies to users located in Brazil:
LANGUAGE
This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail.
CONSENT REVOCATION
Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account through our Support Team or you can contact privacy@digitalextremes.com. This may affect our provision of the Service to you.
PARENTAL AND GUARDIAN CONSENT
If you are under the age of 18, you should not use the Service for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our privacy team at privacy@digitalextremes.com if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
We collect your personal information for the following purposes:
For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.
We disclose personal information to the following types of entities:
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.
RIGHTS UNDER THE CCPA:
If you are a California resident, you have the right to:
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
HOW TO EXERCISE YOUR RIGHTS
First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting our Support Team through our website or by sending us an email at privacy@digitalextremes.com.
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact our Support Team through our website or by sending us an email at privacy@digitalextremes.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.
Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
CONSENT
We will not collect and use your personal information without your consent, and you can withdraw the consent anytime. You should understand that when you withdraw consent, we will not collect and use your personal information and the personal information processing based on your previous consent remains valid.
PARENTAL AND GUARDIAN CONSENT
If you are under the age of 14, you should not use the Service for any purpose without first obtaining parental/guardian consent to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 14 without such consent.
YOUR RIGHTS
We protect your personal information subject rights under PRC privacy laws, which includes the right to access, rectify, erase, copy personal information and etc.. For more information, you can see the sub-section “How To Exercise Your Rights” above.
YOUR RIGHTS
Instructions for the processing of your personal data after your death
You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.
The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.
You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.
When you wish to make such instructions, please contact our Support Team through our websites or by sending us an email at privacy@digitalextremes.com.
As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).
You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.
LANGUAGE
This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.
AGE RESTRICTIONS
You won’t be able to use the Service unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).
TYPES OF PERSONAL INFORMATION WE USE
For clarification purposes, in section 1 "Information we collect” and section 2 “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.
PURPOSES OF PROCESSING
Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations and advertising. We may also use your personal data for the voluntary purpose of sending information to your email that we may consider relevant to you. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.
Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section 4 “How we store and share your personal information”.
DATA TRANSFER CONSENT
In general, we do not require your consent to carry out the transfers detailed in section 4 “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.
By using the Service and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.
YOUR RIGHTS
The sub-sections entitled “Right Of Access”, “Right To Rectification”, “Right To Erasure”, “Right To Object”, “Right To Restrict Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, and “Advertising” included in Section “Your Rights” above also apply to users that are located in Mexico.
You also have the right to revoke the consent that you have provided us to process your personal data.
To exercise any of your rights, contact our Support Team through our websites or by sending us an email at privacy@digitalextremes.com..
To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our data privacy team at privacy@digitalextremes.com.
COOKIES
Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Service may no longer be available to you. For more information about our use of cookies and how to disable them, please see the section entitled “Which Cookies We Or Third Parties Use” above.
If you are using the Service in Russia, by using the Service you consent to:
The sub-sections “Right Of Access”, “Right To Rectification”, “Right To Erasure”, “Right To Restrict Processing To Storage Only”, “Right To Object” and “Advertising” of the section “Your Rights” above apply to users in the Russian Federation.
We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Service after the notification.
As regards the representative for Russia, you can contact us at privacy@digitalextremes.com. Please include the word “Russia” in the subject line of your email.