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PRIVACY NOTICE
Last updated: 01.06.2025
WHO ARE WE, HOW TO CONTACT US AND WHAT DOES THIS PRIVACY NOTICE COVER?
We, XTEN Limited (we, us, our) with our headquarters in Cyprus have developed the game of UFL (the “Game”) and some other products and services in connection with the Game such as applications, test events and contests. We would collectively refer to them as the “UFL Services”.
This privacy policy (the “Policy”) describes and explains how we may collect, use, share, retain and transfer information about you (you, your, yours) when you interact with the UFL Services. We are the controller of your personal information, and if you have any further questions, please get in touch with us.
OUR CONTACT DETAILS:
Controller: XTEN Limited
To: Data Protection Office
Address: Office 701, 169 Archiepiskopou Makariou III, CEDARS OASIS TOWER, 3027, Limassol, Cyprus.
Email address: privacy@strikerz.inc
You may also contact our data protection officer at dpo@strikerz.inc
Please carefully read the Policy below. We have also included the highlights for each section of this Policy that explain our privacy practices in simplified wordings and make them easier to understand. You should also carefully review any other agreements that apply to the UFL Services before using the UFL Services.
HOW AND WHAT INFORMATION DO WE COLLECT?
HIGHLIGHT: we may collect information about you in three different ways: (i) when you provide it directly to us; (ii) from our partners and service providers that help us run and maintain the UFL Services; (iii) automatically when you use the UFL Services.
The information we collect about you can be divided into the following categories:
(i) General Identification Information: your Steam account ID and Steam username, your in-Game clubs names, your advertising IDs, your Twitch account ID, your Discord ID.
(ii) General Location Information: location information derived from your Internet protocol address, approximate geolocation (region or country), country and city.
(iii) Contact Information: email address.
(iv) Device Information: your game console or platform type, hardware model and settings, device memory information, unique device IDs, system activity.
(v) Game Performance Information: matchmaking, connection, error or crash reports.
(vi) In-Game Statistics Information: your in-Game entitlements, achievements and scores, friends, events, session details, presence and player reviews, time spent in the Game, in-Game purchases and rankings.
2.1. Information You Provide to Us.
You can provide us with the information directly when you use the UFL Services. To create an account and club, you will provide the name of your in-Game clubs (General Identification Information). You can also provide us with an email address (Contact Information) when you act as a legal guardian of a child user and help to start playing the Game or contact our customer support team, when you send a privacy request, when you decide to participate in our test events and contests or other activities.
We may ask you to verify your identity when you make a privacy request to exercise some of your privacy rights so that we comply with the legal requirements and ensure that your personal information remains intact.
If you choose to complete our surveys, participate in test events and contests, we will also receive the information you choose to voluntarily provide so that we will be able to contact you, to let you participate in our events and surveys and to provide you with the appropriate rewards.
2.2. Information From Third Parties (Service Providers and Partners).
We may receive information about you from our partners and service providers when you use the UFL Services.
Our game console partners provide us with your information to connect us: this way we can run the Game, and you can access and play it.
The platform shares with us your user account and proPile information, like your username, your account and online ID, chosen language, (General Identification Information).
The platform also may provide us with the information about your in-Game entitlements, achievements and scores, friends, events, session details, presence and player reviews, time spent in the Game, in-Game purchases and rankings, matchmaking, connection, error or crash reports (In-Game Statistics and Game Performance Information).
Our analytics service providers may share with us your information about your device type, hardware model and settings, unique device IDs (General Identification and Device Information). We will receive such information only in case you have previously agreed to share it for the analytical purposes with the respective service providers.
Social network platforms and streaming service providers may share with us your account ID (General Identification Information) to enable us grant rewards to the winners or participants of our activities.
Our anti-cheat partners, including Easy Anti-Cheat (EAC), may provide us with information related to cheat detection and prevention. This may include monitoring hardware, analyzing software binaries, and scanning hardware memory to detect cheating methods. EAC may gather, store, share, and publish data related to identified cheats, cheating behavior, and cheating codes. This data may be used to identify and ban players engaging in cheating, analyze cheating patterns, and share information about detected cheats with EAC affiliates.
2.3. Information We Collect Automatically.
We can also automatically collect some information that is associated with your access to and use of the UFL Services.
This information would basically include the approximate location information derived from your Internet protocol address, your device region or country (General Location Information), and your device type, hardware model and settings, device memory information, unique device IDs, system activity (Device Information).
We may also automatically collect information when you use the UFL Services. Some of this information may be collected with the help of cookies and similar technologies. Please read more about our cookies used in our Cookie Policy.
HOW DO WE USE YOUR INFORMATION?
HIGHLIGHT: When we use your information, we do it only for particular purposes, and we only use the information about you when we have the right, which means the legal basis for it. We rely on the legal bases that are provided by law: (i) Contractual Obligation; (ii) Legitimate Interest; (iii) Consent; (iv) Legal Obligation.
In more detail, we use your information for the following purposes and on the following legal bases.
(i) Purpose of Processing: Provide the UFL Services to you, like enable you visit and use the Website, the App.
Legal Basis: Contractual Obligation.
Personal Information: Your approximate location information derived from your Internet protocol address, your device region or country, necessary Cookie files.
(ii) Purpose of Processing: Execute an agreement between us; create and Game account and clubs.
Legal Basis: Contractual Obligation.
Personal Information: General Identification, Contact, General Location and Device Information.
(iii) Purpose of Processing: Process your customer support and privacy requests, send you service messages and updates.
Legal Basis: Contractual Obligation and Legal Obligation.
Personal Information: Your game account ID, game online ID and username, your email address or other Contact information.
(iv) Purpose of Processing: Secure the UFL Services and protect you from any illegal or harmful events or actions and ensure your uninterrupted experience.
Legal Basis: Contractual Obligation.
Personal Information: Your approximate location information derived from your Internet protocol address, your device region or country, necessary Cookie files.
(v) Purpose of Processing: Continuously develop and improve the UFL Services by analyzing how you interact with the UFL Services and which features of the UFL Services require modifications, as well as by evaluating your feedback.
Legal Basis: Legitimate Interest to improve the UFL Services or Consent.
Personal Information: Your device hardware model and settings, device memory information, unique device IDs, system activity or other Device Information, information provided in your surveys.
(vi) Purpose of Processing: Comply with our legal obligations, perform or enforce our agreements.
Legal Basis: Legal Obligation.
Personal Information: We may use any information about you, namely any General Identification, Contact, General Location, and Device Information.
(vii) Purpose of Processing: Share some exciting news with you, send you marketing communications and engage you in various marketing or other online activities, provide you with your rewards and prizes.
Legal Basis: Consent.
Personal Information: Your name, email address, country or shipment address, Discord ID, other Contact Information, hardware model and settings, device memory information, unique device IDs, system activity or other Device Information.
(viii) Purpose of Processing: Prevent cheating, unauthorized modifications, and unfair gameplay practices.
Legal Basis: Contractual Obligation.
Personal Information: We may use General Identification, In-Game Statistics, Game Performance, and Device Information.
4. HOW LONG DO WE STORE AND USE YOUR INFORMATION?
HIGHLIGHT: We limit the time when we use and store your information to the period that we reasonably need for the purposes described above unless a longer storage or retention period is required or permitted by law.
The period during which we process your information can vary depending on the type of information involved and the type of your interaction with the UFL Services.
We follow the principle of data minimization and store your information only as long as reasonably necessary, unless a longer retention period is required or allowed by law. We retain data only for purposes outlined in this Policy, such as providing UFL Services, fulfilling contracts, pursuing legitimate interests, conducting audits, meeting legal obligations, resolving disputes, and enforcing agreements.
When determining specific retention periods, we consider legal requirements, our contractual obligations, and the potential for disputes. If you request data deletion, we will verify and fulfil it within the timeframe required by applicable law, unless we are legally required or permitted to retain it longer — for example, to respond to legal claims or government requests related to national security or public interest.
The data we collected as part of Steam Next Fest will be deleted within 6 (six) months from the end of the event.
5. WHO DO WE SHARE YOUR INFORMATION WITH?
HIGHLIGHT: We may share some of the information about you with our partners that help us provide the UFL Services. Without our partners we will not be able to run the UFL Services on our own, but we make sure that your information is safe with our partners.
Here are the types of third parties that we may share your information with:
(i) Game consoles and platforms:
Valve Corporation (USA).
Type: Game Platform.
Role: Controllers.
Data Collected and Purpose: game account credentials for authorisation with the help of the platform.
Privacy Policy: Steam Privacy Policy Agreement
(ii) Service providers (data processors) that help us run and provide the UFL Services, help us analyze how the Services perform and help us spread the word about the Game, such as cloud storage providers, tracking and security service providers, business analytics:
Google LLC (USA)
Type: IT Infrastructure.
Role: Processor.
Data Collected and Purpose: all data for hosting the website on the Google Cloud Platform.
Privacy Policy: Google Privacy
Squarespace Ireland Limited (Ireland)
Type: IT Infrastructure.
Role: Processor.
Data Collected and Purpose: all data for building and maintaining the website on the “zero coding” construction platform.
Privacy Policy: Squarespace Privacy
Usercentrics A.S (Denmark)
Type: IT Infrastructure.
Role: Processor.
Data Collected and Purpose: cookie files choices and settings for the CookieBot management tool.
Privacy Policy: CookieBot Privacy Policy
Zendesk, Inc (USA)
Type: Communications and Customer Support.
Role: Processor.
Data Collected and Purpose: game account credentials for authorisation, information provided in the customer’s request.
Privacy Policy: Zendesk Privacy Notice
Google LLC (USA)
Type: Email communications tool.
Role: Processor.
Data Collected and Purpose: all data containing in the email communications.
Privacy Policy: Google Privacy
The Rocket Science Group LLC d/b/a Mailchimp (USA)
Type: Email communications tool.
Role: Processor.
Data all data containing in the email communications.
Privacy Policy: Mailchimp Privacy Statement
SFDC Ireland Limited (Ireland)
Type: Analytical Tool.
Role: Processor.
Data Collected and Purpose: visualization of the data concerning interaction with the website of its visitors.
Privacy Policy: Salesforce Privacy
Google LLC (USA)
Type: Analytical Tool.
Role: Processor.
Data Collected and Purpose: data concerning interaction with the website for the website maintenance and development.
Privacy Policy Google Privacy
SurveyMonkey Europe UC (Ireland)
Type: Analytical Tool.
Role: Processor.
Data Collected and Purpose: information in the surveys for the Game and Services improvement.
Privacy Policy: SurveyMonkey Privacy
Epic Games, Inc. (USA)
Type: Anti-Cheat tool.
Role: Controller/ processor.
Data Collected and Purpose: detection and prevention of cheating, fraud, or unauthorised behaviour within the game environment.
Privacy Policy: Epic Games Privacy Policy
(iii) Governmental or public authorities for the purposes of law enforcement, national security and other issues of public interest importance.
6. HOW DO WE TREAT CHILDREN’S PRIVACY?
HIGHLIGHT: The information below is for parents or legal guardians of children under the age of 13 or the age of digital consent in the child’s place of residence, whichever is higher. However, we recommend that all persons under the age of 18, notwithstanding their place of residence and the age of digital consent under the local law, first ask their parents or other legal guardians to explain to them the meaning of this Policy.
We develop our UFL Services with the core principles of privacy by default and design, and we aim to make them safe for users of any age. We pay particular attention to protecting the rights of children.
We will never collect or process any sensitive personal information concerning children. In case we have concerns about the age of digital consent or have reasonable doubts about the age of the UFL Services users, we will ask for identity, and take immediate actions to erase all personal information and cease its processing as soon as possible.
We strongly encourage you to observe and appropriately adjust the parental control settings on your applicable platform.
7. HOW CAN YOU CONTROL YOUR INFORMATION?
HIGHLIGHT: We want all users of the UFL Services to be in control of their personal information, and any user can fulfill their privacy rights by contacting us.
Here are the privacy rights that you have with regard to your personal information. To exercise these rights, please send us a request to our contact details listed above or contact our customer support team. Please remember that some of the requests may require your identity verification.
(i) Right of access and portability. You have the right to be informed which personal information about you we process, including the categories of personal information we have, where we receive it from, how and for which purposes we use it, who may have access to this information. You can also request a copy of the personal information about you that we have, and we will provide you with a copy of that information in a commonly used and machine-readable format.
(ii) Right of rectification. You have the right to have any inaccurate or outdated personal information about you corrected or updated. Some of the information may be additionally corrected or updated by you in your Game and club settings.
(iii) Right of erasure. You have the right to delete the personal information about you in the Game and the UFL Services. Please note that in case you send such request, you will no longer have access to your Game account and clubs.
(iv) Right to restriction of processing. You have the right to restrict our use of your personal information in case you claim that we use inaccurate information or that we use your personal information unlawfully.
(v) Right to object to processing. You have the right to object to our use of your personal information when we process it on the bases of Consent, Contractual Obligation, or Legitimate Interest. Please note that in case such information is necessary to defend a legal claim, or under any other legally permitted exception, we will be able to continue use it.
(vi) Right to withdraw your consent. You can withdraw your previously provided consent for our use of your personal information for the particular purposes. However, our processing of your personal information preceding such withdrawal will remain lawful.
(vii) Right to object to automated decision making. You have the right to know, whether we use any automated technologies, including profiling that can have significant impact on you, to object to such use of your personal information and to request a revision by a human. Currently we do not use such technologies.
(viii) Right to lodge a complaint. You can make a complaint against our processing of your personal information by contacting your local supervisory authority for data protection (if there is any in your place of residence). The residents of EEA, UK and Switzerland may find more details about their local supervisory authorities as follows:
EEA list of local authorities
UK: Information Commissioner's Office
Swiss Federal Data Protection and Information Commissioner
However, we would be glad to have an opportunity to first address all of your concerns if you contact us directly as specified in the “Our Contact Details” section above.
8. WHAT ARE THE INTERNATIONAL OPERATIONS YOU SHOULD KNOW ABOUT?HIGHLIGHT: XTEN Limited is headquartered in Cyprus, and we use services from providers that operate globally to help us build a better experience with the UFL Services for all our users. This means that your information may be processed in the systems of our service providers located somewhere abroad from your current place of residence.
We may transfer your personal information in and outside the EEA, UK, Switzerland, the United States of America or elsewhere when we provide the UFL Services. We apply the EU Standard Contractual Clauses approved by the European Commission, the EU-U.S. Data Privacy Framework, the UK International Data Transfer Agreement, the UK Extension to the EU-U.S Data Transfer Agreement, the Swiss-U.S. Data Privacy Framework, and other appropriate mechanisms for any such transfer and ensure that such transfers occur only if there are adequate levels of protection in place.
9. INFORMATION FOR OUR NON-EUROPEAN USERS.
HIGHLIGHT: We are eager to provide all our users around the world with the most accurate information about their rights and to fulfill them at our best. You will find below specialized information for our users around the globe as the UFL Services and our community grow.
9.1. Special Notice for the Residents of California.
The California Consumer Privacy Act (“CCPA”) grants particular rights to consumers residing in California with respect to their personal information. If you are a resident of California, you have the right to: (i) request us to delete, update or correct your personal information; (ii) request to provide you with further information about the categories and specific elements of your personal information that we collect, use, and disclose to third parties for their direct marketing purposes; (iii) request to provide you with the list of the categories of third parties to whom we have disclosed such information; (iv) request to provide you with a portable and transmittable (as technically feasible) copy of your personal information; (v) opt out of sale of your personal information (as defined in the CCPA, if any); and (vi) not be subject to any discrimination when exercising these rights.
You or your authorized agent can send us the requests to our contact details. Please note that we may ask you to verify your identity, or we may ask to verify the authority of your agent before we complete the requests.
When you use the UFL Services, we may collect the following categories of personal information as defined in the CCPA: (i) Identifiers and Game 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 Game device settings and IP address location information. (iii) Protected classifications characteristics such as your age. (iv) Commercial information about your interaction with the UFL Services.
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 3 of this Policy. We do not sell or share your personal information as defined in the CCPA. We shall retain your personal information for the term necessary to provide the UFL Services, and we may also retain the information for a longer period in case we are obligated to do so under the applicable legal provisions or on other legitimate grounds.
10. HOW DO WE SECURE YOUR INFORMATION? HIGHLIGHT: We use our best efforts to keep your information secure, and for that we use only trusted service providers, we continuously train our staff, and we use only secure software and devices.
We maintain appropriate technical and physical safeguards, administrative and organizational measures to protect your personal information from any unlawful, unauthorized or accidental destruction, loss, alteration, access, disclosure, or other unlawful forms of processing. If we become aware of any unauthorized disclosure of your personal information, we will immediately notify you as required by applicable law and do our best to secure your information.
11. HOW DO WE UPDATE THIS POLICY?We will update this Policy from time to time to reflect our latest privacy improvements and changes of the applicable laws. You will see the latest effective date of this Policy in its preamble. We may also notify you of the changes by email or within UFL Services communication channels. Please review this Policy regularly to make sure that you are updated and fully understand our privacy practices.
Last updated: 01.06.2025
WHO ARE WE, HOW TO CONTACT US AND WHAT DOES THIS PRIVACY NOTICE COVER?
We, XTEN Limited (we, us, our) with our headquarters in Cyprus have developed the game of UFL (the “Game”) and some other products and services in connection with the Game such as applications, test events and contests. We would collectively refer to them as the “UFL Services”.
This privacy policy (the “Policy”) describes and explains how we may collect, use, share, retain and transfer information about you (you, your, yours) when you interact with the UFL Services. We are the controller of your personal information, and if you have any further questions, please get in touch with us.
OUR CONTACT DETAILS:
Controller: XTEN Limited
To: Data Protection Office
Address: Office 701, 169 Archiepiskopou Makariou III, CEDARS OASIS TOWER, 3027, Limassol, Cyprus.
Email address: privacy@strikerz.inc
You may also contact our data protection officer at dpo@strikerz.inc
Please carefully read the Policy below. We have also included the highlights for each section of this Policy that explain our privacy practices in simplified wordings and make them easier to understand. You should also carefully review any other agreements that apply to the UFL Services before using the UFL Services.
HOW AND WHAT INFORMATION DO WE COLLECT?
HIGHLIGHT: we may collect information about you in three different ways: (i) when you provide it directly to us; (ii) from our partners and service providers that help us run and maintain the UFL Services; (iii) automatically when you use the UFL Services.
The information we collect about you can be divided into the following categories:
(i) General Identification Information: your Steam account ID and Steam username, your in-Game clubs names, your advertising IDs, your Twitch account ID, your Discord ID.
(ii) General Location Information: location information derived from your Internet protocol address, approximate geolocation (region or country), country and city.
(iii) Contact Information: email address.
(iv) Device Information: your game console or platform type, hardware model and settings, device memory information, unique device IDs, system activity.
(v) Game Performance Information: matchmaking, connection, error or crash reports.
(vi) In-Game Statistics Information: your in-Game entitlements, achievements and scores, friends, events, session details, presence and player reviews, time spent in the Game, in-Game purchases and rankings.
2.1. Information You Provide to Us.
You can provide us with the information directly when you use the UFL Services. To create an account and club, you will provide the name of your in-Game clubs (General Identification Information). You can also provide us with an email address (Contact Information) when you act as a legal guardian of a child user and help to start playing the Game or contact our customer support team, when you send a privacy request, when you decide to participate in our test events and contests or other activities.
We may ask you to verify your identity when you make a privacy request to exercise some of your privacy rights so that we comply with the legal requirements and ensure that your personal information remains intact.
If you choose to complete our surveys, participate in test events and contests, we will also receive the information you choose to voluntarily provide so that we will be able to contact you, to let you participate in our events and surveys and to provide you with the appropriate rewards.
2.2. Information From Third Parties (Service Providers and Partners).
We may receive information about you from our partners and service providers when you use the UFL Services.
Our game console partners provide us with your information to connect us: this way we can run the Game, and you can access and play it.
The platform shares with us your user account and proPile information, like your username, your account and online ID, chosen language, (General Identification Information).
The platform also may provide us with the information about your in-Game entitlements, achievements and scores, friends, events, session details, presence and player reviews, time spent in the Game, in-Game purchases and rankings, matchmaking, connection, error or crash reports (In-Game Statistics and Game Performance Information).
Our analytics service providers may share with us your information about your device type, hardware model and settings, unique device IDs (General Identification and Device Information). We will receive such information only in case you have previously agreed to share it for the analytical purposes with the respective service providers.
Social network platforms and streaming service providers may share with us your account ID (General Identification Information) to enable us grant rewards to the winners or participants of our activities.
Our anti-cheat partners, including Easy Anti-Cheat (EAC), may provide us with information related to cheat detection and prevention. This may include monitoring hardware, analyzing software binaries, and scanning hardware memory to detect cheating methods. EAC may gather, store, share, and publish data related to identified cheats, cheating behavior, and cheating codes. This data may be used to identify and ban players engaging in cheating, analyze cheating patterns, and share information about detected cheats with EAC affiliates.
2.3. Information We Collect Automatically.
We can also automatically collect some information that is associated with your access to and use of the UFL Services.
This information would basically include the approximate location information derived from your Internet protocol address, your device region or country (General Location Information), and your device type, hardware model and settings, device memory information, unique device IDs, system activity (Device Information).
We may also automatically collect information when you use the UFL Services. Some of this information may be collected with the help of cookies and similar technologies. Please read more about our cookies used in our Cookie Policy.
HOW DO WE USE YOUR INFORMATION?
HIGHLIGHT: When we use your information, we do it only for particular purposes, and we only use the information about you when we have the right, which means the legal basis for it. We rely on the legal bases that are provided by law: (i) Contractual Obligation; (ii) Legitimate Interest; (iii) Consent; (iv) Legal Obligation.
In more detail, we use your information for the following purposes and on the following legal bases.
(i) Purpose of Processing: Provide the UFL Services to you, like enable you visit and use the Website, the App.
Legal Basis: Contractual Obligation.
Personal Information: Your approximate location information derived from your Internet protocol address, your device region or country, necessary Cookie files.
(ii) Purpose of Processing: Execute an agreement between us; create and Game account and clubs.
Legal Basis: Contractual Obligation.
Personal Information: General Identification, Contact, General Location and Device Information.
(iii) Purpose of Processing: Process your customer support and privacy requests, send you service messages and updates.
Legal Basis: Contractual Obligation and Legal Obligation.
Personal Information: Your game account ID, game online ID and username, your email address or other Contact information.
(iv) Purpose of Processing: Secure the UFL Services and protect you from any illegal or harmful events or actions and ensure your uninterrupted experience.
Legal Basis: Contractual Obligation.
Personal Information: Your approximate location information derived from your Internet protocol address, your device region or country, necessary Cookie files.
(v) Purpose of Processing: Continuously develop and improve the UFL Services by analyzing how you interact with the UFL Services and which features of the UFL Services require modifications, as well as by evaluating your feedback.
Legal Basis: Legitimate Interest to improve the UFL Services or Consent.
Personal Information: Your device hardware model and settings, device memory information, unique device IDs, system activity or other Device Information, information provided in your surveys.
(vi) Purpose of Processing: Comply with our legal obligations, perform or enforce our agreements.
Legal Basis: Legal Obligation.
Personal Information: We may use any information about you, namely any General Identification, Contact, General Location, and Device Information.
(vii) Purpose of Processing: Share some exciting news with you, send you marketing communications and engage you in various marketing or other online activities, provide you with your rewards and prizes.
Legal Basis: Consent.
Personal Information: Your name, email address, country or shipment address, Discord ID, other Contact Information, hardware model and settings, device memory information, unique device IDs, system activity or other Device Information.
(viii) Purpose of Processing: Prevent cheating, unauthorized modifications, and unfair gameplay practices.
Legal Basis: Contractual Obligation.
Personal Information: We may use General Identification, In-Game Statistics, Game Performance, and Device Information.
4. HOW LONG DO WE STORE AND USE YOUR INFORMATION?
HIGHLIGHT: We limit the time when we use and store your information to the period that we reasonably need for the purposes described above unless a longer storage or retention period is required or permitted by law.
The period during which we process your information can vary depending on the type of information involved and the type of your interaction with the UFL Services.
We follow the principle of data minimization and store your information only as long as reasonably necessary, unless a longer retention period is required or allowed by law. We retain data only for purposes outlined in this Policy, such as providing UFL Services, fulfilling contracts, pursuing legitimate interests, conducting audits, meeting legal obligations, resolving disputes, and enforcing agreements.
When determining specific retention periods, we consider legal requirements, our contractual obligations, and the potential for disputes. If you request data deletion, we will verify and fulfil it within the timeframe required by applicable law, unless we are legally required or permitted to retain it longer — for example, to respond to legal claims or government requests related to national security or public interest.
The data we collected as part of Steam Next Fest will be deleted within 6 (six) months from the end of the event.
5. WHO DO WE SHARE YOUR INFORMATION WITH?
HIGHLIGHT: We may share some of the information about you with our partners that help us provide the UFL Services. Without our partners we will not be able to run the UFL Services on our own, but we make sure that your information is safe with our partners.
Here are the types of third parties that we may share your information with:
(i) Game consoles and platforms:
Valve Corporation (USA).
Type: Game Platform.
Role: Controllers.
Data Collected and Purpose: game account credentials for authorisation with the help of the platform.
Privacy Policy: Steam Privacy Policy Agreement
(ii) Service providers (data processors) that help us run and provide the UFL Services, help us analyze how the Services perform and help us spread the word about the Game, such as cloud storage providers, tracking and security service providers, business analytics:
Google LLC (USA)
Type: IT Infrastructure.
Role: Processor.
Data Collected and Purpose: all data for hosting the website on the Google Cloud Platform.
Privacy Policy: Google Privacy
Squarespace Ireland Limited (Ireland)
Type: IT Infrastructure.
Role: Processor.
Data Collected and Purpose: all data for building and maintaining the website on the “zero coding” construction platform.
Privacy Policy: Squarespace Privacy
Usercentrics A.S (Denmark)
Type: IT Infrastructure.
Role: Processor.
Data Collected and Purpose: cookie files choices and settings for the CookieBot management tool.
Privacy Policy: CookieBot Privacy Policy
Zendesk, Inc (USA)
Type: Communications and Customer Support.
Role: Processor.
Data Collected and Purpose: game account credentials for authorisation, information provided in the customer’s request.
Privacy Policy: Zendesk Privacy Notice
Google LLC (USA)
Type: Email communications tool.
Role: Processor.
Data Collected and Purpose: all data containing in the email communications.
Privacy Policy: Google Privacy
The Rocket Science Group LLC d/b/a Mailchimp (USA)
Type: Email communications tool.
Role: Processor.
Data all data containing in the email communications.
Privacy Policy: Mailchimp Privacy Statement
SFDC Ireland Limited (Ireland)
Type: Analytical Tool.
Role: Processor.
Data Collected and Purpose: visualization of the data concerning interaction with the website of its visitors.
Privacy Policy: Salesforce Privacy
Google LLC (USA)
Type: Analytical Tool.
Role: Processor.
Data Collected and Purpose: data concerning interaction with the website for the website maintenance and development.
Privacy Policy Google Privacy
SurveyMonkey Europe UC (Ireland)
Type: Analytical Tool.
Role: Processor.
Data Collected and Purpose: information in the surveys for the Game and Services improvement.
Privacy Policy: SurveyMonkey Privacy
Epic Games, Inc. (USA)
Type: Anti-Cheat tool.
Role: Controller/ processor.
Data Collected and Purpose: detection and prevention of cheating, fraud, or unauthorised behaviour within the game environment.
Privacy Policy: Epic Games Privacy Policy
(iii) Governmental or public authorities for the purposes of law enforcement, national security and other issues of public interest importance.
6. HOW DO WE TREAT CHILDREN’S PRIVACY?
HIGHLIGHT: The information below is for parents or legal guardians of children under the age of 13 or the age of digital consent in the child’s place of residence, whichever is higher. However, we recommend that all persons under the age of 18, notwithstanding their place of residence and the age of digital consent under the local law, first ask their parents or other legal guardians to explain to them the meaning of this Policy.
We develop our UFL Services with the core principles of privacy by default and design, and we aim to make them safe for users of any age. We pay particular attention to protecting the rights of children.
We will never collect or process any sensitive personal information concerning children. In case we have concerns about the age of digital consent or have reasonable doubts about the age of the UFL Services users, we will ask for identity, and take immediate actions to erase all personal information and cease its processing as soon as possible.
We strongly encourage you to observe and appropriately adjust the parental control settings on your applicable platform.
7. HOW CAN YOU CONTROL YOUR INFORMATION?
HIGHLIGHT: We want all users of the UFL Services to be in control of their personal information, and any user can fulfill their privacy rights by contacting us.
Here are the privacy rights that you have with regard to your personal information. To exercise these rights, please send us a request to our contact details listed above or contact our customer support team. Please remember that some of the requests may require your identity verification.
(i) Right of access and portability. You have the right to be informed which personal information about you we process, including the categories of personal information we have, where we receive it from, how and for which purposes we use it, who may have access to this information. You can also request a copy of the personal information about you that we have, and we will provide you with a copy of that information in a commonly used and machine-readable format.
(ii) Right of rectification. You have the right to have any inaccurate or outdated personal information about you corrected or updated. Some of the information may be additionally corrected or updated by you in your Game and club settings.
(iii) Right of erasure. You have the right to delete the personal information about you in the Game and the UFL Services. Please note that in case you send such request, you will no longer have access to your Game account and clubs.
(iv) Right to restriction of processing. You have the right to restrict our use of your personal information in case you claim that we use inaccurate information or that we use your personal information unlawfully.
(v) Right to object to processing. You have the right to object to our use of your personal information when we process it on the bases of Consent, Contractual Obligation, or Legitimate Interest. Please note that in case such information is necessary to defend a legal claim, or under any other legally permitted exception, we will be able to continue use it.
(vi) Right to withdraw your consent. You can withdraw your previously provided consent for our use of your personal information for the particular purposes. However, our processing of your personal information preceding such withdrawal will remain lawful.
(vii) Right to object to automated decision making. You have the right to know, whether we use any automated technologies, including profiling that can have significant impact on you, to object to such use of your personal information and to request a revision by a human. Currently we do not use such technologies.
(viii) Right to lodge a complaint. You can make a complaint against our processing of your personal information by contacting your local supervisory authority for data protection (if there is any in your place of residence). The residents of EEA, UK and Switzerland may find more details about their local supervisory authorities as follows:
EEA list of local authorities
UK: Information Commissioner's Office
Swiss Federal Data Protection and Information Commissioner
However, we would be glad to have an opportunity to first address all of your concerns if you contact us directly as specified in the “Our Contact Details” section above.
8. WHAT ARE THE INTERNATIONAL OPERATIONS YOU SHOULD KNOW ABOUT?HIGHLIGHT: XTEN Limited is headquartered in Cyprus, and we use services from providers that operate globally to help us build a better experience with the UFL Services for all our users. This means that your information may be processed in the systems of our service providers located somewhere abroad from your current place of residence.
We may transfer your personal information in and outside the EEA, UK, Switzerland, the United States of America or elsewhere when we provide the UFL Services. We apply the EU Standard Contractual Clauses approved by the European Commission, the EU-U.S. Data Privacy Framework, the UK International Data Transfer Agreement, the UK Extension to the EU-U.S Data Transfer Agreement, the Swiss-U.S. Data Privacy Framework, and other appropriate mechanisms for any such transfer and ensure that such transfers occur only if there are adequate levels of protection in place.
9. INFORMATION FOR OUR NON-EUROPEAN USERS.
HIGHLIGHT: We are eager to provide all our users around the world with the most accurate information about their rights and to fulfill them at our best. You will find below specialized information for our users around the globe as the UFL Services and our community grow.
9.1. Special Notice for the Residents of California.
The California Consumer Privacy Act (“CCPA”) grants particular rights to consumers residing in California with respect to their personal information. If you are a resident of California, you have the right to: (i) request us to delete, update or correct your personal information; (ii) request to provide you with further information about the categories and specific elements of your personal information that we collect, use, and disclose to third parties for their direct marketing purposes; (iii) request to provide you with the list of the categories of third parties to whom we have disclosed such information; (iv) request to provide you with a portable and transmittable (as technically feasible) copy of your personal information; (v) opt out of sale of your personal information (as defined in the CCPA, if any); and (vi) not be subject to any discrimination when exercising these rights.
You or your authorized agent can send us the requests to our contact details. Please note that we may ask you to verify your identity, or we may ask to verify the authority of your agent before we complete the requests.
When you use the UFL Services, we may collect the following categories of personal information as defined in the CCPA: (i) Identifiers and Game 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 Game device settings and IP address location information. (iii) Protected classifications characteristics such as your age. (iv) Commercial information about your interaction with the UFL Services.
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 3 of this Policy. We do not sell or share your personal information as defined in the CCPA. We shall retain your personal information for the term necessary to provide the UFL Services, and we may also retain the information for a longer period in case we are obligated to do so under the applicable legal provisions or on other legitimate grounds.
10. HOW DO WE SECURE YOUR INFORMATION? HIGHLIGHT: We use our best efforts to keep your information secure, and for that we use only trusted service providers, we continuously train our staff, and we use only secure software and devices.
We maintain appropriate technical and physical safeguards, administrative and organizational measures to protect your personal information from any unlawful, unauthorized or accidental destruction, loss, alteration, access, disclosure, or other unlawful forms of processing. If we become aware of any unauthorized disclosure of your personal information, we will immediately notify you as required by applicable law and do our best to secure your information.
11. HOW DO WE UPDATE THIS POLICY?We will update this Policy from time to time to reflect our latest privacy improvements and changes of the applicable laws. You will see the latest effective date of this Policy in its preamble. We may also notify you of the changes by email or within UFL Services communication channels. Please review this Policy regularly to make sure that you are updated and fully understand our privacy practices.