This privacy policy for Spartan Games (“we,” “us,” or “our“), describes how and why we might
collect, store, use, and/or share (“process“) your information when you use our services
(“Services“), such as when you:

● Visit our website at https://spartan-games.com, or any website or service of ours that links to this
privacy policy

● Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy policy will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns, please contact us at
support@spartan-games.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy policy, but you can find out more
details about any of these topics by clicking the link following each key point or by using
our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services,
we may process personal information depending on how you interact with us and the Services,
the choices you make, and the products and features you use. Learn more about personal
information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal
information.

Do we collect any information from third parties? We do not collect any information from
third parties.

How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do so. Learn more about
how we process your information.

In what situations and with which types of parties do we share personal information? We
may share information in specific situations and with specific categories of third parties. Learn
more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no electronic transmission
over the internet or information storage technology can be guaranteed to be 100% secure, so
we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. Learn more
about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us.
We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy policy in full.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on
the context of your interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may include the following:
● names
● phone numbers
● email addresses
● usernames
● passwords
● contact preferences
● billing addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make
purchases, such as your payment instrument number, and the security code associated with
your payment instrument. All payment data is handled and stored by WooPayments and Stripe.
You may find their privacy policy link(s) here: https://automattic.com/privacy/ and
http://www.stripe.com/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

● Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our
Services and which we record in log files. Depending on how you interact with us, this
log data may include your IP address, device information, browser type, and settings and
information about your activity in the Services (such as the date/time stamps associated
with your usage, pages and files viewed, searches, and other actions you take such as
which features you use), device event information (such as system activity, error reports
(sometimes called “crash dumps”), and hardware settings).
● Device Data. We collect device data such as information about your computer, phone,
tablet, or other device you use to access the Services. Depending on the device used,
this device data may include information such as your IP address (or proxy server),
device and application identification numbers, location, browser type, hardware model,
Internet service provider and/or mobile carrier, operating system, and system
configuration information.
● Location Data. We collect location data such as information about your device’s location,
which can be either precise or imprecise. How much information we collect depends on
the type and settings of the device you use to access the Services. For example, we
may use GPS and other technologies to collect geolocation data that tells us your
current location (based on your IP address). You can opt out of allowing us to collect this
information either by refusing access to the information or by disabling your Location
setting on your device. However, if you choose to opt out, you may not be able to use
certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:

● To facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
● To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
● To respond to user inquiries/offer support to users. We may process your
information to respond to your inquiries and solve any potential issues you might have
with the requested service.
● To send administrative information to you. We may process your information to send
you details about our products and services, changes to our terms and policies, and
other similar information.
● To fulfill and manage your orders. We may process your information to fulfill and
manage your orders, payments, returns, and exchanges made through the Services.
● To request feedback. We may process your information when necessary to request
feedback and to contact you about your use of our Services.
● To send you marketing and promotional communications. We may process the
personal information you send to us for our marketing purposes, if this is in accordance
with your marketing preferences. You can opt out of our marketing emails at any time.
For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
● To deliver targeted advertising to you. We may process your information to develop
and display personalized content and advertising tailored to your interests, location, and
more.
● To protect our Services. We may process your information as part of our efforts to keep
our Services safe and secure, including fraud monitoring and prevention.
● To identify usage trends. We may process information about how you use our Services
to better understand how they are being used so we can improve them.
● To determine the effectiveness of our marketing and promotional campaigns. We
may process your information to better understand how to provide marketing and
promotional campaigns that are most relevant to you.
● To save or protect an individual’s vital interest. We may process your information
when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we
have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent,
to comply with laws, to provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid
legal bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:

● Consent. We may process your information if you have given us permission (i.e.,
consent) to use your personal information for a specific purpose. You can withdraw your
consent at any time. Learn more about withdrawing your consent.
● Performance of a Contract. We may process your personal information when we
believe it is necessary to fulfill our contractual obligations to you, including providing our
Services or at your request prior to entering into a contract with you.
● Legitimate Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and those interests do
not outweigh your interests and fundamental rights and freedoms. For example, we may
process your personal information for some of the purposes described in order to:
● Send users information about special offers and discounts on our products and
services
● Develop and display personalized and relevant advertising content for our users
● Analyze how our Services are used so we can improve them to engage and retain
users
● Support our marketing activities
● Diagnose problems and/or prevent fraudulent activities
● Understand how our users use our products and services so we can improve user
experience
● Legal Obligations. We may process your information where we believe it is necessary
for compliance with our legal obligations, such as to cooperate with a law enforcement
body or regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
● Vital Interests. We may process your information where we believe it is necessary to
protect your vital interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your
information without your consent, including, for example:

● If collection is clearly in the interests of an individual and consent cannot be obtained in
a timely way
● For investigations and fraud detection and prevention
● For business transactions provided certain conditions are met
● If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
● For identifying injured, ill, or deceased persons and communicating with next of kin
● If we have reasonable grounds to believe an individual has been, is, or may be victim of
financial abuse
● If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a contravention of the
laws of Canada or a province
● If disclosure is required to comply with a subpoena, warrant, court order, or rules of the
court relating to the production of records
● If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the information
was produced
● If the collection is solely for journalistic, artistic, or literary purposes
● If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with
the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data
with third-party vendors, service providers, contractors, or agents (“third parties”) who perform
services for us or on our behalf and require access to such information to do that work. We have
contracts in place with our third parties, which are designed to help safeguard your personal
information. This means that they cannot do anything with your personal information unless we
have instructed them to do it. They will also not share your personal information with any
organization apart from us. They also commit to protect the data they hold on our behalf and to
retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

● Website Hosting Service Providers
● Sales & Marketing Tools
● Payment Processors

We also may need to share your personal information in the following situations:

● Business Transfers. We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of
all or a portion of our business to another company.
● Affiliates. We may share your information with our affiliates, in which case we will
require those affiliates to honor this privacy policy. Affiliates include our parent company
and any subsidiaries, joint venture partners, or other companies that we control or that
are under common control with us.
● Business Partners. We may share your information with our business partners to offer
you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather
information when you interact with our Services. Some online tracking technologies help us
maintain the security of our Services and your account, prevent crashes, fix bugs, save your
preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our
Services for analytics and advertising, including to help manage and display advertisements, to
tailor advertisements to your interests, or to send abandoned shopping cart reminders
(depending on your communication preferences). The third parties and service providers use
their technology to provide advertising about products and services tailored to your interests
which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which
includes targeted advertising, as defined under the applicable laws) under applicable US state
laws, you can opt out of these online tracking technologies by submitting a request as described
below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?“
Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Policy.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your
own.

Our servers are located in the United States and Germany. If you are accessing our Services
from outside the United States and Germany, please be aware that your information may be
transferred to, stored, and processed by us in our facilities and by those third parties with whom
we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE
YOUR PERSONAL INFORMATION?” above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or
Switzerland, then these countries may not necessarily have data protection laws or other similar
laws as comprehensive as those in your country. However, we will take all necessary measures
to protect your personal information in accordance with this privacy policy and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the
European Commission’s Standard Contractual Clauses for transfers of personal information
between our group companies and between us and our third-party providers. These clauses
require all recipients to protect all personal information that they process originating from the
EEA or UK in accordance with European data protection laws and regulations. Our Data
Processing Agreements that include Standard Contractual Clauses are available here: https://spartan-games.com/data-processing-agreement/. We have implemented similar appropriate safeguards with
our third-party service providers and partners and further details can be provided upon request.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in
this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set
out in this privacy policy, unless a longer retention period is required or permitted by law (such
as tax, accounting, or other legal requirements). No purpose in this notice will require us
keeping your personal information for longer than the period of time in which users have an
account with us.

When we have no ongoing legitimate business need to process your personal information, we
will either delete or anonymize such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and
technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission over
the Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor
do we knowingly sell such personal information. By using the Services, you represent that you
are at least 18 or that you are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take reasonable measures
to promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at support@spartan-games.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the
European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have
rights that allow you greater access to and control over your personal information. You may
review, change, or terminate your account at any time, depending on your country, province, or
state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; (iv) if applicable, to data portability; and (v) not to be
subject to automated decision-making. In certain circumstances, you may also have the right to
object to the processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your Member State data protection authority
or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link in
the emails that we send, or by contacting us using the details provided in the section “HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the
marketing lists. However, we may still communicate with you — for example, to send you
service-related messages that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate
your account, you can:

● Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms
and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If
you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.
If you choose to remove cookies or reject cookies, this could affect certain features or services
of our Services.

If you have questions or comments about your privacy rights, you may email us at
support@spartan-games.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in a
revised version of this privacy policy.

California law requires us to let you know how we respond to web browser DNT signals.
Because there currently is not an industry or legal standard for recognizing or honoring DNT
signals, we do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana,
Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or
Virginia, you may have the right to request access to and receive details about the personal
information we maintain about you and how we have processed it, correct inaccuracies, get a
copy of, or delete your personal information. You may also have the right to withdraw your
consent to our processing of your personal information. These rights may be limited in some
circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12)
months:

We may also collect other personal information outside of these categories through instances
where you interact with us in person, online, or by phone or mail in the context of:
● Receiving help through our customer support channels;
● Participation in customer surveys or contests; and
● Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or
for:
● Category A – As long as the user has an account with us
● Category B – As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO
WE COLLECT?”

How We Use and Share Personal Information

Learn about how we use your personal information in the section, “HOW DO WE PROCESS
YOUR INFORMATION?“

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Learn more about how we disclose personal
information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?“

We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
“selling” of your personal information.

We have not sold or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months.

The categories of third parties to whom we disclosed personal information for a business or
commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?“

Your Rights

You have rights under certain US state data protection laws. However, these rights are not
absolute, and in certain cases, we may decline your request as permitted by law. These rights
include:

● Right to know whether or not we are processing your personal data
● Right to access your personal data
● Right to correct inaccuracies in your personal data
● Right to request the deletion of your personal data
● Right to obtain a copy of the personal data you previously shared with us
● Right to non-discrimination for exercising your rights
● Right to opt out of the processing of your personal data if it is used for targeted
advertising (or sharing as defined under California’s privacy law), the sale of personal
data, or profiling in furtherance of decisions that produce legal or similarly significant
effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

● Right to obtain a list of the categories of third parties to which we have disclosed
personal data (as permitted by applicable law, including California’s and Delaware’s
privacy law)
● Right to obtain a list of specific third parties to which we have disclosed personal data
(as permitted by applicable law, including Oregon’s privacy law)
● Right to limit use and disclosure of sensitive personal data (as permitted by applicable
law, including California’s privacy law)
● Right to opt out of the collection of sensitive data and personal data collected through
the operation of a voice or facial recognition feature (as permitted by applicable law,
including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at support@spartan-games.com, or
by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a
request on your behalf. We may deny a request from an authorized agent that does not submit
proof that they have been validly authorized to act on your behalf in accordance with applicable
laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. We will only use personal
information provided in your request to verify your identity or authority to make the request.
However, if we cannot verify your identity from the information already maintained by us, we
may request that you provide additional information for the purposes of verifying your identity
and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request and the agent will need to
provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request,
you may appeal our decision by emailing us at support@spartan-games.com. We will inform
you in writing of any action taken or not taken in response to the appeal, including a written
explanation of the reasons for the decisions. If your appeal is denied, you may submit a
complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our
users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your request in writing
to us by using the contact details provided in the section “HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?“

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by
Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

This privacy policy satisfies the notice requirements defined in both Privacy Acts, in particular:
what personal information we collect from you, from which sources, for which purposes, and
other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable
purpose, it may affect our ability to provide our services, in particular:

● offer you the products or services that you want
● respond to or help with your requests
● manage your account with us
● confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information.
You can make such a request by contacting us by using the contact details provided in the
section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?“

If you believe we are unlawfully processing your personal information, you have the right to
submit a complaint about a breach of the Australian Privacy Principles to the Office of the
Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the
Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information.
You can make such a request by contacting us by using the contact details provided in the
section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?“

If you are unsatisfied with the manner in which we address any complaint with regard to our
processing of personal information, you can contact the office of the regulator, the details of
which are:

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za &
POPIAComplaints@inforegulator.org.za

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by an
updated “Revised” date at the top of this privacy policy. If we make material changes to this
privacy policy, we may notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this privacy policy frequently to
be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at
support@spartan-games.com.

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the
right to request access to the personal information we collect from you, details about how we
have processed it, correct inaccuracies, or delete your personal information. You may also have
the right to withdraw your consent to our processing of your personal information. These rights
may be limited in some circumstances by applicable law. To request to review, update, or delete
your personal information, please email us at: support@spartan-games.com.