PRIVACY POLICY

This Privacy Policy sets out the privacy policies and practices for Arcane Embers Game Studio Inc. ("Arcane Embers") with respect to the collection, use, and disclosure of personal and non-personal information.

COLLECTION OF PERSONAL INFORMATION

Arcane Embers generally collects your personal information through:

your access to and use of Arcane Embers' video games and software applications for PC, Console, mobile devices, or other devices ("Arcane Embers Applications"),
your access to and use of any of Arcane Embers' websites (arcaneembers.com) (the "Websites"),
any dealings that you have with Arcane Embers (for example, by contacting Arcane Embers for any purpose), and
third-party organizations, including those that distribute Arcane Embers Applications or who process payments for in-app purchases within the Arcane Embers Applications (including but not limited to: Valve, Epic, Apple, Google, Amazon, Microsoft, Nintendo, and Sony), our advertising partners (including advertising networks, many of which are specifically listed below), and credential management partners, such as Playfab. The type of information that we collect in these circumstances will vary depending on the third party and the type of Arcane Embers Application, but will generally include contact and demographic information such as your user ID, account or registration information, email address, name, age, and location information. When you use a social media credential to log in, additional information we receive may include your public profile (including photo) and friends list.

In certain circumstances, third parties may collect your personal information in connection with your access to and use of the Arcane Embers Applications or the Websites. This includes our advertising partners, such as:

Unity Technologies, who may collect the personal information set out in its privacy policy as it exists from time to time, which policy (as of the date of this Privacy Policy) is located at https://unity3d.com/legal/privacy-policy);
Valve, who may collect the personal information set out in its privacy policy as it exists from time to time, which policy (as of the date of this Privacy Policy) is located at https://store.steampowered.com/privacy_agreement);
Epic Games, who may collect the personal information set out in its privacy policy as it exists from time to time, which policy (as of the date of this Privacy Policy) is located at https://www.epicgames.com/site/en-US/privacypolicy);

Personal information is any information that relates to an identified or identifiable natural person. This might include your name, address, email address, phone number, and sign-in information for third-party social networking services. The personal information that Arcane Embers collects will vary depending on the type of products or services that you are using, including the Websites or Arcane Embers Applications, and how you access and use those products or services, but may include your name, contact information (such as email address, mailing address, fax number, and telephone number), demographic information (such as gender, age, and occupation), your device's IP address, unique device identifier, MAC address, or other transactional or identifier information regarding your device or systems, geolocation information, "cookies", social media information, and personal preferences. This information may also include the length of time you used or played any Arcane Embers Applications, the features of Arcane Embers Applications that you used, your game progress, and other game-related statistics.

Arcane Embers may also collect and analyze non-personal information to evaluate how users use the Websites or Arcane Embers Applications. Such non-personal information may include general technical information about your computer, device, hardware, or software that you use to access the Websites or Arcane Embers Applications, or any of the information described above in circumstances where that information does not relate to an identified or identifiable natural person.

PURPOSE FOR PROCESSING PERSONAL INFORMATION

Arcane Embers may process (for example, collect, use and disclose) information, including personal information, in the following ways:

to develop, deliver, maintain and improve Arcane Embers Applications, the Websites and other Arcane Embers products and services and to better tailor them to meet the needs of Arcane Embers' users, customers and potential customers (including for analytics purposes);
to develop, deliver, maintain and improve Arcane Embers' marketing and promotional efforts and manage its relationship with you;
for third parties to provide Arcane Embers and you with their products and services (including in relation to advertising), including to make ad targeting decisions, conduct audience segmentation and targeting in connection with online behavioural advertising, provide monetization services to their customers, assist their customers with maintaining their services, improving their services, and analyzing the marketplace for their services as well as for the performance of their services, improving their services, and researching and developing new services, for fraud prevention, bot detection, quality rating, analytics, enhancements. These include:
- any purpose for which Unity Technologies, who may collect the personal information set out in its privacy policy as it exists from time to time, which policy (as of the date of this Privacy Policy) is located at https://unity3d.com/legal/privacy-policy;
- any purpose for which GameAnalytics, who may collect the personal information set out in its privacy policy as it exists from time to time, which policy (as of the date of this Privacy Policy) is located at https://gameanalytics.com/privacy);
optimization, viewability, geolocation services, ad security, ad verification services, and service misuse prevention;
to communicate with you in connection with Arcane Embers Applications or the Websites;
to assist law enforcement agencies with the investigation of actual or potential fraud or other offences;
for any other purpose in connection with Arcane Embers' or a third party's legitimate business interests (including in connection with actual or potential the sale, reorganization, or management of all or part of its business or operations);
to establish or exercise legal rights or defend against legal claims; and
as otherwise required or permitted by law.

Any of the foregoing may involve us combining the personal information we collect with personal information collected by third parties, such as our advertising partners, business partners and services providers.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

We rely on your consent to serve as the legal basis for our processing of your personal information in accordance with this Privacy Policy. We may occasionally rely on other legal bases in order to process your personal information in certain ways, for example where the processing is necessary in order to comply with a legal obligation to which Arcane Embers is subject. Where consent serves as the legal basis for our processing of your personal information, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to that withdrawal, by notifying Arcane Embers' privacy officer (contact at the bottom of this Privacy Policy).

SENSITIVE INFORMATION

Sensitive information is defined in the US Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a professional body, criminal records, or health information.

We will not attempt to obtain nor record any sensitive information.

RETENTION OF PERSONAL INFORMATION

Arcane Embers will retain personal information:

in relation to a Arcane Embers Application, until we permanently discontinue the game (we assume you want to be able to restore your gameplay at any time, so we only delete information where we are discontinuing the game and have decided to never restore it); or
otherwise, only as long as necessary for the purposes outlined in this Privacy Policy or as required or permitted by law.

DISCLOSURE OF PERSONAL INFORMATION

Arcane Embers may disclose your personal information to the following organizations or types of organizations:

third party service providers and Arcane Embers' affiliated entities who carry out work on behalf of, or provide products and services to, Arcane Embers,
law enforcement agencies,
legal, financial, insurance, and other advisors, and
as otherwise required or permitted by law.

Arcane Embers will not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. Arcane Embers acts as the controller in relation to your personal information, but there may be some circumstances in which a third party recipient of that information may also act as the controller of that information.

TRANSFER OF PERSONAL DATA OUTSIDE OF THE EU

In certain cases where your personal information has been collected in the EU, that personal data may be transferred outside of the EU. Arcane Embers (or its partners) will take steps to ensure such transfer is carried out in accordance with applicable data protection laws. This includes that any third party recipient outside of the EU will ensure an adequate level of protection, for example, by adhering to the EU-US or Switzerland-US Privacy Shield or entering into the EU standard contractual clauses with the party that transferred that information.

YOUR RIGHTS

When appropriate, you may request to (i) opt-out of receiving communications from Arcane Embers, (ii) remove your personal information from Arcane Embers' records, or (iii) elect to no longer receive information from Arcane Embers. If you wish to opt-out in the manner as listed above, please contact Arcane Embers' privacy officer (contact at the bottom of this Privacy Policy). You may also be able to opt out of the collection and use of your information by third parties for ad targeting purposes through avenues such as http://www.aboutads.info/choices.

In addition, you may have the right in certain circumstances under privacy laws to request from Arcane Embers:

access to,
rectification or erasure of,
restrictions in relation to the processing of (including in relation to direct marketing), and
data portability in relation to,

the personal information that we hold about you.

Please contact Arcane Embers' privacy officer in order to make such a request.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 allows users who are California residents and have provided their personal information to us to request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. To make such a request, please contact our privacy officer (contact at the bottom of this Privacy Policy).

Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year.

PRIVACY OF CHILDREN

Arcane Embers does not knowingly collect personal information from children under 16 without appropriate parental notice and consent. If you are under 16, please do not attempt to use the Arcane Embers Applications or the Websites or send any information about yourself to Arcane Embers, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to Arcane Embers. In the event that Arcane Embers learns that it has collected personal information from a child under age 16 without verification of parental consent, Arcane Embers will delete that information as quickly as possible. If you believe that Arcane Embers might have any information from or about a child under 16, please contact Arcane Embers' privacy officer.

SECURITY

Arcane Embers takes steps to protect the loss, misuse, and alteration of the personal information that it holds. Arcane Embers seeks to limit access to personal information to individuals who Arcane Embers reasonably believes need to access the information to utilize the information as set out in this Privacy Policy. However, it is possible that any information transmitted via the Internet may be intercepted by unknown third parties.

COMPLAINTS

You may direct a written complaint regarding compliance with this Privacy Policy to the privacy officer and, within a reasonable time upon receiving the written complaint, the privacy officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the privacy officer will inform you whether the complaint will be allowed or denied. If the privacy officer allows the complaint, Arcane Embers will take appropriate measures necessary to rectify the source of the complaint. Separately, you may also be able to lodge a complaint with a supervisory authority or privacy commissioner.

LINKS

Arcane Embers is not responsible for the privacy practices of other websites, games or applications, including those that you access via a link provided in the Arcane Embers Applications or on the Websites. Arcane Embers encourages you to read the privacy policy of websites, games or applications operated by third parties. This Privacy Policy applies solely to information collected by Arcane Embers in accordance with the section above entitled "collection of personal information".

CHANGES TO THIS PRIVACY POLICY

Arcane Embers may update this Privacy Policy from time to time. It is your responsibility to periodically review this Privacy Policy to remain informed of Arcane Embers' current privacy practices. The most recent version of this policy can be found at arcaneembers.com/privacy-policy/. Your continued access to or use of the Websites and Arcane Embers Applications after such update constitutes your acceptance of this Privacy Policy as amended.

CONTACT

If you have any questions about this Privacy Policy, Arcane Embers' privacy practices in connection with the Websites or Arcane Embers Applications, please contact Arcane Embers' privacy officer as follows:

Arcane Embers Game Studio Inc.
privacy@arcaneembers.com

Last updated: April 22, 2025