Game Privacy Policy

Last updated: 30.05.2024

1. WHO ARE WE, HOW TO CONTACT US AND WHAT DOES THIS PRIVACY POLICY COVER?

We, XTEN Limited (we, us, our) with our headquarters in Cyprus have developed the game of UFL (the “Game”) and some other products and services in connection with the Game such as applications, test events and contests. We would collectively refer to them as the “UFL Services”. 

This privacy policy (the “Policy”) describes and explains how we may collect, use, share, retain and transfer information about you (you, your, yours) when you interact with the UFL Services. We are the controller of your personal information, and if you have any further questions, please get in touch with us.

OUR CONTACT DETAILS:

Controller: XTEN Limited 

To: Data Protection Office

Address: Office 701, 169 Archiepiskopou Makariou III, CEDARS OASIS TOWER, 3027, Limassol, Cyprus

Email address: privacy@strikerz.inc

You may also contact our data protection officer at dpo@strikerz.inc. 

Please carefully read the Policy below. We have also included the highlights for each section of this Policy that explain our privacy practices in simplified wordings and make them easier to understand. You should also carefully review any other agreements that apply to the UFL Services, and confirm you understand and agree to them, before using the UFL Services.

2. WHAT INFORMATION DO WE COLLECT?

HIGHLIGHT: we may collect different categories of information about you in three different ways: (i) when you provide it directly to us (general identification, contact, any additional information), (ii) from our partners and service providers that help us run and maintain the UFL Services (identification, general location, in-Game statistics and Game performance, device information), (iii) automatically when you use the UFL Services (general location, device information).

2.1. Information You Provide to Us.

You can provide us with the information directly when you use the UFL Services. To play the Game, you will provide us with general identification information like the name of your in-Game clubs. You can also provide us with the information if you contact our customer support team, in this case the information you provide will depend on the type of your request. We may ask you to verify your identity when you make a privacy request to exercise some of your privacy rights so that we comply with the legal requirements and ensure that your personal information remains intact.

We will also receive your information if you choose to sign up for our emails, complete surveys, participate in test events and contests. In such cases we will collect your general identification, contact details, and the information you choose to voluntarily provide so that we will be able to contact you, to let you participate in our events and surveys and to provide you with the appropriate rewards.

2.2. Information From Third Parties (Service Providers and Partners).

We may receive information about you from our partners and service providers when you use the UFL Services. 

We receive your identification, general location, in-Game statistics, Game performance and device information from the gaming console platforms when you download and play the Game on your gaming console. Such information, concerning your user account and profile, includes your username, your account and online ID, country, language, age or age group, parental control restrictions, in-Game entitlements, achievements and scores, friends, events, session details, presence and player reviews, time spent in the Game, the Game statistics and rankings, in-Game purchases, information about our Game’s performance, including error reports.

We may also receive your identification and device information from our advertising and analytics service providers, namely your advertising IDs, your gaming console or platform type, hardware model and settings, unique device identifiers in case you have agreed to such information collection and sharing by the advertising and analytics service providers.

2.3. Information We Collect Automatically.

We can also automatically collect some information that is associated with your access to and use of the UFL Services. 

This information would basically include the general location information such as the Internet protocol address, approximate geolocation (region or country), and your device information like your gaming console or platform type, hardware model and settings, device memory information, unique device identifiers, system activity, crash reports information. 

And this information also includes usage data such as in-Game statistics showing us how long and when you played the Game, the gameplay sessions, progress and achievements, saved preferences, crash reports.

Some UFL Services may use technologies such as cookies, web beacons or log files to automatically collect the mentioned information. Some of these technologies may create small files that may be stored on your device and that help us and other third parties to recognize your device and your preferences, like language preferences, to enhance your experience interacting with the UFL Services.

3. HOW DO WE USE YOUR INFORMATION?

HIGHLIGHT: we use the information about you and how you use the UFL Services to provide, maintain, analyze, improve and promote our UFL Services.

In more detail, we use your information for the following purposes.

  1. We use your identification, in-Game statistics, the Game performance and device information to develop, deliver, maintain and improve the Game and other UFL Services;

  2. We use your identification, general location, in-Game statistics information to create, verify and manage the accounts and clubs in the Game;

  3. We use your identification, in-Game statistics, the Game performance and device information to support the UFL Services and contact you when you send your requests or inquires to our support team, to send you service messages and updates;

  4. Hold and manage the closed and open test events, early access events, contests, and to collect and analyze your feedback;

  5. We can use your identification, in-Game statistics, the Game performance and device information to comply with our legal obligations, perform or enforce our contractual terms and conditions;

  6. We use your in-Game statistics, the Game performance and device information to analyze the data to improve the Game and other UFL Services so that you could enjoy them;

  7. We use your identification, in-Game statistics, the Game performance and device information to make our UFL Services secure to let you enjoy them without interruptions and protect you from any illegal or harmful events or actions;

  8. We use your identification, in-Game statistics, the Game performance and device information to promote the Game and other UFL Services by analyzing and measuring the effectiveness of our promotional offers, advertisements, surveys, and other events.

4. ARE WE ENTITLED TO USE YOUR INFORMATION?

HIGHLIGHT: We only use the information about you when we have the right, the legal basis for it, and we only rely on the legal bases that are provided by law.

We use your information relying on the following legal bases:

  1. Contractual obligation. We will use your identification, in-Game statistics, the Game performance and device information to provide you with the UFL Services under our agreements with you. For example, we process your personal information to set up and verify your account; let you play the Game and save your progress, monitor and analyze the UFL Services; prevent fraudulent behaviour, respond to your customer support requests or other inquiries, notify you about changes to our applicable agreements, terms or policies.

  2. Legitimate Interest. We will use your contact, in-Game statistics, the Game performance and device information to achieve our business purposes in case such use of your information is balanced against any potential impact on your privacy rights. We will only use your information under this legal basis for the purposes that can be reasonably expected, like to share some news related to the UFL Services, to better know and understand our users, to personalize your experience with the UFL Services, to manage and customize advertisements or promotional offers, to provide you with updates; to provide similar user experience, to improve the UFL Services. 

  3. Consent. We will process your identification and the Game performance information when you agree to see personalized in-Game advertisements, and you can withdraw your consent at any time.

  4. Legal Obligation. We will use your information in cases necessary to comply with the law, for example to respond to requests from law enforcement authorities or other government officials.

In case we use any automated technologies to detect fraudulent practices and behaviour, the results will be subject to revision by a human. 

5. HOW LONG DO WE STORE AND USE YOUR INFORMATION?

HIGHLIGHT: We limit the time when we use and store your information to the period that we reasonably need for the purposes described above unless a longer storage or retention period is required or permitted by law.

The period during which we use and store your information can vary depending on the type of information and the type of your interaction with the UFL Services. For example, XTEN may store your personal information for the term needed to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

6. WHO DO WE SHARE YOUR INFORMATION WITH?

HIGHLIGHT: We may share some of the information about you with our partners that help us provide the UFL Services. Without our partners we will not be able to run the UFL Services on our own, but we make sure that your information is safe with our partners. 

Here are the types of third parties that we may share your information with:

  1. Gaming console and platform partners.

  2. Service providers (data processors) that help us run and provide the UFL Services, help us analyze how our Game performs and help us spread the word about the Game, such as cloud storage providers, tracking and security service providers, business analytics, marketing and advertising partners.

  3. Governmental or public authorities for the purposes of law enforcement, national security and other issues of public interest importance.

7. HOW DO WE TREAT CHILDREN’S PRIVACY?

HIGHLIGHT: The information below is for parents or legal guardians of children under the age of 13 or the age of digital consent in the child’s place of residence, whichever is higher. However, we recommend that all persons under the age of 18, notwithstanding their place of residence and the age of digital consent under the local law, first ask their parents or other legal guardians to explain to them the meaning of this Policy. 

We develop our UFL Services with the core principles of privacy by default and design, and we aim to make them safe for users of any age. We pay particular attention to protecting the rights of children. 

When the gaming console indicates that the user of our UFL Services is a child, we would ask for your permission to collect and process the information about the child, and to accept the terms and conditions of our agreements on the child’s behalf. 

We will at all times respect and be compliant with the parental controls of the gaming consoles. We will only collect and use the personal information of a child in accordance with the consent and permission that a parent or another legal guardian has granted to the gaming console platform. We will never collect or process any sensitive personal information concerning children. In case we have concerns about the age of digital consent or have reasonable doubts about the age of the UFL Services users, we will ask for identity, and take immediate actions to erase all personal information and cease its processing as soon as possible.

We strongly encourage you to observe and appropriately adjust the parental control settings on your applicable platform. 

8. HOW CAN YOU CONTROL YOUR INFORMATION?

HIGHLIGHT: We want all our users to receive the best experience when they use the UFL Services, and being in control of your information is one of the main features of your user experience. You can ask us to perform particular actions and to provide you with particular information.

Here are the privacy rights that you have with regard to your information.

  1. You can ask us to provide you with access to, erase, correct or update the personal information that we have collected from you. You can object to or restrict our processing of your personal information. You can ask us to provide you with a portable copy of the personal information you have provided. You can also withdraw your consent for processing your information at any time for the cases where we have asked you to allow us to use your data for particular purposes. To exercise these rights, please send us a request to our contact details or contact our customer support team. Please remember that some of the requests may require your identity verification. 

  2. You can change your email marketing settings and preferences by using the opt-out mechanism or by sending us your request as to our contact details.

  3. You can always change your privacy setting and preferences on third parties’ platforms and websites. The parents and other legal guardians can change the privacy settings for their child’s gaming console account.

  4. You can make a complaint against our processing of your personal information by contacting your local supervisory authority for data protection (if there is any in your place of residence). However, we would be glad to have an opportunity to first address all of your concerns if you contact directly.

9. WHAT ARE THE INTERNATIONAL OPERATIONS YOU SHOULD KNOW ABOUT?

HIGHLIGHT: XTEN Limited is headquartered in Cyprus, and we use services from providers that operate globally to help us build a better experience with the UFL Services for all our users. This means that your information may be processed in the systems of our service providers located somewhere abroad from your current place of residence.

9.1. International Transfers of Information.

We may transfer your personal information in and outside the EEA, EU, UK, Switzerland or the United States of America when we provide the UFL Services. We apply the EU Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Agreement and other appropriate mechanisms for any such transfer and ensure that such transfers occur only if there are adequate levels of protection in place.

9.2. Special Notice for the Residents of California.

The California Consumer Privacy Act (“CCPA”) grants particular rights to consumers residing in California with respect to their personal information. If you are a resident of California, you have the right to: (i) request us to delete, update or correct your personal information; (ii) request to provide you with further information about the categories and specific elements of your personal information that we collect, use, and disclose to third parties for their direct marketing purposes; (iii) request to provide you with the list of the categories of third parties to whom we have disclosed such information; (iv) request to provide you with a portable and transmittable (as technically feasible) copy of your personal information; (v) opt out of sale of your personal information (as defined in the CCPA, if any); and (vi) not be subject to any discrimination when exercising these rights.

You or your authorized agent can send us the requests to our contact details. Please note that we may ask you to verify your identity, or we may ask to verify the authority of your agent before we complete the requests. 

When you use the UFL Services, we may collect the following categories of personal information as defined in the CCPA: (i) Identifiers and console account login information. We may collect your username, account name, your online identifiers and device identifiers, IP address. (ii) Approximate geolocation information based on your console settings and IP address location information. (iii) Protected classifications characteristics such as your age. (iv) Commercial information about your interaction with the UFL Services, in-Game purchase information. (v) Audio and electronic information that you share when you play the Game. 

We can also receive and process other categories of your personal information in case you contact our customer support team for help.

We collect, use and disclose your personal information for the purposes described in Section 3 of this Policy. We do not sell or share your personal information as defined in the CCPA. We shall retain your personal information for the term necessary to provide the UFL Services, and we may also retain the information for a longer period in case we are obligated to do so under the applicable legal provisions or on other legitimate grounds.

10. HOW DO WE SECURE YOUR INFORMATION? 

HIGHLIGHT: We use our best efforts to keep your information secure, and for that we use only trusted service providers, we continuously train our staff, and we use only secure software and devices.

We maintain appropriate technical and physical safeguards, administrative and organizational measures to protect your personal information from any unlawful, unauthorized or accidental destruction, loss, alteration, access, disclosure, or other unlawful forms of processing. If we become aware of any unauthorized disclosure of your personal information, we will immediately notify you as required by applicable law and do our best to secure your information.

11. HOW DO WE UPDATE THIS POLICY?

We will update this Policy from time to time to reflect our latest privacy improvements and changes of the applicable laws. You will see the latest effective date of this Policy in its preamble. We may also notify you of the changes by email or within UFL Services communication channels. Please review this Policy regularly to make sure that you are updated and fully understand our privacy practices.