Game Privacy Policy

June 03, 2024 by Join Ufl

Last updated: 23.10.2024

WHO ARE WE, HOW TO CONTACT US AND WHAT DOES THIS PRIVACY POLICY COVER?
We, XTEN Limited (we, us, our) with our headquarters in Cyprus have developed the game of UFL (the “Game”) and some other products and services in connection with the Game such as applications, test events and contests. We would collectively refer to them as the “UFL Services”.

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

OUR CONTACT DETAILS:
Controller: XTEN Limited
To: Data Protection Office
Address: Office 701, 169 Archiepiskopou Makariou III, CEDARS OASIS TOWER, 3027, Limassol, Cyprus
Email address: support@uflgame.com
You may also contact our data protection officer at support@uflgame.com.

Please carefully read the Policy below. We have also included the highlights for each section of this Policy that explain our privacy practices in simplified wordings and make them easier to understand. You should also carefully review any other agreements that apply to the UFL Services, and confirm you understand and agree to them, before using the UFL Services.
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:
1. General Identification Information: your game console account ID, game console online ID and username, your age or age group, any game console account parental control restrictions, your in-Game clubs names, your advertising IDs, your Twitch account ID.
2. General Location Information: location information derived from your Internet protocol address, approximate geolocation (region or country).
3. Contact Information: email address, postal address.
4. 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.
5. Game Performance Information: matchmaking, connection, error or crash reports.
6. Device Information: your game console or platform type, hardware model and settings, device memory information, unique device IDs, system activity.
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. 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 game consoles share with us your user account and profile information, like your username, your account and online ID, chosen language, your age or age group, any parental control restrictions (General Identification Information).
  
  The game consoles also 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 advertising and analytics service providers may share with us your advertising IDs, and information about your game console or platform 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 advertising and analytical purposes with our 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.
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 game console region or country (General Location Information), and your game console or platform type, hardware model and settings, device memory information, unique device IDs, system activity (Device Information).
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.
1. Execute an agreement between us, create and verify your Game account and clubs. We will use your General Identification, Contact, General Location and Device Information, and we rely on the Contractual Obligation basis for these purposes
2. Provide the UFL Services to you, most importantly, let you play the Game. For this we will use your General Identification, Contact, General Location, In-Game Statistics, Game Performance and Device Information on the Contractual Obligation basis.
3. Process your customer support and privacy requests, send you service messages and updates. We will use your General Identification, Contact, General Location, In-Game Statistics, Game Performance and Device Information on the Contractual Obligation and Legal Obligation bases.
4. Secure the UFL Services and protect you from any illegal or harmful events or actions and ensure your uninterrupted game experience. We will use your General Identification, General Location, In-Game Statistics, Game Performance and Device Information for these purposes on the Contractual Obligation basis.
5. Continuously develop and improve the Game and other UFL Services. We will use your General Identification, General Location, In-Game Statistics and Game Performance Information on our Legitimate Interest basis.
6. Hold and manage test events, early access events, contests, collect and analyze your feedback and grant rewards to the winners or participants of our activities. We will use your General Identification, Contact, In-Game Statistics, Game Performance, Device Information, and any information that you share with us voluntarily in the surveys on basis of our Legitimate Interest or your Consent, in case it is required in particular circumstances.
7. Promote the Game and other UFL Services efficiently by analyzing and measuring the effectiveness of our marketing campaigns. We will use your General Identification and Device Information on basis of your Consent.
8. Show you a more tailored in-Game advertising content. For this we will use your General Identification, General Location and In-Game Statistics information on basis of your Consent.
9. Comply with our legal obligations, perform or enforce our agreements. We will use your General Identification, Contact, General Location, In-Game Statistics, Game Performance and Device Information on the Contractual or Legal Obligation bases.
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 are always guided by the principle of data minimization and we store your information only as long as we reasonably need, unless a longer retention period is required or permitted by law, and only for the purposes designated in this Policy, like providing the UFL Services and fulfilling our contractual obligations, pursuing our legitimate business interests, conducting audits, complying with our legal obligations, resolving disputes, and enforcing our agreements.

When we determine specific retention periods, we always consider the minimum requirements under applicable laws, our contractual and other legal obligations, possible litigation or similar proceedings. For example, your In-Game Statistics Information will only be retained for the duration of the Game football season period, whilst your General Identification Information will be retained as long as you play the Game and your game console account is active, unless you decide to delete your game console account or the Game account. In case you submit a request to delete your information, we shall verify and fulfill it within the time required by the applicable laws, unless we have a legal right or obligation to retain the information for a longer period. This may be the case, when there is a possibility to hold defense against a legal claim, or when there is a request for the information provision from a governmental authority, including for such reasons as national security or public interests protection.
WHO DO WE SHARE YOUR INFORMATION WITH?
HIGHLIGHT: We may share some of the information about you with our partners that help us provide the UFL Services. Without our partners we will not be able to run the UFL Services on our own, but we make sure that your information is safe with our partners.

Here are the types of third parties that we may share your information with:
1. Game consoles. Microsoft Corporation (USA) and Microsoft Ireland Operations Limited (Ireland). Sony Interactive Entertainment Group of companies: Sony Interactive Entertainment, Inc. (Japan), Sony Interactive Entertainment LLC (USA), and Sony Interactive Entertainment Europe Limited (UK).
2. Service providers (data processors) that help us run and provide the UFL Services, help us analyze how our Game performs and help us spread the word about the Game, such as cloud storage providers, tracking and security service providers, business analytics, marketing and advertising partners.
3. Governmental or public authorities for the purposes of law enforcement, national security and other issues of public interest importance.
HOW DO WE TREAT CHILDREN’S PRIVACY?
HIGHLIGHT: The information below is for parents or legal guardians of children under the age of 13 or the age of digital consent in the child’s place of residence, whichever is higher. However, we recommend that all persons under the age of 18, notwithstanding their place of residence and the age of digital consent under the local law, first ask their parents or other legal guardians to explain to them the meaning of this Policy.

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

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

We will at all times respect and be compliant with the parental controls of the game consoles. We will only collect and use the personal information of a child in accordance with the consent and permission that a parent or another legal guardian has granted to the game console. 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.
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.
1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. Right to withdraw your consent. You can withdraw your previously provided consent for our use of your personal information for the particular purposes.
7. 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.
8. 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:
  1. EEA: list of local authorities at: https://edpb.europa.eu/about-edpb/board/members_en
  2. UK: Information Commissioner's Office at: https://ico.org.uk/global/contact-us/
  3. Switzerland: Federal Data Protection and Information Commissioner at: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
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.
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.
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.
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 console account login information. We may collect your username, account name, your online identifiers and device identifiers, IP address. (ii) Approximate geolocation information based on your console settings and IP address location information. (iii) Protected classifications characteristics such as your age. (iv) Commercial information about your interaction with the UFL Services, in-Game purchase information. (v) Electronic information that you share when you play the Game.
  
  We can also receive and process other categories of your personal information in case you contact our customer support team.
  
  We collect, use and disclose your personal information for the purposes described in Section 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.
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.
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.