INTRODUCTION

Sold Out Sales & Marketing Limited Trading as Fireshine Games (hereinafter “Fireshine Games”, “we”, “our” or “us”) cares about the protection of your personal data and the respect of your privacy. The purpose of this privacy policy is to provide you with clear and transparent information on how we collect, process, store, share and transfer any information that can directly or indirectly identify you (hereinafter “personal data”).

DATA CONTROLLER
Sold Out Sales & Marketing Limited Trading as Fireshine Games, a company registered in England and Wales with company no 6989121 and registered office at 21 Whitefriars Street, London, EC4Y 8JJ, is the data controller of the processing of your personal data implemented as part of your use of our video games and/or websites and further described in this privacy policy.

KEY INFORMATION
Fireshine Games collects certain of your personal data via our video games and/or websites in particular to allow you to subscribe to our newsletter and video games related updates, benefit from the games and services you have requested, and receive promotional and commercial offers when you have given your consent.
Fireshine Games mainly collect identification information and information concerning your use of our video games, (your email address, your name, your username, Steam ID or other platform ID, your password, your IP address, your country and languages). The categories of information we collect in connection with your use of our video games and/or websites, products and services, the purposes and legal basis for which we collect it, are described in the table provided under Section 2 of this Privacy Policy.
You have rights of access to and rectification or erasure of your personal data and to restrict or object to its processing, as well as the right to data portability, which you can exercise at any time by making a written request to us. You also have the right to lodge a complaint about our processing of your personal data with the competent supervisory authority, such as the Information Commissioner’s Office in the United Kingdom (ICO). To the extent, the French data protection legislation is applicable; you have the right to establish instructions in respect of the retention, the deletion and the transmission of your personal data after your death. Where the processing of your personal data relies on your consent, you have the right to withdraw such consent at any time. For more information on your data protection rights, please read Section 4 of the privacy policy.

CHILDREN
Children under the age of 13 years old cannot subscribe directly to Fireshine Games websites or accounts relating to our video games. We do not intentionally collect personal information from children under the age of 13 years old. If we realise that we have collected personal information of a child under 13, or equivalent minimum age depending on jurisdiction concerned, we will delete any personal information related to such child.

CONTACT
If you have any questions or concerns with regard to the processing of your personal data, the exercise of your rights or this privacy policy, feel free to contact us by sending an email to our customer services at customerservice@fireshinegames.co.uk or by post at the following address: Sold Out Sales & Marketing Limited Trading as Fireshine Games, 21 Whitefriars Street, London, EC4Y 8JJ. For more information on the way to contact us for any privacy questions or complaints, please read Section 11 of this privacy policy.

WHAT PERSONAL DATA WE COLLECT AND PROCESS

Fireshine Games collect certain of your personal data via our video games and/or websites in order to provide you with the best game experience, the use of our services and for marketing purposes with your consent. We mainly collect identification and usage information about you. Fireshine Games does not collect or process any transaction data concerning you (e.g., credit card details.

The table set out under Section 2 below describes the categories of personal data Fireshine Games may collect and process as part of the services, websites, or video games, the corresponding purposes and the related legal ground.

The mandatory or optional nature of the personal data collected directly by Fireshine Games will be indicated as such on each collection form made available by Fireshine Games. You should be aware that if you refuse to provide certain personal data whose collection is mandatory, you would not be able to benefit from all or part of the services or features of the video games offered.

FOR WHICH PURPOSE(S) AND ON WHICH LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

Categories of Personal Data	Purpose(s) of the Processing	Legal Basis
Age	To verify if you are 13 years old or above.	To comply with our legal obligation not to process children’s personal information without parental consent or authorization
Third party’s online platform/ stores (e.g. Steam, Epic, GOG) or third party consoles (e.g. Sony PlayStation, Microsoft Xbox, Nintendo Switch etc.) services identification information: name, account’s ID, password, where applicable.	To allow you to register via your existing account on third party’s online platforms/stores such as Steam, Epic, GOG or through the use of third party consoles (e.g. Sony PlayStation, Microsoft Xbox, Nintendo Switch etc.); To provide you with and give you access to additional features and content that you have requested (Mods, etc.); To manage customer relationship; To detect and prevent misuse or improper usage of our video games and services(including moderation of content); and To ensure the security of your personal data and use.	Necessary for the performance of the contract (EULA and specific video games terms & conditions, if any).
Personal information necessary as part of the organisation of video games contests, competitions, survey or promotional operations and campaigns: where relevant, in particular for winners, first name, last name, Email address, home address, date of participation, responses to the video games contests or surveys, nature of the prize if any.	To send you relevant information to participate to the video games contests or surveys; To inform you about events or campaigns in relation to our video games, community, and services; To receive feedbacks from you as part of the community; and To provide you with prizes, if any and where applicable.	Our legitimate interest to vary our services and to assess the quality performance of our video games with our players
Information about your behaviour when using our video games and related services (analytics and statistics related data, existing account ID on third party digital / gaming platforms, crash reports).	To ensure and monitor the effectiveness and availability of the video games and related services provided; To assess the level of performance of our videos games on a regular basis; To generate statistical data relating to the use of the video games and related services (internal gameplay analysis). To carry out market surveys and analysis to improve our video games and users’ experience (internal purposes); and To ensure the security of Fireshine Games’ information systems.	Our legitimate interests: To control and resolve problems with services and to regularly improve services; To develop new functionalities, new products and services; and To maintain an appropriate level of security for our information systems.
Personal information obtained via cookies, analytics and/or tracking technologies set in our video games and/or websites: in particular, unique identifier of a cookie, IP address, identifier of your terminal, device model, types of network, languages and country preferences and location, region, playtime, video games items, progression and statistics, chat logs where applicable etc.	To personalize your game experience; To conduct internal gameplay analysis; To improve users’ experience based on statistical data; To better understand your usage, interests and preferences; and To improve the performance of our video games, our services and websites. (For more information, please read Section 9 of this privacy policy).	For more information on consent mechanisms relating to cookies, please read Section 9 of this privacy policy

3. HOW DO WE GET YOUR PERSONAL DATA?
   3.1 Personal data you provide to Fireshine Games directly
   When you use our video games and related services, you share some information with us, which may directly identify you. In particular:

• Your age;
• Your Steam ID; and/or
• Any other identification number / information when registering via existing accounts created on third party platforms / digital stores such as Epic Games, GOG, where applicable.

In some cases, we may collect your first name, last name, email address and nickname when we organize a video game contest, conduct a survey about one or more of our video games or any other marketing campaigns.

3.2 Personal data Fireshine Games obtains indirectly

We may indirectly collect or receive certain of your personal data, in particular via:

• Cookies and other tracking technologies used in our video games and/or websites to analyse your behaviour when using our video games and/or websites and to assess the performance of our video games (see Section 9 of this Privacy Policy);
• Our third-party distributors and business partners where you have expressly consented to the sharing of your email address for commercial and marketing (e.g., newsletters, promotional offers, etc.).
• Your access to, or use of, some of our video games and services available on certain social networks or other platforms or websites owned by third parties.

(Collectively, the Third Parties).

Please note that this Privacy Policy does not apply to the processing of personal data implemented by Third Parties or on Third Parties’ platforms. Fireshine Games does not supervise or control their respective privacy practices. We recommend that you specifically review the privacy policies available on each of these Third-Party Platforms, in particular regarding the sharing of your personal data.

In any event, Fireshine Games will only process the personal data received indirectly under the terms of this privacy policy.

4. YOUR RIGHTS
   4.1 Your data protection rights

• Your right of access: you have the right to ask us if we are using or storing your personal data. You can also ask us for copies of such personal data.
• Your right to rectification: you have the right to ask us to rectify information you think is inaccurate and to complete information you consider is incomplete.
• Your right to erasure: you have the right to request from us erasure of your personal data when:
  • We no longer need your personal data;
  • You initially consented to the use of your personal data, but have now withdrawn your consent;
  • You have objected to the use of your personal data and your interests outweigh those of Fireshine Games,
  • We have collected or used your personal data unlawfully; and/or
  • We have a legal obligation to erase your personal data.
• Your right to restriction of processing: you have the right to request from us the restriction of the processing of your personal data as follows:
  • Temporarily limit when you have challenged the accuracy of your personal data; or you have objected to the use of your personal data; and /or
  • Limit if we processed your personal data unlawfully without you wishing to delete it; and we no longer need your personal data, but you wish us to keep it in order to defend or exercise legal claims.
• Your right to object to processing: you have the right to object to the processing of your personal data if we are using your personal data for (a) a task carried out in the public interest, (b) our legitimate interests, (c) scientific or historical research or statistical purposes; or (d) direct marketing.
• Your right to data portability: this right applies to personal data you have provided to us and where the processing is automated and based on your consent or made under a contract. You have the right to ask us, if technically feasible, to transfer your personal data to a third party or directly provide it to you in a way accessible and machine-readable.
• You also have the right to withdraw consent at any time where the processing is based on your consent (e.g., cookies, marketing communications), without affecting the lawfulness of processing based on consent before such withdrawal. In particular, you may withdraw your consent for the receiving of commercial communications and marketing offers by clicking on the “Unsubscribe” link included in each marketing communication or by contacting Fireshine Games through the procedures described under Section 4.2 below.
• You have the right to lodge a complaint before a supervisory authority – In United Kingdom, the Information Commissioner’s Office.

Where French data protection law is applicable, you also have the right to set guidelines for the retention and communication of your personal information after your death.

4.2 How to exercise your rights

• You can exercise any of the above listed rights by sending an email at any time to our Customer Services at the following address: help@soldout.uk.com; or
• By post to the following address: Sold Out Sales & Marketing Trading as Fireshine Games, 21 Whitefriars Street, London, EC4Y 8JJ, United Kingdom; or
• You can also directly exercise any of the above listed rights via the contact form directly available on our website.

5. HOW FIRESHINE GAMES PROTECTS YOUR PERSONAL DATA?
   Fireshine Games has implemented and maintains adequate technical, physical and organisational measures to ensure the confidentiality and security of your personal information and to protect your personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. In particular, Fireshine Games relies on encryption mechanisms where technically feasible, restricted internal access and credentials, internal security and IT policies, back-up procedures, and strong contractual commitments and warranties when relying on third party providers.
6. HOW LONG WILL FIRESHINE GAMES KEEP YOUR PERSONAL DATA?
   Fireshine Games will not keep your personal data for longer than necessary (i.e., 5 years from our first contact) and will immediately delete your personal information once the purpose for which they have been collected and processed is achieved.

For more information on the retention of your personal data collected via cookies and tracking technologies, please see Section 9 of this privacy policy.

7. WITH WHOM FIRESHINE GAMES SHARES YOUR PERSONAL DATA?
   As a global organisation involved at all stages of the video game value chain, we may share your personal data with other trusted companies of the Enad Global 7’s group for administrative, technical and operational purposes in relation to the video games and related services offered by Fireshine Games. When trusted group companies (i.e. Toadman Interactive Game Development, Artplant LLC) have access to your personal data, Fireshine Games implements appropriate contractual, technical and organisational measures to ensure that your personal data are only processed to the extent necessary and only for the purposes set out above.
   In addition, Fireshine Games may communicate or share certain of your personal data with our partner development studios, IT services providers and our suppliers acting as processors for technical purposes in order to allow us to offer you high-performance video games and quality services. In particular, the following third parties are involved in the processing of your personal data:

• Amazon Web Services (hosting of gamers’ personal data).
• Pugstorm AB (partner development studio).
• Unity Technologies in relation to Cloud diagnostic solution; and
• Hetzner Online GmbH (physical data server based in Germany).

Finally, Fireshine Games relies on external technologies and platforms to develop or publish its video games and make available its online services. In particular, we closely collaborate with the following business partners:

• Valve Corporation in relation to the access to Steam platform.
• Unity Technologies ApS in relation to the cross-platform game engine (Unity); and
• Microsoft in relation to the use of GitHub NuGet open-source tools.

Fireshine Games implements the necessary contractual and organisational measures to ensure that the processing of your personal data by these third-party providers and business partners is strictly limited to the purposes defined in this privacy policy and to guarantee the confidentiality and security of your personal data.

8. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
   Fireshine Games may transfer some of your personal data outside of the United Kingdom and of the European Economic Area (EEA) when necessary for technical and operational purposes, to enable us to offer you high-performance video games and to provide you with products and services you requested. In particular, we will share or give access to your personal data to our trusted affiliate company Artplant LLC located in Russia. These transfers will be made in compliance with applicable data protection regulations and will rely on appropriate safeguards recognised under the General Data Protection Regulation (GDPR).
   In particular, when the transfer of your personal data cannot be based on an adequacy decision of the European Commission recognising an adequate level of protection, we put in place other appropriate transfer mechanisms and guarantees to ensure the protection of your personal data such as, for example, data transfer agreements including the standard contractual clauses approved by the European Commission or the Privacy Shield for processing carried out in the United States, as the case may be.
9. COOKIES, ANALYTICS AND TRACKING TECHNOLOGIES
   Cookies are small text files that are placed on your computer and devices by us when you use our video games or visit our website. They are widely used in order to make the application and our website work, or work more efficiently, as well as to provide us with more information.
   Fireshine Games uses cookies and other tracking technologies for authentication and security purposes. We would also like to use internal analytical tools or third party analytical metrics to provide you with personalized content and to improve our video games and services based on how you use such video games and services.
   You can manage the use of optional cookies by as instructed in the video game or on the website.
   In any event, cookies and tracking technologies will not be set for more than 6 months following which we will ask your consent again before setting again such cookies and tracking technologies.

9.1 Cookies/tracking technologies set by us and/or third parties
The table below explains the types of cookies and tracking technologies, we use and why:

Source of the Cookie	Category of the Cookies	Purpose(s)	Retention Period
	Necessary cookies	Cookies strictly necessary (i) in order for us to provide you with the services explicitly requested by you; and (ii) to enable you to move around the website / video games and use their related features.	5 Years
Internal cookies / tools	Preferences cookies	To remember your browser and languages preferences.	5 Years
	Authentication cookies	to allow us to identify you once you have logged in; and To allow you to authenticate yourself on successive visits to the website or in video games and gain access to authorized content. These cookies are encrypted.	5 Years
	Security cookies	To increase the security of the service and to detect repeated failed login or similar mechanisms designed to protect you from abuse.	5 Years
Internal analytical tools (e.g., game back end)	Game back-end analytics	We will collect information relating to your playtime, region, game items owned, progression, in game profile, chat logs in order to improve our video games and your experience, to conduct market analysis and to detect technical issues in game (including moderation).	5 Years
Universal analytics (Google)*	Analytics and measurement cookies	These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improving the website. These cookies collect information in a way that does not identify you, including the number of visitors of the website, where visitors have come to the website from and the pages visited.	5 Years
Google Analytics cookies*	Analytics	These cookies allow us to measure the audience on our website based on statistics.	5 Years
YouTube cookies*	Analytics and targeted advertisement	These cookies are used to better understand your interests and preferences. This processing is made in a way that does not enable us to identify you directly or indirectly and is based on aggregated data such as web browsing activity related information, age, gender, regional location.	A year
YouTube video sharing cookies*	Multimedia	These cookies allow you accessing multimedia content / video directly on our website but embedded by YouTube.	5 Years
Facebook Pixel cookies*	Analytics and targeted advertisement	These cookies are used to track conversions and interactions on the website and feed them back to the ad platform so we can determine the effectiveness of our ads. These cookies are also used for online global retargeting based on aggregated data (demographical information, age, gender, regional location, etc.). This processing is made in a way that does not enable us to identify you directly or indirectly.	A year
Twitter cookies*	Analytics and targeted advertisement	These cookies are used to track conversions and interactions on the website and feed them back to the ad platform so we can determine the effectiveness of our ads. These cookies are also used for online global retargeting based on aggregated data (demographical information, age, gender, regional location, etc.). This processing is made in a way that does not enable us to identify you directly or indirectly.	6 months
AdWords Pixel*		These cookies are used to track conversions and interactions on the website and feed them back to the ad platform so we can determine the effectiveness of our ads. This processing is made in a way that does not enable us to identify you directly or indirectly and is based on aggregated data	A year

 

* Any further processing of your personal data by the third parties listed above will be governed by the privacy and cookie policies of the platforms concerned.

9.2 Social networks sharing buttons
Cookies that are set by the following social networks are intended to allow you to facilitate the sharing of content and to improve your experience on our dedicated pages on third parties’ social networks platforms.

• Facebook: see Facebook’s privacy policyand cookies policy ; and
• Twitter: see Twitter’s privacy policyand cookies policy.

Any further processing of your personal data by the social networks listed above will be governed by the privacy and cookie policies of the platforms concerned.

10. CHILDREN’S PRIVACY
    We do not provide services or video games directly or proactively to children under the age of 13 years old nor do we intentionally collect their personal data. If we realise that we have collected personal data of a child under 13 years old, or equivalent minimum age depending on jurisdiction concerned, we will immediately delete any related personal data.
11. HOW TO CONTACT FIRESHINE GAMES

• By sending an email to our Customer Services at the following address: customerservice@fireshinegames.co.uk;
• By post to the following address: Sold Out Sales & Marketing Trading as Fireshine Games, 21 Whitefriars Street, London, EC4Y 8JJ, United Kingdom; or
• You can also directly contact us through the contact form directly available on our website.

12. HYPERLINKS TO OTHER WEBSITES
    You may identify hyperlinks to access the websites of other organisations on our websites or in the content, we provide to you. Please note that this privacy policy does not cover how other third parties may process your personal data. We recommend you to read the privacy policies related to such third party platforms.
13. UPDATES AND CHANGES TO THE PRIVACY POLICY
    We keep our privacy policy under regular review to ensure it is up to date and compliant with the applicable data protection regulation.
    In case of significant changes or modifications, we will inform you of such changes and provide you with a hyperlink to the updated privacy policy 30 days in advance. This information will be provided to you by email and will be made available through a pop-up window when opening the game or visiting the website again.