Privacy Policy
Effective as of August 05, 2024
This Privacy Policy explains how XTEN Limited ("XTEN", "we", "us" and "our"), the data controller, collects information about you, including personal information when you interact with this website ("Website"), our mobile application UFL (“App”) and related products and services, the technical support portal of our game UFL (“Game”), or other online activities (collectively, the “Services”). Capitalized terms that are not defined in this Privacy Policy have the meaning as defined in our Terms of Use or Cookie Policy.
This Privacy Policy explains what information we collect, why we collect it, how we use it, who we share it with, where it is processed, how we handle it and your rights and choices regarding this information.
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.
XTEN Limited is registered in Cyprus under company number HE365174. XTEN Limited is the controller for the personal information we process, unless stated otherwise.
XTEN provides privacy notice through this Privacy Policy and other timely means, like popups and cookie notifications to let you know about our privacy practices.
- INFORMATION WE COLLECT OR RECEIVE
- Information you provide to us
We collect the information that you directly provide to us when you enter it on the Website or include it in an email or other messages that you send to us. Such kind of information collection would happen during usual business support processes, such as technical support. We may ask you to provide information such as name, email address, date of birth, country if you decide to take part in promotions and other events, market research surveys, beta and other user testing research, and if you agree to receive marketing information from us.
- Information we collect automatically
We may also automatically collect information when you use the Services. Some of this information may be collected with the help of cookies and similar technologies. Please read more about our cookies use in our Cookie Policy.
We may collect device-specific and device event information, such as hardware model and settings, operating system version, device memory information, browser type, browser language, unique device identifiers, system activity, crashes data.
Some information that we collect automatically may be location information, such as Internet protocol address, geolocation/tracking details, cookies, and similar tracking technologies.
We may collect information of how you use our Services, such as your general use patterns, search queries details, engagement with the Services features and areas, frequency of visits and use.
- Information received from third parties
We may receive information from third-party sources and combine it with the information we receive directly from you. We will handle this information in accordance with this Privacy Policy.
- PROCESSING OF PERSONAL INFORMATION
XTEN endeavors to provide you with the best level of information privacy and security practices recognized globally and strives to guarantee the highest level of information protection. The personal information is processed in compliance with the General Data Protection Regulation 2016/679 (GDPR), the Law 125(I)/2018 of the Republic of Cyprus and other applicable data protection laws and regulations of the respective data protection supervisory authorities. We are transparent about our privacy practices and follow the principles of data minimization, purpose limitation, accuracy and accountability.
With regard to the rules and principles of the applicable data protection laws and regulations, we have adopted appropriate technical and organizational measures in order to ensure protection of personal information and your rights as the data subjects.
We limit the retention period of personal information to the terms necessary to achieve the purposes of processing it or as far as this is stipulated in laws and regulations to which XTEN is subject to. For example, XTEN may retain 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.
We process personal information under the following legal bases and for the designated purposes.
LEGAL BASIS PURPOSE OF PROCESSING Fulfilling legal obligations Ensuring security of the Website and our Services.
We may process your personal information to comply with applicable laws and regulations, to mitigate malware, network and information security risks, and to excel the security of our Website and Services.
Fulfilling contractual obligations Providing Services to you, providing customer support to users of our Game.
We may process your personal information to let you use the Website as per the Terms of Use and to inform you of any relevant security issues or updates.
Pursuing our legitimate interests Enhancing your online experience and developing the Website and our Services.
We may process your personal information to understand how visitors interact with our Services and how to measure, improve and tailor our Services by implementing your preferences and feedback.
Your consent Sharing some exciting news with you and providing targeted advertisements.
We may send you marketing communications and engage you in various marketing activities in case you have provided your consent for that.
If we ask for your consent as the legal basis for processing of your personal information, you have the right to withdraw your consent at any time. However, our processing of your personal information preceding such withdrawal will remain lawful.
You also have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, and thus we avoid any automated decision making, including profiling that can produce any legal or similarly significant effects for our Website visitors or Service recipients.
- THIRD-PARTY AND FURTHER PROCESSING
We engage third-party service providers that help us make the Website and App run and help us support the Services. Such third-party service providers are, among others, cloud storage providers, IT and security service providers, product development and customer support tools, marketing and analytics tools.
We will never sell or otherwise disclose your personal information. Only our service providers, conditionally to ensuring adequate security and protection measures, may process information as an essential part of their services provision to us.
We will process your personal information only for the designated purposes, and in case we need to process it for any new purpose, we will do so only upon your consent.
- INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We may transfer your personal information in and outside the EEA, EU, UK, Switzerland or the U.S.A in the course of the Services provision. 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.
By using our Website and Services or providing us with any information through them, you acknowledge such transfer, processing, and storage of your personal and other information in countries in which privacy regulations may be not as comprehensive as those in the country of your residence.
- YOUR PRIVACY RIGHTS
You have the rights to your personal information as described below and you can exercise them by contacting us at privacy@strikerz.inc. We shall consider your request under applicable legal provisions. In case we receive particular rights request, we may be obligated to verify such request and thus, ask you to verify your identity before complying with the request to protect your privacy and security.
Right of access and portability. You have the right to request that we inform you which personal information associated with you we process and to request that we provide you with a copy of that information without undue delay in a structured, commonly used, and machine-readable format, or to request that we transfer your personal information directly to another data controller in case that would be technically feasible and would not adversely affect the rights and freedoms of others.
Right of rectification. You have the right to request that we correct or update any inaccurate or outdated personal information associated with you.
Right of erasure. You have the right to request that we erase the personal information associated with you in some circumstances as defined by law. You may request that we erase the personal information that we process on basis of your consent, and you no longer consent to our processing it, you may request that we erase the personal information in case it is no longer necessary for the designated purposes, or the personal information that we process for activities to which you object, and we do not have any overriding legitimate basis for processing.
Right to restriction of processing. You have the right to restrict our processing of your personal information in case the accuracy of your personal information is under question and you have made the request to correct such information, you can also restrict our processing of your personal information if you claim that it is unlawful and you do not request to erase it, or you may restrict our processing of your personal information when we do not longer need it for the designated purposes, but you need it to establish, exercise, or defend legal claims.
Right to object to processing. You have the right to object to our processing of your personal information when we process it on the basis of consent, contract, or legitimate interests, for example, you can object to processing of your personal information for direct marketing purposes. However, we can continue to process your personal information if it is necessary to defend a legal claim, or under any other legally permitted exception.
If you have any questions or concerns about our processing of your personal information, please get in touch with us first at privacy@strikerz.inc, and we will do our best to resolve your query. You are also entitled to contact and lodge a complaint with a data protection supervisory authority, you may find the list of EEA national data protection authorities here, the contact details of the UK Information Commissioner’s Office here, and the contact details of the Swiss Federal Data Protection and Information Commissioner here.
- PROTECTION OF CHILDREN’S PERSONAL INFORMATION
We pay particular attention to protecting the rights of children. Thus, we recommend that all individuals under the age of eighteen first ask their parents or other legal guardians to explain to them the meaning of this Privacy Policy. We will ask parents or other legal guardians to provide their consent to send some advertisement materials about our future products to individuals under the age of eighteen. We will never collect or process any sensitive personal information concerning children. In case we have concerns about the age of consent or have reasonable doubts about the age of our Services recipients, we will ask for identity, and take immediate actions to erase all personal information and cease its processing as soon as possible.
- CHANGES TO THIS PRIVACY POLICY
We may, in our sole discretion, from time to time amend this Privacy Policy. You are deemed responsible for reviewing this page for the latest information regarding our privacy practices. If you continue to use the Website and (or) our Services after any such amendments come into effect, you acknowledge your acceptance of the amendments made to this Privacy Policy. In case you do not accept the terms of this Privacy Policy and do not want your personal information to be processed in accordance with it, you should discontinue to use the Website and the Services.
- INFORMATION FOR OUR NON-EUROPEAN USERS
- 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 Services, we may collect the following categories of personal information as defined in the CCPA: (i) Identifiers and game consoles 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 Services, in-Game purchase information. (v) 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.
We collect, use and disclose your personal information for the purposes described in Section 2 of this Privacy 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 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.
- Special Notice for the Residents of California.
XTEN collects different types of personal information about you when you use the Services. Anonymized or aggregated information is not personal information.