Privacy and Cookie Policy 1. Introduction 1.1 We are committed to protecting and respecting your privacy. This Privacy and Cookie Policy ("Policy") describes how we treat information that you provide to us or that we collect about you through: • Our websites, including http://www.rimlightstudios.com , and any other Rimlight Studios sites on which this Policy is posted (the "Sites"). • Your signing in by using your Microsoft Xbox Live ID credentials and use of a Rimlight Studios account on any of the Sites (an "Account"). For more information on Accounts and how an Account is created please see our Terms of Use. • Your use of any of our console and video games including, but not limited to, "ZHEROS" on Xbox 360 or Xbox One (the "Games"). Your use of each Game will be subject to the Terms of Use (the "Agreement") in respect of that Game. In this Policy we refer to the Sites, the Account, the Games and the Support Services together as the "Services". 1.2 By information we refer to both personal information (meaning information that, on its own or in combination with other information, can be used to identify you) and also anonymous information (meaning information that does not directly or indirectly identify and cannot reasonably be used to identify you). 1.3 Please read this Policy carefully. If you wish to sign in and use the Services on any of our sites, you will need to accept our Terms of USe and this Policy. If you do not want us to collect, store or use your personal information or do not wish to accept this Policy for any other reason, then please do not sign in and use our Services. If you have any queries, please email us. 2. Who we are We are Rimlight Studios srl, via Trinacria 32/34, Tremestieri Etneo (CT) 95030 - Italy, ("Rimlight Studios", "we", "our" and "us"). We respect your right to privacy and will only process personal information you provide to us in accordance with applicable privacy laws. 3. Information we may collect from you When you use the Services we may collect the following categories of information: • Information you provide when you sign in by using your Microsoft Xbox Live ID credentials, which includes your nick name and email address. You may also choose to provide some other optional information about you. • Location information associated with your IP address when you visit our Sites or use a Game, where we are permitted by law to collect this information. • Information that you post in any of the Games Forums. • Information you provide when you request information or support from us or purchase a product or service from us, including information necessary to process your orders with the relevant payment merchant which may include the amount of any transaction, but will not include your financial information which will only be submitted directly to the payment merchant by you under secure protocols. • Information you provide us when participating in competitions, contests and tournaments and responding to surveys. • Where we obtain your consent, technical information about any device that you use when you visit the Sites or use a Game, including your Media Access Control (MAC), Unique Device Identifier (UDID) or equivalent device identifier, your IP address and the browser you are using. • Information relating to your profiles on social networking sites in order to allow integration with such social networking sites. • Information relating to your use of our Services including, but not limited to, information about when and how you use the Services and data traffic. • Log files and statistics in relation to actions taken on our Sites and in the Games. 4. Cookies 4.1 The Sites use cookies and similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you access the Sites and use the Services. 4.2 A cookie is a small file of letters and numbers that a website places on your computer or device when you visit a website. You were given the opportunity to consent using cookies as you entered our Sites (to get this far, you have already either consented or opted out of their use). If you have opted out, we only store one permanent ‘compliance' cookie which tells us that you want to opt out of use of any other cookies. For more information about cookies, we recommend that you visit www.allaboutcookies.org. 4.3 The cookies that may be used on the Sites fall into the categories described below. These descriptions can help you determine if and how you would like to interact with our Sites and other online services: • Strictly necessary cookies These cookies are essential in order to enable you to navigate the Sites and use certain features. Without these strictly necessary cookies, the online services you have asked for, like shopping baskets or producing your bill at checkout cannot be provided. Consent is not required for strictly necessary cookies as they are required for us to provide the services requested by you. • Performance cookies Our performance cookies collect anonymous information about how you use the Sites and their features. For instance, our performance cookies collect information about which pages on the Sites are visited most often, [if you open or read the communications we send, which advertisements you view or interact with on the Sites or other websites on which our advertisements appears ]and if you receive any error messages. Our performance cookies do not collect information that identifies you personally, however, if you have an Account with us, the information collected by us using our performance cookies may be associated with your Account. [In addition, the coding language the Sites are written in uses session cookies. These are deleted each time you close your browser. These cookies do not store any information about the visitor once the browser is closed.] • Analytics cookies The Sites uses in particular Google Analytics cookies and other cookies of the same kind. These cookies are used to collect information about how visitors use the Sites. The information is collected anonymously, and used to report on the number of visitors to the Sites, where they have come from, and the pages they have visited. You can find out more information on Google Analytics cookies here at: http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html and: http://www.google.co.uk/intl/en/analytics/privacyoverview.html • Functionality cookies Functionality cookies are used to remember choices you make (such as language preference, country location, or other online settings) and collect anonymous information. • Targeting or advertising cookies Third-party targeted advertising cookies may be placed on your device by third-party advertisers, ad networks, data exchanges, marketing analytics and other service providers. Third-party targeted advertising cookies collect information about your browsing activity across multiple websites and online services in order to provide you with relevant advertisements on the websites and online services of third parties. Ad networks may share this information with the advertisers using their network. The information collected using these third-party advertising cookies does not identify you personally. 4.4 If you wish to do so, you can change your browser settings to reject cookies. As the means by which you can do this varies from browser to browser, please visit your web browser's "Help" menu for further details. Please note that, should you choose to refuse cookies, this might impair some of the functionality of the Sites and the Services. 5. How we use your information We may use the information that you provide to us or that we collect about you for the following purposes: • Provide you with the products or services that you request from us. • Provide you with information about other products and services that may be of interest to you and about offers and promotions, where you have opted in to receive such information. If you do not want us to send you e-mail about our products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of each e-mail. • Where you have given us your consent, disclose your personal information to carefully chosen third parties so that they may provide you with information about products and services that may be of interest to you. • Monitor, improve, or modify the Services and our operations. • Detect, investigate and prevent activities that may be illegal, or that may violate the AGREEMENT in respect of any of the Games. 6. Sharing your information 6.1 We will not share your personal information with anyone else unless you have consented to this, other than in limited circumstances including the following: • Where third companies perform services, such as email delivery, platform providing, hosting and payment processing, for the purpose of providing you with products and services that you request from us. However, these companies will only be entitled to use your personal information in order to provide the services requested by us or as may be required by law. • To the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes. • If we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of those business or assets in accordance with applicable data protection laws, or if a third party acquires all (or substantially all) of our business and/or assets, in which case we may disclose your personal data to that third party in connection with the acquisition. • Where necessary to enforce the Terms of Use in respect of any of the Games, to protect the safety of our users and third parties, to protect our rights and property and the rights and property of other users and third parties, or in other cases if we believe in good faith that disclosure is required by law. 6.2 We may share anonymous information and aggregated information (meaning information about groups and categories of users, including game statistics and behavior, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve, or modify their operations. 7. Children We recognize that we have a special obligation to protect personal information obtained from children. We will not knowingly collect personal information from any child without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 13 (or the minimum legal age to consent to the collection and processing of personal information where this is higher under applicable law). 8. Security 8.1 We take reasonable precautions to prevent the loss, misuse or alteration of your personal information. Our employees, contractors and agents may be given access to your personal information which we collect, but their use shall be limited to the performance of their duties in relation to facilitating your use of the Services. Our employees, contractors and agents who have access to your personal information are required to keep that information confidential and are not permitted to use it for any purposes other than those listed above or to deal with requests which you submit to us. 8.2 We have implemented all reasonable technical, administrative and physical security measures to protect the security of your information. However, although we will do our best to protect your information from unauthorized access, disclosure and modification, no security measures are perfect and we cannot guarantee the security of your information nor can any transmission over the Internet can ever be guaranteed to be totally secure and therefore we cannot ensure or warrant the security of any personal information that you transfer over the Internet to us. 9. Third party sites The Services may contain links to other websites operated and services provided by third parties, including those retailers you enter into a transaction with. Please note that this Policy applies only to the personal information that we collect through the Services and we cannot be responsible for personal information that third parties may collect, store and use through their websites or their services. You should always read the privacy policy of each website you visit carefully. 10. Transfers We operate globally and may transfer your personal information to individual companies in the Rimlight Studios group or third parties in locations around the world that are outside the European Economic Area for the purposes described in this Policy. Please be aware that countries that are outside the European Economic Area may not offer the same level of protection as European countries, but we will always take reasonable steps to safeguard the privacy of your personal information and our collection, storage and use of your personal data will continue to be governed by this Policy. 11. Your choices You may, depending on local law, exercise the following choices: • You may ask us to provide you with copies of the personal information that we hold about you at any time, subject to a fee specified by law. • You may ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge. • If you have opted to receive information about other products and services and about offers and promotions, then you may opt out from receiving any further information. If you wish to exercise any of these choices, then please contact us. If you ask us to delete personal information about you then we may retain an archived copy of this information if required to do so by law. 12. Changes to this Policy We may change this Policy from time to time for various reasons such as changes to reflect in law and regulation, changes in industry practices and technological developments. The latest version of this Policy will always be available on the Sites. Any new version of this Policy shall take effect (i) immediately upon the date of posting on the Sites where the changes to this Policy relate to non-material changes which do not reduce your rights; or (ii) no less than thirty (30) days after the date of posting on the Sites where the changes to this Policy potentially reduce your rights. Please make sure you check for updates to this Policy each time you use the Services. 13. Questions and comments If you have any questions or comments about this Policy, please contact us.