PRIVACY POLICY Last Updated: August 1, 2018 1. DEFINITIONS 2. WHO IS PROCESSING YOUR DATA? 3. WHAT INFORMATION DO WE COLLECT, AND HOW LONG DO WE KEEP IT? 4. WHY DO WE PROCESS YOUR DATA? 5. HOW WE SHARE YOUR DATA 6. INTERNATIONAL TRANSFER 7. WHAT RIGHTS DO I HAVE? 8. TRACKING TECHNOLOGIES 9. INTERNET PROTOCOL 10. SECURITY MEASURES 11. MINORS 12. CONTACT INFORMATION, FURTHER INFORMATION OR COMPLAINTS Universe Projects Inc., its subsidiaries, partners, and affiliates (collectively "UP", "we", "us"), respects the privacy of its online visitors, gamers, and users (collectively "users", "you", "your"), and ensures a secure environment for their data. This document ("Privacy Policy") explains how and why we collect, use, retain, disclose, safeguard and dispose of the information you provide us. UP builds online, mobile, and computer videogames, most of which are generally free to play ("Services"). We may change this Privacy Policy at any time by posting a new version available on our home page. The new version will be effective as of the "Last Update" set out in this Privacy Policy. We will notify you by email, or we will provide a post on our website, if we make material changes to the Privacy Policy and you will have the option to opt-out of our Privacy Policy and Services. This Privacy Policy is incorporated as part of the UP Terms of Service (https://www.universeprojects.com/tos) and applies to all Services provided to you by UP. It does not apply to Services provided to you by third party providers, other individuals, whether such was introduced to you through links on our website or references through our Services or games. 1. DEFINITIONS The following definitions apply in this Privacy Policy: "Consent" means the voluntary, unequivocal, expressed, informed, and unambiguous indication from you stating that you, wish to affirm or agree to this Privacy Policy or permit the processing of your Personal Information. "Controller" means the person or organization responsible for deciding the purpose of processing the Personal Information. "GDPR" means the General Data Protections Regulation, which serves to regulate privacy and data protection for residents of the UK and EU. To read the full text, please visit http://data.consilium.europa.eu/doc/document/ST-5419-2016-INIT/en/pdf. "Personal Information" or "personally identifiable information" means any information related to a natural person or what is sometimes called a 'data subject', whether collected on the internet or not, which can be used to directly or indirectly identify the person (sometimes referred to as 'personal data'). This can be anything from a name, telephone number, photo, email address, bank details, posts on social networking websites, medical information, or a computer internet protocol ("IP") address. Personal Information also includes characteristic, opinions, health, or financial information about/of an individual. "Processing" means any work we do with Personal Information, including how we change Personal Information into non-personally identifiable information or aggregate information (i.e. pseudonymization), whether by automated means or not. This includes collecting, retaining, using, disclosing, and destroying the information. "Third Party" means a person or organization other than the Controller or Processor who is authorized by agreement or contract with the Controller or Processor to access and process the Personal Information. For greater certainty, the terms used in this Privacy Policy have the same meanings as in our Terms of Service, which is available on our website https://www.universeprojects.com/tos. In the case there is a conflict of terms, the interpretation and definitions in the Terms of Service shall apply. 2. WHO IS PROCESSING YOUR DATA? For the purposes of this Privacy Policy, UP is a data controller and processor of your personal data. We are a registered company located at 211-89 Stonehurst Ave, Ottawa, ON K1Y 4R6 For the performance of certain games and platform Services, your data may be controlled by, or pass through, servers used by UP in the United States. 3. WHAT INFORMATION DO WE COLLECT, AND HOW LONG DO WE KEEP IT? We only collect information in relation to our legitimate interests (namely, to provide computer and mobile application games to you), and with your Consent. UP will only retain and process information that is absolutely necessary and will limit access to your Personal Information to those who need it to provide the Services. We do not collect or process Personal Information further than what we require for the basic functionalities of our games and Services. We collect information from or about you in the following ways: Information that is provided and generated when a user creates his or her Account. Most of this data is available to the user by logging into his or her Account and can be updated by the user in the Account settings section. When you register for an Account, we will ask you for your user name, password, email address, date of birth (or confirmation that you have attained the age of majority in your jurisdiction, or have obtained consent from your parent or guardian), and country of origin. This information is mandatory to create an Account and use our Services or games. Information while assisting users through our customer support Services to investigate and address users' concerns and improve our Services. Information gathered or produced during support of our users is retained for up to 5 years to ensure that we address concerns and issues in the best way possible. Information we may request from you to complete customer service requests include your user name, your name, and your email address. Other information may be required if UP needs to verify your identity. Information from users' actions to enable communications between our users in multiple ways, such as chat and on-line gaming ("Forums"). UP will have access to the contents of your communications on any of our Forums for a limited period of time before it is automatically deleted from our servers. Information we collect would include the time and location of your activities, your Account ID or username, and IP address. Server logs. In most cases, server logs are retained for up to 30 days. Information about the devices used to access our Services. UP may collect information on whether you are playing our browser games, mobile games, etc. Information from user or partners to communicate with our users about our current and upcoming products, Services, promotions, studies, surveys, news, updates and events. Data gathered for a specific occurrence such as surveys and giveaways are held no longer than 90 days. Legal records as support for any actual or anticipated legal matter for up to 7 years. This includes litigation, pre-litigation, and dispute resolution information or information pertinent to any such claims or disputes. UGC and Game data generated while a user plays our games. We have access to User Generated Content ("UGC") created or shared by you through our Services or games which may contain your Personal Information or Personal Information of others. We also keep records of users' game licenses, progress, history, stats, in-game purchases and interactions with other users. Information we may find about you available publically or online through social media outlets and platforms including Facebook, Twitter, Instagram, etc. with links to our social media accounts or platforms. WE DO NOT COLLECT, USE, STORE, OR DISCLOSE SENSITIVE INFORMATION RELATED TO YOUR PERSONAL FINANCES OR HEALTH. PLEASE DO NOT SEND US ANY SUCH INFORMATION. 4. WHY DO WE PROCESS YOUR DATA? We process Personal Information and non-identifiable information for our own security, diagnostic, authentication and billing purposes. We collect IP address information to prevent hacking and fraud, and for diagnostics and data traffic analysis to improve our games and Services. UP collects and uses your data for the following legitimate reasons: Gameplay and User Experience. UP collects and uses Personal Information and aggregate information to improve our games and user experience. User Account. UP gamers use an Account to keep track of assets, communicate with friends or other users, and learn about our other games and services. Business optimization and service development. We conduct troubleshooting, research, analysis and product and service development to provide you with the best gameplay experiences and services. Customer Service. We provide you with support to investigate and address any possible difficulty you might experience with our games, your Account or your transactions. Social Features. We enable communications and experience sharing between our users through Forums. Communications with our users. We communicate with our users about Services, marketing, promotions, studies, surveys, news, updates and events. Legal requirements. We may use the information we collect to investigate or address claims or disputes relating to your use of the Services or as otherwise allowed or required by applicable law. This may include litigation, pre-litigation, security monitoring, investigations, and any other legal compliance. UP's legal basis for collecting and processing your Personal Information includes: Providing you with the Services and games, including creating your Account, detecting bugs, addressing fraud, etc.); Offering the best experience to users and gamers; Improving our Services and games; and Providing supplementary Services, like custom Content. For residents and data subjects from the EU, we will ask for Consent before collecting your information. For residents in other jurisdictions, including Canada and the US, wherever possible we will seek your Consent before collecting your Personal Information. By using our Services, downloading our applications or playing our games, you impliedly agree to the collection and use of your Personal Information under this Privacy Policy and in accordance with our Terms of Service. ALL USERS MAY WITHDRAW CONSENT AT ANY TIME. IF YOU WOULD LIKE US TO STOP COLLECTING, USING, RETAINING YOUR PERSONAL INFORMATION, OR REQUEST THAT WE DISPOSE OF YOUR PERSONAL INFORMATION, OR REQUEST TO EXERCISE ANY OF YOUR RIGHTS UNDER THIS ARTICLE, PLEASE EMAIL US AT support@universeprojects.com USING YOUR EMAIL ADDRESS REGISTERED TO YOUR ACCOUNT ON OUR SYSTEMS. ONCE WE VERIFY YOUR IDENTITY, WE WILL DO OUR BEST TO SATISFY YOUR REQUEST AS SOON AS POSSIBLE. 5. HOW WE SHARE YOUR DATA UP generally does not share or disclose your Personal Information to others without notifying you or unless required by law or otherwise set out in this Article. UP websites have Forums where users can exchange ideas and communicate with one another. When posting to a Forum, please be aware that the information is being made publicly available online and the user does so at his or her own risk. Some of UP's products, Services and features require that we share information with other users, our partners and third party providers, or for legal reasons or in the event of a dispute. With partners and third party providers. UP may provide information to third party companies whose services our users may use to facilitate payments, communicate with other users, etc. Our third party providers include: - Paypal - Steam - Google Play Store - Apple App Store - CoinPayments With other users and/or the general public. Information may be viewable by your friends, people in games, or the public in general if you play our games, use certain features in our games, use certain features on our platforms or make posts in the Forums. For legal reasons or in the event of a dispute. UP may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request. This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Service, user agreements or other policies to protect our rights or property or the rights or property of others, or where there is a dispute relating to your use of our Services. In the event that UP's business activities are transferred partly or totally to any third party, such third parties may access your Personal Information. In that case, UP would notify you and allow your Personal Information to be transferred to the acquiring third party. 6. INTERNATIONAL TRANSFER Your personal data will be transferred to and processed in the United States where our servers are located. If you are a European Union data subject or accessing our Services or games from the European Union, be advised that we use European Commission approved contract clauses (Standard Contractual Clauses) to protect your personal data. Where we share data with third party companies or service providers, we use these clauses to protect your data. 7. WHAT RIGHTS DO I HAVE? Right to Access. You may be able to receive a report about the data UP stores about you. Right to be Forgotten. You may have a right to request the deletion of some your data. UP is required by law to retain certain data, which cannot be deleted for a period of time. Right to Object. You may object to the processing of your data or if you wish to ask UP not to process your personal data for direct marketing purposes. Right to Information Accuracy. You can correct your personal data if you feel it is inaccurate or there is an error by logging in to your Account to make the changes. If you think UP's records are inaccurate or there is an error in our information and you cannot make the required changes through your Account, please contact us. Right to Restrict Processing. You can request that your data no longer be processed in certain cases. To request that UP restrict its processing of your Personal Information, please contact us. Right to Data Portability. Data portability is the ability to move data from one company to another (for instance, when you transfer your mobile phone service to another carrier). On request, we will provide you with an electronic file with your most basic account information. To exercise any of your rights in this Section, please contact support@universeprojects.com. UP may request information from you when you contact UP to verify your identity and in order to complete any of the above customer service requests. Under California law, California residents may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer's personal information with unaffiliated third parties for direct marketing purposes without their Consent. If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from UP about new products, services, or promotions, you can do so. You may contact us at support@universeprojects.com. 8. TRACKING TECHNOLOGIES UP may use tracking technologies like cookies, beacons, tags, scripts and unique codes used in apps. We use this technology for various purposes, including our shopping cart, maintenance of user settings (e.g. language preference) and authentication. These technologies are used in analyzing trends, administering the websites or apps, tracking users' movements around the websites or apps and gathering demographic information about our user base as a whole. We also use Local Shared Objects such as Flash cookies and Local Storage such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. "Cookies" recognize any given user who visits multiple website pages during the same session and remembers the user's preferences. When you visit our website, your browser will send cookies to us, which contain the information about your session and preferences. You may block cookies through your browser settings but this may limit your use of our Services. UP may employ third party technological or tools to collect non-personally identifiable information concerning gaming hardware, habits, behaviors and use of our Services or games. The information collected helps us better adapt our Services to your interests. The information may include: 9. INTERNET PROTOCOL An IP address is the unique number that is used by computers on the network to identify your computer every time you log on to the Internet. UP may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused. 10. SECURITY MEASURES We maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We also take reasonable steps to assure that third party service providers to whom we transfer any data will provide sufficient protection of Personal Information and we restrict access to your personal data to only authorized individuals. In addition, we require that members of our team sign agreements regarding confidentiality and maintaining the privacy and security of your information. Some of our security processes include: Encryption of data at rest and in transit; Strict filtering rules; Stateless firewalls; Brute force detection; Additional care to protect your financial information; Secured and monitored facilities; Authorization to access Personal Information only for employees, contractors, and agents who have undergone background checks and signed confidentiality agreements; Vault clusters to store API keys, application passwords and other secrets; and VPN solutions to further secure our servers. For greater certainty, UP does not handle Personal Information for any and all in-game transactions or trades. The unique function of our games allows users to trade directly between each other with little supervision from UP. DESPITE OUR REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE COMPLETE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA. OUR PRIVACY POLICIES AND PROCEDURES ARE "AS IS" AND UP MAKES NO REPRESENTATIONS AS TO THE FITNESS FOR A PARTICULAR PURPOSE OR MERCHANTABILITY. 11. MINORS At the time of Account registration, we require all users to confirm that they have attained the age of majority in their jurisdiction where they reside. If a person who has not attained the age of majority in their jurisdiction registers for an Account, UP is entitled to rely on their representation that they have obtained Consent from their parent or guardian to collect and process their Personal Information under this Privacy Policy. We do not knowingly collect or store any Personal Information from children under the age of majority in the jurisdiction. If parents or guardians believe that we have unintentionally collected their children's personal information, they may request the deletion of the information by contacting us support@universeprojects.com. If you are a parent or guardian and have requested the deletion of any information we have collected or your child has provided to us, be advised that certain Services or game functions may not be available to your child as a user of our Services or games. California residents under the age of 18 have the right to remove, or request the removal of, content or information they have posted to the message boards or forums. This request can be made by contacting us at support@universeprojects.com. Please again be advised that any information posted to the Forums is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive information at any time. Please note that residual copies of content and/or information that have been deleted may remain on our backup servers. We are not required to remove posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted the content or information. AS FAR AS IS PERMITTED BY APPLICABLE LEGISLATION, UP DECLINES ANY RESPONSIBILITY REGARDING ANY ACTIVITIES WHICH MAY BE CONDUCTED BY CHILDREN WITHOUT THE PERMISSION OF THEIR PARENTS OR LEGAL GUARDIANS. 12. CONTACT INFORMATION, FURTHER INFORMATION OR COMPLAINTS If you have questions or concerns regarding data protection at UP, you may contact our Data Protection Officer by emailing: support@universeprojects.com If you are an EU data subject or have accessed our Services or games form the EU, you may contact your EU independent public authority(ies) responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the Union ('supervisory authority'). For any and all other users, if you feel that UP has violated your rights, or if you wish to raise a concern with the data protection authorities, please contact the supervisory authority in the country where you live, work, or where you believe a breach of data protection law has occurred.