INTRODUCTION

Relic Entertainment Inc. (“Relic”, “we”, “us”) is committed to protecting the privacy and security of your personal data. Relic collects different types of information from you when you use our mobile, online and downloadable products and services (together, the "Products").

This Privacy Policy explains how we collect, use and protect your personal data when you use our Products or interact with us.

By using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.

Per data protection legislation, the “data controller” is the party ultimately responsible for collecting and using your personal data. As such, when you purchase a Product from us or otherwise provide us with your personal data, Relic is the data controller. See the 'Your questions and how to contact us' section of this Privacy Policy for more details.

We reserve the right to update this Privacy Policy from time to time. We want you to enjoy using our Products and urge you to follow common sense whenever disclosing personal data – to us, in our Products or elsewhere.

The Products may contain links to third-party websites, plug-ins, features, or services. If you choose to use these sites or features, please note that we do not have control over the third parties that operate these websites and services and are not responsible for their content or privacy practices. We encourage you to read their privacy policies before using their websites or services or giving them your personal information.

If you are a business customer or contact of Relic, including suppliers, vendors, business partners, and similar businesses, please visit Appendix A of this Privacy Policy for information about our processing practices.

SUMMARY

Our Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it. The key points of our Privacy Policy are provided below, however you can also learn more by clicking the ‘learn more’ link below.

We will only collect and process your personal data where we have a lawful basis to do so. As stated throughout this Privacy Policy, our lawful bases include consent, (for example, where you have agreed to receive updates and marketing emails from Relic), contract (when you contract with Relic to use our Products), compliance with our legal obligations, and/or our legitimate business interest in administering our business operations.

1. INFORMATION WE COLLECT AND RECEIVE

We collect personal data about you and the devices you use to access and interact with us and our Products. We collect:

(a) Registration information:	you give us when you sign up to access our Products, or when you wish to register to attend an event or program, hosted or sponsored by Relic
(b) Billing information:	provided by you and/or third party stores
(c) Technical and device information:	information from your mobile or computer device when you use our Products
(d) Feedback / surveys / user research:	your questions, suggestions or views on our Products
(e) Third party information:	information about your use of our Products that is shared with third party platforms and services connected with our Products
(f) Information from publicly available online sources:	information that has been made publicly available by you on third party platforms (such as Facebook or Twitter) and which relates to our Products
(g) Information about your use of our Products:	information we collect when you use our Products
(h) Competitions:	information you provide to us when you participate in our competitions
(i) Social media plug-ins:	information that is collected when you utilize third party social media plug-ins relating to our Products
(j) Anti-cheat and anti-hacking technologies:	information that helps us to ensure our Products are used in a fair and lawful manner
(k) Information from live operations software tools used to make changes, updates or improvements to our Products (“LiveOps Software”):	information that is processed by third party LiveOps tools when you use our Products
(l) User Acquisition/Attribution and Core / Custom / Lookalike Audiences:	information that is collected to help us acquire new users for our Products and to build Core, Custom and Lookalike Audiences

Read further below for more details on the information we collect and/or receive from you.

(A) REGISTRATION INFORMATION

When you register or sign up to use our Products (or a Relic account associated with our Products, such as Games2Gether), or to attend an event or program organized and administered by Relic we may collect information about you including your name, contact details, age, gender, personal preferences and additional information that you chose to provide. You may be required to register with your Platform Operator account ID to use certain features within our Products. We may also collect your contact information so that you can sign-up to receive Relic’s marketing communications. We use tracking pixels in our marketing communications so that we can verify if the e-mail has been opened. As part of any required sign in to use our Products, we will verify the information that you use to log in.

You can choose to sign-up for our Products using third party services such as your Facebook account in which case Facebook will ask you for permission to provide certain personal data such as your username, date of birth, contact details, profile picture, your “likes”, and your friend list, depending on the settings you have selected for such third party services. If you prefer not to have this personal data disclosed when you use third party services, please do not use third party services to access our Products and Services. For information about how third party services, including social networking websites handle your personal data, please refer to their privacy policies and terms of use. Social networking websites may have features that prevent you from modifying certain privacy settings.

(B) BILLING INFORMATION

We may collect payment information such as credit or debit card details (including expiration dates) and other billing information such as your name and address. We may collect this information from you and/or third party stores that have been authorized to sell our Products.

We collect information from your web browsing activity about the way you use our Products. We may also collect information about you from the notifications or messages you post or send online as well as what you search for, look at and engage with. Information obtained from social features used within our Products, such as in-game communications, forums and chat functionality, may be stored, copied or used by Relic, the public, or third-party companies.

By accessing our Products, we may collect technical information from your mobile or computer device, for example your location information where you choose to share this with us, which devices are connected to the Internet, hardware settings, components of your devices, installed software, updates and plugins to facilitate the use of our Products. We may automatically collect information such as your operating system, IP address (the unique address which identifies your device on the internet), your browser type, browser language preferences and when, how often and how long you interact with our Products, websites and services. We, and/or our third party suppliers may use cookies and similar technologies (including but not limited to web beacons and tracking pixels), or collect data about your device(s) to create a device fingerprint of the components of your specific device(s).

We, and our service providers may use cookies and similar technologies (including but not limited to tracking pixels and web beacons (collectively, “ Cookies ”), or collect data about your device(s) to understand how you navigate through and interact with our Products and Services, to learn what content is popular amongst our customers, to enhance the Products, and to provide you with a more relevant and personalized user experience, to save your communication and privacy preferences, and for authentication and advertising purposes, You can learn more about our processing practices when you interact with cookies, by reviewing our Cookies Policy available at https://content.relic.com/legal/cookiepolicy.html . Please note that you may not be able to use certain features relating to our Products and Services if you opt out from receiving Cookies.

Do not track (“ DNT ”) is a privacy preference that is available in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals. Please note that Do Not Track is a different privacy mechanism than the user “preference signal” referenced in the “Californian Privacy Notice” section below. Preference signals are a legally recognized browser-based control that indicates whether you would like to opt out of processing of your personal information for certain purposes, such as the “sale” or “sharing” of your information or the disclosure of your personal information for targeted advertising purposes, under applicable laws.

(D) FEEDBACK / SURVEYS / USER RESEARCH

We will collect personal data from the messages and reviews you post on our social channels and forums, or on the Games2Gether platform, and when you contact us, for example with a question, problem or comment.

If you decide to participate in our surveys you may be asked to provide personal data such as your name and e-mail address, and additional information relevant to the survey, for instance, information about your gaming platforms and habits.

From time to time, Relic carries out user research testing sessions to obtain feedback from our customers about our Products. By participating in these sessions, you may be asked to provide your personal data including your name, address, age and email address. Relic may also film and record these sessions.

(E) THIRD PARTY INFORMATION

We share information obtained about your use of our Products with certain third party partners.

We also receive data about you from Platform Operators and other partners to track and improve the performance of our Products.

(F) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES

Relic uses its own and third-party analytic technologies to collect information about how you use our Products. In doing so, we may collect and analyze information which has been made publicly available by you through third party platforms such as Facebook, Twitter, Reddit and public forums. The data that Relic collects may include a Facebook comment, a Tweet or a post on a public forum, where these specifically relate to our Products.

(G) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS

When you visit or use our Products we collect, process and combine information about your use of those Products, such as your IP address, Platform Operator account information (e.g. the pseudonymized user ID associated with your Xbox or Steam account), hardware and software information, and aggregate gameplay data, usage data and purchase histories. We also receive data about you and your use of our Products from Platform Operators, including but not limited to sales and gameplay data related to your interactions with our Products.

(H) COMPETITIONS

When you participate in a competition organized by Relic, you may be asked to provide certain personal data, such as your name, email address, country of origin and the User ID for the Platform Operator which you use to access our Products (e.g. Steam ID). You may also be required to submit a photograph or video of yourself if this forms part of the entry requirements of the competition.

Winners may be required to provide their address for the purpose of delivering the prizes. Where cash prizes are awarded, you will be prompted to register with our authorized third-party partner that will handle the issuing of the prize payments on our behalf.

The competition you participate in will have its own terms and conditions which will set out the specific requirements in more detail.

(I) SOCIAL MEDIA PLUG-INS

Some Relic sites may include social media plug-ins. These plug-ins allow you to easily share our content via social media platforms such as Facebook and X, most commonly via a “share” or “like” button.

Whenever you launch a Relic webpage that contains a social media plug-in, your browser establishes a connection with the servers of that social media platform. If you decide to utilize the plug-in, by “sharing” or “liking” the content on our website, that data will be shared with the social media platform via your browser.

(J) ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES

Relic strives to ensure that anyone who interacts with our Products, or participates in our competitions and tournaments, does so in a fair and lawful manner. Relic uses anti-cheat and/or anti-hacking technologies to collect certain personal identifiers relating to your use of our Products.

(K) LIVEOPS SOFTWARE

Our Products may include third party LiveOps software which helps us to provide in-game features that are core to your gameplay experience. For example, the software may enable us to offer multiplayer modes, leader boards, in-game rewards and more. The software may also allow Relic to collect data analytics relating to your use of the Product.

(L) USER ACQUISITION / ATTRIBUTION AND CORE / CUSTOM / LOOKALIKE AUDIENCES

We may share your personal data with Facebook, Google, X and other third-party partners for marketing purposes (which may involve acquiring new users for our Products and/or measuring the effectiveness and performance of our marketing campaigns) and to help us build Core Audiences, Custom Audiences and Lookalike Audiences. We will only share your data (typically a device ID or an e-mail address) with these partners with your express consent.

2. OUR USE OF COLLECTED INFORMATION

Collected information may be used in the following ways:

(A) REGISTRATION INFORMATION:

(i) to create your profile and so you can access our Products;
(ii) to identify you when you sign-in;
(iii) to give you access to your user preferences;
(iv) to contact you for your views on our Products;
(v) to notify you of changes or updates to our Products; and
(vi) for marketing purposes, based on your communication preferences.

(B) BILLING INFORMATION:

(i) to verify your purchase of our Products and process any refunds;
(ii) to reply to any queries and questions and to resolve problems;
(iii) to carry out analysis and research to develop our Products; and
(iv) to protect you and our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.

(C) TECHNICAL AND DEVICE INFORMATION:

(i) to provide you with an optimal experience;
(ii) to understand how you interact with our Products
(iii) to provide Products you request;
(iv) to measure and analyze the use and effectiveness of our Products;
(v) to understand which of your devices are using our Products and playing our videogames;
(vi) to provide safe and fair gaming environments;
(vii) to customize and optimize the targeting of our advertising both within our Products and across our websites;
(viii) to operate and improve our Products; and
(ix) to fix errors.

(D) FEEDBACK / SURVEYS / USER RESEARCH:

(i) to reply to your questions or queries;
(ii) to record comments and information which you provide on our gaming forums; and
(iii) to conduct analysis and research to improve and develop our Products.

(E) THIRD PARTY INFORMATION:

(i) to enable us to provide tailored offers to you;
(ii) to facilitate sharing on social networks; and
(iii) to facilitate your gameplay.

(F) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES:

(i) to understand the community sentiment about our Products.

(G) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS:

(i) to track the performance of our Products;
(ii) to communicate with our platform operators and partners; and
(iii) to improve our advertising and targeting systems.

(H) COMPETITIONS:

(i) to verify your identity; and
(ii) to distribute prizes to you.

(I) SOCIAL MEDIA PLUG-INS:

(i) to allow you to easily share our content via social media platforms.

(J) ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES:

(i) to detect illegal or malicious activity in our Products.

(K) LIVEOPS SOFTWARE:

(i) to provide certain in-game features and functionality.

(L) USER ACQUISITION / ATTRIBUTION AND CORE / CUSTOM / LOOKALIKE AUDIENCES:

(i) to acquire new users for our Products, to measure the performance and effectiveness of our marketing campaigns and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.

Read further below for more details on how we use the information we collect and/ or receive from you.

We use the personal data we collect for the following purposes:

(A) REGISTRATION INFORMATION

Your registration information enables us to provide you with access to our Products and to supply the Products, including when you attend an event or program organized and/or administered by Relic. This is necessary for the purpose of performing the contract we have with you or facilitating your attendance at one of our events or programs. It helps us to authenticate your access to our Products, to contact you for your views and to notify you of important changes or updates to our Products or an event which you have registered to attend.

Where we have your consent and in accordance with your stated communication preferences, we may also contact you for marketing purposes to let you know by email, telephone, mobile or in-app messaging about our other products and services.

If you choose to sign-up for our Products using third party services such as your Facebook account, Facebook may share your personal data with us subject to Facebook's privacy policy and the privacy settings of your Facebook account. This may also enable Facebook and us to link your activities with your personal registration information at their site, and may include notifying your friends about your activities whilst using our Products. If you sign-up via third party services you should visit the third party website and review their privacy policy and your registration profile or account to understand how your data is processed by them and to find out what your options are.

If you no longer want us to use your personal data in this way or generally change your mind about receiving marketing communications, you can unsubscribe at any time, either by using the unsubscribe option in the communication you receive or by changing your communication settings. By unsubscribing from marketing communications, you will be opted out of our e-mail/marketing tracking pixels. Please note that we will retain a record of the user information when you unsubscribe from our marketing information for the legitimate purpose of ensuring that we do not contact you further in this way, during the period of your objection, if relevant.

(B) BILLING INFORMATION

This information will enable us to verify your purchases with third party stores and to contact you in order to assist with resolving any problems with your purchases and to process any refund payments that you may be due.

We will also use and analyze information on transactions on your account for our legitimate interests by data matching or statistical analysis so that we can administer, support, improve and develop our business and to help us detect and prevent fraud, or other illegal activities, or acts prohibited by our terms of service or any policies applicable to our Products.

(C) TECHNICAL AND DEVICE INFORMATION

We analyze information about how you engage with our Products to understand how our Products are used and to provide you with an optimal gaming experience, such as by rolling out performance-optimizing software updates for our Products. We use anonymous data in order to analyze and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals. This allows us to deliver you personalized content, helps us understand the features of our Products that appeal to you and allows us to manage advertising, amongst other things.

When you interact with or visit our websites, we may automatically collect information about you such as the type of internet browser or mobile device you use, any website from which you have come to any of our Products and your IP address and your operating system, which are automatically recognized by our web server.

We use internet log files to monitor traffic on our Products, resolve technical problems and to detect and prevent fraud. We use these technologies to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of advertising or marketing on our websites. In some cases, working with third-party partners, we use this information to send you ads for our Products based on your interests.

We also use technical and device information to operate and improve our Products, enable online matchmaking, facilitate sharing, measure our effectiveness, set up and maintain accounts, identify and fix errors and to help keep online content fair and safe and to resolve related disputes.

(D) FEEDBACK / SURVEYS / USER RESEARCH

We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Products. We will also publish reviews that you submit to us for this purpose about our Products and will conduct analysis of feedback for the purpose of improving and developing our Products. Relic may also film and record these sessions so that we can observe your playing habits and record your feedback.

Relic uses the information collected during surveys and user research sessions to help us to tailor and improve our Products.

Relic may share data from user research sessions with certain third-party partners where there is a legitimate business requirement to do so. In such circumstances, your data will always be fully anonymized before it is shared.

(E) THIRD PARTY INFORMATION

We share information obtained from your use of our Products with third parties to provide you with an optimal experience, to facilitate use of our Products as advertised and to enable you to play our Products on various gaming platforms.

We also receive data about you and your use of Products from Platform Operators. This data includes but is not limited to:

(i) sales data so that we can track the sale and performance of our Products; and

(ii) gameplay data related to your interactions with our Products, including player performance statistics, in-game actions, character options and other similar in-game data which helps us to improve certain aspects and features within our Products.

We may use analytics technologies to link your online activities (including across your devices) so that we can serve targeted ads. Valve (the Platform Operator for the Steam digital download platform) may for example share pseudonymized Steam IDs with us to help optimise our offerings to you and to help us understand how you are using our Products. Again, if Valve shares this information with us it does so subject to its privacy policy, and the privacy settings of your Steam account.

We may also work with advertising networks that serve advertisements into our Products, or the websites and products of third parties. Some of those advertisements may be personalized to your interests based on your activity and technical information and/or use data contained within the cookies which are stored on your device, with your consent. Personalization of your experience may be facilitated when our technology partners disclose data, such as your browsing patterns, geolocation, and device identifiers, and this information is matched with the browser and device you are using.

Certain Products are currently supported by third party advertising partners that serve advertisements (“ Third Party Advertisers ”), including behavioral, location or interest based advertising (“ Interest Based Advertising ”) within our Products. These Third Party Advertisers use technology to serve the advertisements and link to them directly into our Products. They may automatically receive your device ID, IP address or geo-location data when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content you see. See also our Cookie Policy at https://content.relic.com/legal/cookiepolicy.html

We may also provide functionality within our Products which enables you to upload gameplay footage to YouTube. If you choose to use this feature, we will receive and store an authentication token from Google so that the feature will operate properly.

The use of this functionality is governed by YouTube’s Terms of Service: https://www.youtube.com/static?template=terms .

Further information about the protection of your privacy can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en-US .

You can also view and modify your permissions via Google’s security settings: https://myaccount.google.com/permissions.

Certain Third Party Advertisers may collect (with your permission) precise location data, or street-level location information, about you (“ Precise Location Data ”). Your mobile device may allow you to opt out of the collection of Precise Location Data by the Third Party Advertiser in the Product through settings on your device. Please note that your mobile device will not share location information without your permission.

(F) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES

We will use and analyze this data for our legitimate interests so that we can collect information about how you use our Products, how you engage with our marketing campaigns and to gain an understanding of community sentiment about our Products. We may use third party analytics providers who collect this data on our behalf.

(G) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS

This information enables us to track the performance of our Products, develop new Products and communicate with our Platform Operators and partners. It also enables us to better understand our users and improve our advertising, targeting and measurement systems. We will only provide tailored advertising where we have your consent. Any information we use to inform and enhance our business strategies is fully anonymized.

(H) COMPETITIONS

Relic collects and processes this data for the purposes of running and monitoring the competition, as well as for carrying out publicity activities relating to the competition.

Your personal data will be retained by Relic for the duration of the competition and for a period after this time as necessary to deliver the prizes (if applicable).

We may offer opportunities to receive certain services or benefits (including virtual or tangible items, competition entry, or monetary prizes when you sign up for communications, participate in surveys or research sessions, or when we are conducting similar incentive based activities, which may require the provision of your personal data for participation (“Incentive Activities”). Your participation in Incentive Activities is purely voluntary. When you participate in Incentive Activities, you agree to the terms of the applicable Incentive Activity and may revoke your participation depending on the nature of the Incentive Activities.

(I) SOCIAL MEDIA PLUG-INS

Once your data has been shared with the social media platform (acting as a joint controller of your data), your interactions with these features are governed by the privacy policies of the relevant platform. More information about their privacy practices can be found at the following links:
https://www.facebook.com/about/privacy/
https://x.com/en/privacy

(J) ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES

Relic may utilize anti-cheat and/or anti-hacking technologies to help us to detect illegal or malicious activity and to take the appropriate actions if such activity is detected.

The anti-cheat/hacking technologies within your Product may require you to download certain data to your device. If you disable or otherwise tamper with these technologies, the Product may not operate properly and you will be in breach of the applicable end user license agreement.

(K) LIVEOPS SOFTWARE

If you play a Product that utilizes LiveOps software, that third party software will collect certain personal data about you as required by that service. This personal data will be processed and stored in accordance with the third party’s privacy policy (as notified to you before your data is collected, most commonly when the Product first launches).

(L) USER ACQUISITION / ATTRIBUTION AND CORE / CUSTOM / LOOKALIKE AUDIENCES

We use various forms of marketing to acquire new users for our Products, working with a variety of third party partners to deliver our marketing campaigns and serve advertisements on external websites and social media platforms. As part of this, we may share certain data with our user acquisition and attribution partners.

If you have consented to this type of marketing, you will receive targeted ads when you use the internet or play our Products (our Custom Audience). Other users of those platforms who share similar interests to you may also receive targeted ads about our Products (our Lookalike Audience). Other users may receive ads about our Products depending on their age, location, gender and language (our Core Audience).

Further information about the protection of your privacy can be found in the relevant partner’s privacy policy. You can disable the remarketing functions by visiting the following links:

Platform	Platform privacy policy	Opt out
Facebook	https://www.facebook.com/about/privacy/	https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
Google	https://policies.google.com/privacy?hl=en&gl=uk	https://support.google.com/google-ads/answer/9606827?hl=en-GB
Amazon	https://www.amazon.co.uk/gp/help/customer/display.html?ie=UTF8&nodeId=201909010&ref_=footer_privacy	https://www.amazon.co.uk/adprefs
X	https://www.x.com/en/privacy	https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads
AppsFlyer	https://www.appsflyer.com/services-privacy-policy/	https://www.appsflyer.com/optout
Gamesight	https://console.gamesight.io/privacy-policy	https://console.gamesight.io/optout

You will need to log in to the social platform to administer your advertising preferences.

We will only collect and process personal data about you where we have a lawful basis. As stated throughout this Privacy Policy, our lawful bases include consent (where you have given consent to, say, receive updates and marketing emails), contract (where processing is necessary for the performance of a contract with you (e.g. to supply the Products you have requested)) and “legitimate interests”.

3. WHEN WE SHARE INFORMATION

We may share the information we collect about you (subject to the necessary security, contractual and transfer safeguards). These are some of the partners we may share your personal data with:

(a) Third party platform operators such as Valve who operate the Steam digital download platform, Sony PlayStation, , Microsoft Xbox, and other partners who carry out various activities and services to support our Products (collectively, the “Platform Operators”);
(b) Marketing partners for marketing or promotions such as Mailchimp, based on your communication preferences;
(c) New owners or re-organized entities and their advisors in the event of a business restructure, sale, purchase or joint venture affecting our business; and
(d) Law enforcement agencies/authorities, when we are under a duty or are authorized by law for law enforcement purposes.

Your personal data may be transferred to other countries where Relic or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access our Products, but we will ensure that we rely on appropriate safeguards.

Read further below for more details on when we share the information which we collect and/or receive from you.

4. SECURITY AND DATA RETENTION

Your privacy is important to us and we place great importance on the steps we take, including technical and organizational measures to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. We cannot guarantee the security of your personal information transmitted to, through, or on our Products and that any such transmission is at your own risk.

Your personal data will be kept by Relic for the duration of your relationship with us and for as long as you use our Products and may be retained for a period after this time if it is necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws.

Where you have chosen a password which allows you to access any of our Products, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We will not be liable for any unauthorized transactions entered into using your personal data, including but not limited to your username, and/or password. If you suspect unauthorized access, you should change your password, using a strong password immediately.

Your personal data will be retained by us for the duration of your use or access to our Products and may be retained for a period after this time as necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce any obligations in our agreements, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings or disputes, fraud prevention, and related security purposes. When determining how long to retain personal data, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our general business operations.

We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.

We will take appropriate steps to seek to destroy or permanently de-identify personal data at the point this information is no longer needed by us for our business or legal purposes.

For more information about exercising your rights with respect to our data processing activities, or if you no longer wish to use our Products, see details below about your choices and rights.

5. YOUR CHOICES AND RIGHTS

You may be required to register or sign in to use or access some of our Products, and may need to provide personal data to create a user profile which is associated with your use of our Products. You have options and choices over how we use your personal data. If you sign up to our marketing communications, you will be asked to confirm your communication preferences and will be given the opportunity to unsubscribe at any time. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you may continue to receive service updates from us, such as to confirm your purchase of one of our Products, updates relating to our policies and practices, or other communications regarding our relationship or transactions with you. Please note that we will retain a record of the user information when you unsubscribe from our marketing information for the legitimate purpose of ensuring that we do not contact you further in this way, during the period of your objection, if relevant.

If you wish to amend the personal data that you use to access our Products or would like us to correct, erase, restrict, object to, or move your personal data, you can make a request by contacting as outlined below:

Please email: dsar@relic.com

We respect the rights you may have under applicable law to request access to your personal data and where applicable, to request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal data, to seek to object to the further processing under certain circumstances of your information or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information.

We reserve the right to charge a reasonable fee for providing access to personal data.

If your request for access or correction is rejected by us, we will notify you of the reasons for the refusal‎ and make a notation of ‎such request and rejection on your file or on our record of the relevant personal data.

If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority

NOTICE OF RIGHT TO OPT OUT OF SALES OF PERSONAL INFORMATION AND PROCESSING/SHARING OF PERSONAL INFORMATION FOR TARGETED ADVERTISING PURPOSES

Depending on your jurisdiction, you may also have the right to opt out of “sales” of your personal information and “sharing/use of your personal information for targeted advertising.”

As explained in the “ When we share information ” section above, we sometimes disclose information to third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under applicable laws.

We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, or use analytics partners to assist us in analyzing use of our services and our user/customer base. The disclosure of your personal information to these third-parties to assist us in providing these services may be considered a “sale” of personal information under applicable law, or, the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective Relic property (Relic and click on the “Your Privacy Choices” link in the footer of the website or settings menu of the app. You must make this choice on each site/app on each browser/device you use to access the services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dsar@relic.com

Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable laws.

6. CHILDREN’S INFORMATION

Protecting the privacy of young children is especially important to Relic . For that reason, Relic does not knowingly collect or maintain personal data or non-personally identifiable information from users under 13 years of age, other than as permitted by law in support of our internal operations.

If Relic learns that personal data of users under the age of 13 has been collected, other than for support of our internal operations, Relic will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal data about your child who is under 13 years of age, you may contact us using the details provided below.

7. REVISIONS TO THIS POLICY

This Policy was last updated on 6/12/2024. We will occasionally update this Policy and revise the “last updated” date above.

To ensure that this Policy is up to date and in compliance with applicable laws, we reserve the right to make changes, which will become effective 30 days following us posting the updated version. If we make any material changes, we will either (a) notify you by email (sent to the email address listed in your account), or (b) provide a notice on our Products or otherwise through our Products before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification, whichever is sooner. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes. Your continued use of our Products signifies your acceptance of any changes to this Policy.

7. CALIFORNIAN PRIVACY NOTICE

The Californian Consumer Privacy Act 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”) Privacy Rights for California Minors in a Digital World, and the Californian Shine the Light law provides Californian residents with certain rights regarding the processing of their “ personal information” or “sensitive personal information”, as defined under the CCPA, and as used throughout the remainder of this section 7.

The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy in relation to the categories of personal information that we have collected from California residents generally, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business and operational purposes.

Categories of personal information collected (see “The Information We Collect” section above for additional information)	Purpose of use	Categories of third parties to whom we disclose the personal information for business and operational purposes (See “How We Disclose the Information We Collect” section above for additional information)
Identifiers such as name, address, phone number, username, and email address; and information about your browser or device such as your IP address and device IDs	Process orders Provide the Products and customer service Verify and authenticate your information, account, and interactions with us Communicate with you Personalize your experience and customize the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Advertising partners and advertisers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Unaffiliated third parties for their advertising purposes Others with your consent
Demographic information such as age or date of birth and gender	Provide the Products and customer service Verify and authenticate your information, account, and interactions with us Personalize your experience and customize the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Advertising partners and advertisers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Unaffiliated third parties for their advertising purposes Others with your consent
Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post	Process orders Provide the Products and customer service Communicate with you Improve the Products Bug detection and error reporting Security, fraud, and legal compliance	Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent
Financial information such as credit card information stored by our payment processors on our behalf	Process orders Communicate with you Verify and authenticate your information, account, and interactions with us Provide the Products and customer service Bug detection and error reporting Security, fraud, and legal compliance	Third party payment processors Entities for legal and security purposes
Transactional information such as information about your transactions with us and related to your attendance at events or programs	Process orders Communicate with you Provide the Products and customer service Improve the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Advertising partners and advertisers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Unaffiliated third parties for their advertising purposes Others with your consent
User-generated content such as any user-generated content you voluntarily decide to provide through the Products, including photographs, or other information you provide in connection with your account	Communicate with you Provide the Products and customer service Improve the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Advertising partners and advertisers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent
Survey, research, feedback, or sweepstakes information such as information you provide in response to a survey or sweepstakes on in relation to the Products	Communicate with you Provide the Products and customer service Improve the Products Understand your interests and engage in research, analysis, and reports Bug detection and error reporting Security, fraud, and legal compliance	Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Unaffiliated third parties for their advertising purposes Others with your consent
Internet network and device activity data such as browsing information and usage information	Provide the Products and customer service Personalize your experience and customize the Products Improve the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Advertising partners and advertisers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent
Geolocation information Such as your approximate location based on IP address	Process orders Provide the Products and customer service Personalize your experience and customize the Products Improve the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Advertising partners and advertisers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent
Information about others such as if you submit information about others	Communicate with you and others Provide the Products and customer service Improve the Products Understand your interests and engage in research, analysis, and reports Our marketing and advertising purposes Bug detection and error reporting Security, fraud, and legal compliance	Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent
Other information Any other information that you provide in the course of using the Products	Purposes of use will depend on the additional information you provide	Disclosure will depend on the additional information you provide

As explained in the ”When we share information” section above, we sometimes disclose information to third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under the CCPA. We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, or use analytics partners to assist us in analyzing the use of our services and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under the CCPA, or the “sharing” of your personal information for purposes of “cross-context behavioral advertising.”

The following chart lists the categories of personal information we have sold or shared over the last 12 months and the categories of third parties to which we have sold or shared such personal information:

Category of personal information	Categories of third parties to which we have “sold” or “shared” such personal information
Identifiers	Advertising partners and advertisers; Unaffiliated third parties for their advertising purposes; Analytics providers
Demographic information	Advertising partners and advertisers; Unaffiliated third parties for their advertising purposes; Analytics providers
Transactional information	Advertising partners and advertisers; Unaffiliated third parties for their advertising purposes; Analytics providers
User-generated content	Advertising partners and advertisers; Analytics providers
Survey, research, or sweepstakes information	Unaffiliated third parties for their advertising purposes; Analytics providers
Internet network and device activity data	Advertising partners and advertisers; Analytics providers
Geolocation	Advertising partners and advertisers; Analytics providers

If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective property (e.g., relic.com or the specific game website or app) and click on the “Your Privacy Choices” link in the footer of the website or settings menu of the app.” You must make this choice on each site/app on each browser/device you use to access the services. You must also renew this choice if you clear your cookies, or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dsar@relic.com. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of children under 16 years of age without legally required affirmative authorization.

Please note that if you have a legally recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable laws.

OTHER CALIFORNIA RIGHTS

The California Civil Code Section 1798.83 (“Shine the Light”) permits our customers who are California residents to request, once per calendar year, the following information from us: (i) a list of the kinds of personal information that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and (ii) the names and addresses of all of the third parties that received personal information from us for direct marketing purposes during the preceding calendar year. For inquiries regarding our disclosure policy, please contact us by emailing dsar@relic.com. Requests must include “Shine the Light Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

California Business and Professions Code Section 22581 (“California Privacy Rights for Minor Users”) permits you, if you are a California resident under the age of 18, to view, correct or remove information provided by you or publicly posted by you. For inquiries regarding our disclosure policy, please contact us by emailing dsar@relic.com. Requests must include “California Privacy Rights for Minor Users Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

8. YOUR QUESTIONS AND HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy you can contact us as set out below:

Please email: dsar@relic.com

We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question. If you are not satisfied with our team’s response to your question or concern, you may be able to file a complaint under applicable privacy laws.

APPENDIX A

Information from suppliers, vendors, business partners, and similar businesses

Contact and Business Information . If you are a company or other organization that we engage with, or a representative of the foregoing, we may collect your name, phone number, email address, and postal address, government identifier, and business name, industry, locations, other information related to your employer, and any other information or personal data that you choose to provide us, including through third-party portals and platforms.
Financial and Transactional Information . If we need to make payments to you or receive payments from you, we may collect financial account and related transactional information.
Communications . If you contact us, we may receive personal data such as your name, email address, and phone number. We will also receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding our Products, services we provide to each other, an account you hold with us, or other topics you might raise.
Events and Programs . If you register for or attend an event or program that we host, sponsor, or attend, we may receive information such as your name, email address, phone number, and other personal data related to your attendance at the event or program from those who interact with or express interested in Relic or our Products.
Surveys, Promotions, Competitions and Gifting . If you decide to participate in any surveys, promotions, competitions or our gifting activities, you may provide certain personal data, such as basic contact information and other information relevant to the survey, promotion, competition or gifting activity.

We will process and retain this information and the related personal data for as long as necessary to perform our legitimate business activities in accordance with applicable laws and our business data retention policy.