SOULFRAME PRELUDES PRIVACY POLICY

Last Edited: December 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 game 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 pre-alpha for Soulframe (the “GAME”).

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.

WHAT INFORMATION DO WE NEED TO PROVIDE THE GAME?

If you register an account to use the Game then we will need some information from you to set this up. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features, or participate in the Game. 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.

HOW WILL WE USE YOUR INFORMATION?

We use your information to provide the many functions and Services that comprise the Game. We also use your information for account verification, security purposes and to support and improve the Game. We do not share your information with any third parties, except where we need to in order to provide the Game (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Game) or monitor the success of our marketing and advertising programs, or we are instructed to by a court, authority or compelled by law.

WHO DO WE SHARE YOUR INFORMATION WITH?

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 Game and we may be required by a court or legal obligation to disclose certain information in some circumstances.

WHERE DO WE PROCESS YOUR 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 Netherlands, Singapore, France, UK, Germany, United States, Canada and the Philippines. Please see the ‘How we store and share your personal information’ section below.

HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?

We generally retain your information 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.

HOW CAN I EXERCISE MY RIGHTS OVER MY 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.

HOW TO GET IN TOUCH WITH US

If you have any questions about anything in this Privacy Policy, please contact us at privacy@digitalextremes.com . To request support with Soulframe account-specific features, please contact our Support team at support@soulframe.com .

HOW WILL WE NOTIFY YOU OF CHANGES?

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.

CONTACT 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

WELCOME TO SOULFRAME!

This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the Game, 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 Game. By using the Game you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This Game 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 Game 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 would like to request to access, update, or delete your personal data, you can contact our Support team at support@soulframe.com. If you have any questions about your personal data you can contact us either privacy@digitalextremes.com or one of our representatives at:

Jurisdiction

Name

Address

Contact details

Bird & Bird GDPR Representative Ireland

Deloitte House, 29 Earlsfort Terrace, Dublin 2, D02 AY28

eurepresentative.digitalextremes@twobirds.com

Key contact: Vincent Rezzouk-Hammachi

Bird & Bird GDPR Representative Services UK

12 New Fetter Lane, London, EC4A 1JP, United Kingdom

ukrepresentative.digitalextremes@twobirds.com

Key contact: Vincent Rezzouk-Hammachi

INFORMATION WE COLLECT

As you engage with our Game, 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 some of our services or Services. Here are examples of when we directly ask you to provide us with information:

Account related data provided by you upon account creation, including email, account name, password, and platform.
Any information provided by you in connection with contacting our Customer Support Services.
Information that is provided by using the in-game chat features or our forums.

We also collect a variety of information from you automatically as a result of you using our Game and through your interactions on our websites. 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:

IP address
Geographic location information using IP information
Basic operating system information
Event data related to how your account information is modified or updated over time.
Transactional data around virtual currency purchases and in-game purchases

HOW WE USE YOUR INFORMATION

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, Brazil or Turkey (“RELEVANT JURISDICTION”), it also identifies the legal basis under which we process your data.

INFORMATION YOU PROVIDE TO US

(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: Account ID, alias, email, password, hardware ID, IP address, date of birth.	We use this information to create your account in order to provide access to the Game, in accordance with your request. Note that your alias will be publicly visible to all other users of the Game. Where you have an in-game profile (with game specific stats), this may be publicly visible to all other users of the Game depending on the settings that you have configured.	Necessary to perform our contract with you to provide the Game.
MATCHMAKING SERVICES: IP address, account ID, hashed credentials.	We use this information to allow you to use the match-making services of the Game and hosted gameplay.	Necessary to perform our contract with you to provide the Game.
CUSTOMER SUPPORT: Any information voluntarily provided to customer support including email, login data, gameplay data and transaction data	We use this information to help provide support to you in relation to the issue you’ve contact us about.	Our legitimate interest in answering your questions about the Game in order to improve your experience and improve our relationship with you.
SECURITY: IP address, IP lookup information, account ID.	We use this information to help provide security and network protection mechanisms.	Necessary to perform our contract with you to provide support for the Game.
FORUM: Account information including email, password and alias, and forum postings.	We use this information to allow you to use the forum Services.	Necessary to perform our contract with you to provide the Game.
FRIENDS LIST (manually added by you): friend aliases.	We use this information so that you can connect with your friends and share game activities with your friends.	Necessary to perform our contract with you to provide the Game and connect you with your friends.
DATA SUBJECT REQUEST INFORMATION: alias, email address, transaction history, login history, 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 – our obligations under data protection laws.
SENDING LEGAL REPORTS/RESPONDING TO COURT ORDERS: Purchase and activity data, online identifiers, information requested by law enforcement	We may be required by law to disclose this information to law enforcement bodies.	Necessary to comply with a legal obligation – our obligations under intelligence and security laws

INFORMATION COLLECTED AUTOMATICALLY OR GENERATED AS PART OF THE GAME

Personal Information	Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
GENERATED ACCOUNT ID	We generate this and use this to store your gameplay data (including level and progress) with your profile, and it allows you to connect to the Game server.	Necessary to perform our contract with you to provide the Game.
GAMEPLAY INFORMATION: Various gameplay related data (i.e. account state, aggregate account data, mission time, item acquisition rates, inventory amounts, ability usage, account ID of friends)	We use this information to: provide the Game and provide you with feedback and information about your gameplay and progress Improve the Game	To provide the Game, feedback, and information: Necessary to perform our contract with you to provide the Game. To provide the Game, feedback, and information: Necessary to perform our contract with you to provide the Game.
IP ADDRESS	We use this information to: Allow you to connect to the Game server Optimize your matchmaking experience Determine your country of origin Security and anti-cheat functions Security and anti-cheat functions	Necessary to perform our contract with you to provide the Game. + see legal bases for matchmaking + security.
SECURITY / DIAGNOSTICS RELATED INFORMATION: IP address, operating system information, user account information, processes, memory, and driver which is related to the game running.	We use this information to: for security and verification purposes identify and address bugs and assess game function for optimisation solve game crashes and optimise compatibility of hardware with the game to combat users registering for multiple accounts	Your opt-in consent to obtain diagnostic information about your device and to contact you by email to help fix any related issues. (Where consent is not relied on and obtained) It is in our legitimate interest to ensure the security of our Services and to manage registrations and improve our Services.
CHAT DATA: text communicated to other players in-game (message history), on our forum, and through public chat channel or sent to peers, including alias and account ID.	If you engage with chat services then we will process such data in order to deliver your messages to other users.	Necessary to perform our contract with you to provide the chat Services in-Game.
CHAT MONITORING AND LOGGING: text communicated to other players in-game (message history), on our forum, and through public chat channel or sent to peers, including alias and account ID.	We monitor and take logs of chats on a short-term basis for moderation and customer support purposes. If your account is determined to breach our Terms of Service, we may consider restricting or banning your access to the service.	Our legitimate interest in providing customer support and security by ensuring the messages you leave are not inappropriate or offensive.
FINANCIAL REPORTING: Purchasing data, activity data, and IP lookup (country) data.	We use this information to complete our financial reporting and disclosure obligations to parent company, tax agencies and regulators.	Necessary to comply with a legal obligation.

HOW WE STORE AND SHARE YOUR PERSONAL INFORMATION

Pursuant to our contract with you to provide you with the Game, 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 Game are located in:

Canada;
the USA;
Netherlands;
Singapore; and
France.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the Netherlands, Singapore, France, UK, Germany, Canada, the Philippines and the USA.

ONLY WHERE NECESSARY will we share your personal information with third parties. Situations where this occur are:

THIRD PARTIES that provide services in support of the Game, including platform, distribution and payment processing partners, providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Game, for the purpose of processing support ticket ID and support communication, and for the purpose of providing marketing and advertisements and monitoring the success of our marketing and advertising programs. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their Services
COMPANIES WITHIN OUR CORPORATE GROUP who process your personal information in order to operate the Game around the world. All related group companies may only use your personal information in accordance with this Privacy Policy.
REGULATORS, JUDICIAL AUTHORITIES AND LAW ENFORCEMENT AGENCIES, AND OTHER THIRD PARTIES FOR SAFETY, SECURITY, OR COMPLIANCE WITH THE LAW. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A THIRD PARTY THAT ACQUIRES ALL OR SUBSTANTIALLY ALL OF US OR OUR BUSINESS. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or reorganize any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

HOW WE PROTECT YOUR INFORMATION

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 Game or otherwise via the Internet; any transmission is at your own risk.

DATA RETENTION

We do not keep your data for longer than is necessary unless we are required to do so under law. We will keep the majority of your data for the duration of the pre-alpha, and any directly identifying information will be removed after the pe-alpha has finished (unless an account deletion request is submitted, in which case your data will be deleted or anonymised within 30 days). De-identified data is retained for 12 months following the pre-alpha, after which it is deleted. The exceptions to this are Matchmaking services, in respect of which data is retained for 30 days.

If we are required to retain your information beyond these retention periods to comply with applicable laws, in which case we will store it separately from other types of personal information.

YOUR RIGHTS

Some jurisdictions’ laws grant specific rights to users of the Game, 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.

RIGHT OF ACCESS

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 contacting our Support team at support@soulframe.com.

RIGHT TO PORTABILITY

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., advertising) 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).

RIGHT TO RECTIFICATION

At any time you can update your Account Information by logging in to your account profile on our website. If for whatever reason you believe the personal information we have about you is inaccurate or incomplete and requires changes, please notify our Support team at support@soulframe.com.

RIGHT TO ERASURE

You can delete your account and have the right to request that we delete Personal Data that we store on you. You can do this by contacting our Support team at support@soulframe.com and requesting your account to be deleted. We ensure that all deletion requests are satisfied within one month upon receipt of your request. Please note that once an account is deleted there is no way to recover it. 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 Game 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.

RIGHT TO RESTRICT PROCESSING TO STORAGE ONLY

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.

RIGHT TO WITHDRAW CONSENT

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 Game.

RIGHT TO OBJECT

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.

RIGHT TO PROCEED AND TO TAKE LEGAL ACTIONS

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.

ANNOUNCEMENTS

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 Game for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these Game-related announcements, which are not promotional in nature.

FURTHER RIGHTS

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.

HOW TO EXERCISE YOUR RIGHTS

You can exercise your rights by contacting our Support team at support@soulframe.com 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

UPDATES TO THIS POLICY

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.

HOW TO CONTACT US

If you have any questions about how we process your personal data, contact privacy@digitalextremes.com . If you would like to make a request in connection with your rights listed above, please contact our Support team at support@soulframe.com.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, 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.

CALIFORNIA

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:

Identifiers, such as your Account ID, IP address, device ID, email address, and nickname.
Internet or other electronic network activity information, such as your information regarding your use of the Game, including gameplay information and time stamps of actions, log-in and clickstream data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Commercial information about any transactions within the Game such as what products were purchased and how much they cost. This information is collected directly from you and your device.
Geolocation data such as your region location when you set up your account and choose to provide this information for the Game. This information is collected directly from you.
Other information described in subdivision (e) of Section 1798.80. This information is collected directly from you in the context of being our consumer.

We collect your personal information for the following purposes:

To provide you with the Game, maintain your account, provide customer Game, process payments, and deliver text messages.
To improve our services, including the functionality of the Game.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

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:

Other companies within our corporate group who process your personal information in order to operate the Game.
Other companies that provide services on our behalf in support of the Game and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
Regulators, judicial authorities and law enforcement agencies
Entities that acquire all or substantially all of our business.

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:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the purpose for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
the specific pieces of personal information we collected about you;

Request we delete personal information we collected from you, unless CCPA recognises an exception; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
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 at support@soulframe.com or by sending us an email at privacy@digitalextremes.com privacy@digitalextremes.com.

CANADA

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our Game providers located outside Canada, you may contact our Support team at support@soulframe.com or send us an email atprivacy@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 Game providers.

Where we use Game 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 Game 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.