Privacy Notice of Singularity 6 Corporation

The Singularity 6 team is dedicated to crafting deeper, more meaningful gaming experiences to enrich players’ lives, create thriving online communities and provide diverse in-game experiences and pioneering gameplay that drives meaningful social connections through our games, applications, websites and online services (collectively hereinafter referred to as our “Services”).

We collect your personal data to let you benefit from our Services, and we take the trust you have placed in us seriously!

This Privacy Notice helps you understand the different ways we may use your data, inform you of your rights and how to exercise your rights. Before using our Services, please ensure that you have read and understood the terms of this Privacy Notice. If you do not agree with our policies and practices, please discontinue the use of our Services immediately.

1. What data do we collect and process?

The type of data we collect and process depends on how you interact with us and use our Services. Depending on your use of our Services, the personal information, as defined by applicable data protection laws, we may have collected and disclosed in the prior 12 months include:

• Technical data: When you use our Services, we collect technical data in order to ensure the functionality and security of these offerings. This includes IPs, logs and other device data. To ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device. When signing up, downloading, installing, and/or playing a game as part of the Services we provide, we process information from you and your device.

• Registration data: Certain Services can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we may collect data about the use of such Services. We generate or collect this information when you voluntarily create an account to use our Services.

• Communication data: When you contact us by any means of communication, we may collect the data exchanged between you and us, including your contact details and the metadata of the communication. Communications made using a product or Service should not be considered private. We may monitor and/or record your communications (including, without limitation, chat text) when you are using a product or Service to analyze for toxicity, prevent cheating and fraud, or enforce our End User License Agreement and/or terms of licensing. You can choose to not use these communication features. You acknowledge that you should not have an expectation of privacy concerning the transmission of any user generated content or communications, that we will monitor and record such content and/or communications as described in this Privacy Notice, and that you should avoid disclosing any personally identifiable information when using these communication features.

• Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes. We collect information when you interact with our customer service department. In certain cases, we may ask you to provide a copy of a document or government-issued ID to verify your identity, location, and/or account ownership. When photo identification is provided to us, we ask that you remove or hide any sensitive information and it is normally deleted as soon as the identification verification is complete or within other legally permissible limits.

• Contract and Player data: This means data that is collected in relation to entering into or the performance of a contract, for example information about the contracts and the Services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback. We collect contact information when you create an account or use our Services to contact us. Data is also collected from in-game interactions such as player status information (e.g. online status, in-game location etc.). We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but may also collect from third-party sources and/or public sources as permissible.

• Preference data: Depending on our relationship with you, we may try to get to know you better and to tailor our products, services and offers to you. For this purpose, we may collect and process data about your preferences. Based on this data, we may, for example, determine if you are interested in certain services. The data processed for this purpose is already known to us (for example where and when you use our Services), or we may collect it by recording your behavior (for example how you navigate our websites). We collect browsing information automatically when you access our websites.

• Social Media Information: We collect this information automatically when you share information through social media widgets on our Services. We also collect it when you voluntarily provide it to us.

Much of the data is provided to us by you (through forms, when you communicate with us, or when you use our Services). You are not obliged or required to disclose data to us, unless you choose to continue using our Services.

As far as it is lawful, we may also collect data from public sources (for example the media, or the internet including social media) or receive data from service providers and other third parties in connection with your use of our Services or your interactions with us on other platforms.

2. For what purposes do we process your data?

We generally process your data for purposes related to communicating with you, including responding to inquiries or to help you exercise your rights. For this purpose, we may use communication data, master data, and registration data in relation to offers and Services that you use. We keep this data for purposes such as documenting our communication with you, training purposes, quality assurance, providing our Services and any associated support for them including follow-up inquiries.

We process data for the administration and performance of contractual relationships including providing you with Services like Palia game functionalities. We may also use data to manage alpha, beta, or other forms of playtests and collect feedback.

We process data for marketing purposes and relationship management, for example to send you personalized advertising for products and services from us, some of which may be offered in partnership with third parties. This may happen in the form of newsletters and other regular contacts, through other channels for which we have contact information from you, but also as part of marketing campaigns and may also include free services.

We further process your data for data analytics, market research, to improve our services and operations, and for product development to improve the Services we provide.

We may also process your data for security and access control purposes.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations.

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development. We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and training.

3. On what basis do we process your data?

The legal bases on which we process your personal data depend on the Services you use and how you interact with them. We may ask for your consent for certain processing activities. You may withdraw your consent at any time with effect for the future by contacting us through the relevant Service . Once we have received notification of withdrawal of consent, we will promptly cease processing your information for the purpose(s) you consented to, unless we have another legal basis to continue doing so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not seek consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you or on our legitimate interest in the particular processing. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law. This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing Palia, our other Services, and Singularity 6, including its operations, safely and efficiently.

We may process your data on other legal bases, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. We will communicate to you separately as necessary where such other legal bases may apply.

4. What applies in case of personalization?

We may automatically evaluate personal aspects relating to you, where we wish to determine preference data, but also to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e., we may combine behavioral and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person and your experiences with our game.

In this case, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles. Where these can produce legal effects concerning you or similarly significantly affect you, we ensure human review.

5. How do we share your data?

In relation to our contracts, websites, products and all other Services, our legal obligations or otherwise with protecting our legitimate interests and the other purposes, we may disclose your personal data to different parties, including:

• Service providers: We may work with service providers in the US, Europe and other regions who process your data on our behalf. This includes for example hosting services. We disclose personal information to these service providers for a business purpose as legally permissible.

• Parties you Authorize, Access, or Authenticate: Third parties you access through the services, social media services you use or other users with whom you communicate. For example, we work with businesses such as Stripe, in which case we do not share personal data, but allow the players or visitors to share their personal data directly with these parties. We then receive transactional information from the business e.g., if the payment or age verification was successful.

• Contractual partners: This refers to contractual partners we may enter into partnerships or other contractual relationships with. For example, they may receive pseudonymized or anonymized registration data in relation to issued and redeemed vouchers or invitations. These recipients may also include contractual partners with whom we cooperate or who carry out advertising for us and to whom we may therefore disclose anonymized or pseudonymized data about you for analysis and marketing purposes.

• Authorities: We may disclose personal data to agencies, courts and other authorities in the US and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.

• Disclosure in Merger, Sale or Other Asset Transfer: In the event of a reorganization, dissolution, merger, sale or bankruptcy, we may transfer any information we collect to relevant third parties and will obtain your consent to do so where required.

• Other persons: This means other cases where interactions with third parties follows from the purposes, for example service recipients, the media and associations in which we participate or if you are included in one of our publications.

In addition, we enable certain third parties to collect personal data from you on our website and in our Services. Where we have no control over these data collections, these third parties are sole controllers.

6. Is your personal data disclosed abroad?

When you use our Services or access our websites, we may collect personal data about you which may be transferred, processed and/or accessed by us in the United States or any other country in which we or our service providers operate. Please be aware that the privacy laws and standards in certain countries, including the rights of government authorities to access your personal information, may differ from those in the country in which you reside. We will only transfer personal information to those countries to which we are permitted by law to transfer personal data.

For data transfers, Singularity 6 has taken the necessary steps to comply with applicable data protection laws to ensure that international transfers of data are carried out with an adequate level of protection by implementing an agreement incorporating the European Commission's standard contractual clauses.

7. How long do we retain your data?

We generally store and retain your data for as long as our processing purposes, legal retention periods and our legitimate interests in documentation and keeping evidence may require, or where storage is a technical requirement. When determining applicable retention periods, we consider multiple criteria including the minimum requirements under applicable law, applicable industry standards and whether the data is required to prevent fraud, cheating or other forms of misuse of our Services. If there are no contrary legal or contractual obligations requiring otherwise and there are no further purposes for processing the data, we will delete or anonymize your data once the retention period has expired as part of our usual processes.

8. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

You may have the following rights depending on the data protection law(s) applicable to you:

• The right to request information from us as to whether and what data we process from you;
• The right to have us correct your personal data if it is inaccurate;
• The right to request deletion of your personal data;
• The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
• The right to withdraw consent, where our processing is based on your consent;
• The right to receive, upon request, further information that is helpful for the exercise of these rights;
• The right to express your point of view in case of automated individual decisions and to request that the decision be reviewed by a human.

If you wish to exercise the above-mentioned rights or have any questions relating to those rights, please contact us. For us to be able to prevent misuse, we need to verify your identity.

If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country, but we would appreciate the opportunity to address any concerns you may have and kindly request that you direct your complaint to us first.

9. For US customers and residents

Selling and Sharing.

• Singularity 6 does not sell your personal information, nor have we done so in the last twelve months. By sell, we mean exchanging your data with another party for financial compensation.
• We do share your information. By share, we mean making personal information available to another party for cross-site or interest-based advertising. We share information with analytics service providers, such as Google. Those parties may combine your browsing information, including information from your use of our Websites, to generate interest-based advertisements.

By clicking the link Privacy Settings on this website you are given the option to choose how we can use your personal information. If you decide not to allow any other than the necessary cookies, your personal information will not be shared or sold.

Singularity 6 provides you with the ability to access, edit, or remove certain information, as well as choices about how we contact you. Although some of these rights apply generally, certain rights apply only to limited individuals or circumstances.

• Right to Know and Access Information.
  • For example, you have the right to know about our information practices. You also have the right to know the categories of information we collect, with whom we share that information, and in some cases, what specific personal information we associate with you or your account.
• Right to Data Portability.
  • We will provide you with a copy of certain information we hold about you in an easily accessible format if you request it.
• Right to Deletion or Erasure.
  • You may request that we delete the personal information we have collected about you.
• Right to Correct Information.
  • You may request that we correct or amend any inaccurate information we have about you or your account.
• Right to Object to & Restrict Processing.
  • You may object to the processing of your personal information on the basis of our legitimate interests at any point in time. You may object to (and opt-out of) direct marketing. You may restrict or limit the way we use your information when:
  • You contest the accuracy of the personal information.
  • You believe our processing to be unlawful, but don’t want us to delete it.
  • We no longer need the personal information for the purposes we collected it, but must retain it for legal purposes (for example, defending legal claims).
  • You have objected to our processing of your personal information and we are verifying whether that objection controls our legitimate use of the personal information.
• Right to Universal Opt-Out.
  • You can limit certain ways in which we use and disclose your personal information (also called "opting out" or "requesting an opt-out"). You can opt out of having your personal information shared for targeted advertising purposes and opt out of having your sensitive personal information shared. This can be done it through the <>.
• Right to Withdraw Consent.
  • You may withdraw your consent to our consent based data processing at any time.
• Right to Non-Discrimination.
  • You have the right not to be discriminated against by us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our services or limiting the quality of our services. However, restricting or deleting your personal information may limit the purposes or uses that rely on that information. If you need further assistance, you may contact us through any of the channels listed in this notice.

Other California Rights

California’s Shine the Light Law

If you are a California resident, you may request and receive information about our disclosures of your personal information to third parties for their direct marketing purposes in the preceding year. If applicable, this information would include a list of the categories of personal information shared and the names and addresses of the third parties with whom we shared your information in the immediately preceding year.

California’s Online Eraser Law

If you are a California resident under the age of 18 and a registered user of our websites, you may request and obtain removal of content or information that you have posted. A request to remove content or information that you have posted does not ensure or require the complete or comprehensive removal of such content or information from our databases (for example, content that has been reposted by another user may not be removable).

To exercise any of your privacy rights, please email us at privacy@singularity6.com or complete our privacy request web form.

10. Persons under the age of 13

The age at which minors can create an account with Singularity 6 or have access to some of our Services depends on the laws of the person’s respective country. Our Services are intended to be suitable for a general audience and are not specifically directed at persons under the age of 13. Singularity 6 does not intentionally collect personal information from minors without seeking any required parental approval in compliance with applicable legal and regulatory requirements. By accessing, downloading and/or using our Services, you represent that you are (i) at least 13, and where applicable (ii) your parent or legal guardian has consented to your use of the Services. Singularity 6 Corporation has considered children’s privacy when creating our products and Services. Our signup process specifically asks for the age of each user to ensure that we can comply with child safety regulations in our markets. IF YOU ARE THIRTEEN (13) YEARS OF AGE OR OLDER BUT NOT OF LEGAL AGE TO ENTER INTO A CONTRACT, YOU SHOULD REVIEW THIS PRIVACY NOTICE WITH YOUR PARENT OR GUARDIAN TO MAKE SURE THAT YOU AND YOUR PARENT OR GUARDIAN UNDERSTAND THESE TERMS AND CONDITIONS. IF YOU ARE A PARENT OR LEGAL GUARDIAN WHO HAS CONSENTED TO YOUR CHILD’S USE OF THE SERVICES, YOU AGREE AND ACKNOWLEDGE THAT YOU ARE SUCH CHILD’S PARENT OR LEGAL GUARDIAN AND THAT YOU AGREE TO BE BOUND BY THE WITHIN TERMS ON BEHALF OF SUCH CHILD, INCLUDING WITHOUT LIMITATION, BEING LIABLE FOR ALL USE OF THE SERVICES BY THE CHILD.

To ensure the safety and wellbeing of minors, we have taken additional measures by using a parental verification and consent solution for minors before any minor can continue to access the applicable Services. We use this solution to notify parents that their minor has requested access to our Services, inform them of our privacy practices, offer them the opportunity to approve our collection and use of the minor’s information as described in this Privacy Notice, and describe the controls available to them.

For further information on how we ensure the safe usage of our game for minors, please see our section “Parental Consent and Minors”.

Parental Consent and Minors

We use Kids Web Services (“KWS”) for age gating, parental and guardian verification and consent management purposes. KWS is a service focused on children’s safety that is offered through Kids Web Services Ltd (a wholly-owned Epic Games subsidiary).

When you verify that you are an adult with KWS through our Services or any other games supported by KWS, KWS will remember that you have been verified the next time you use your email address to manage your child’s permission for other games or services powered by KWS so that you won’t need to do so again. This means we and KWS are jointly responsible for how your personal information is used for parent verification services.

We use KWS’s Parent Consent Management service to obtain your permission to process your child’s personal information as part of our Services and determine how your child interacts with our Services (including accessing communications and social features like chat and friends list). Payment in the in-game store accessible in our Services can only be made by credit card. You can choose to change the permission settings relating to your child’s use of the Services at any time “What is KWS” Parent Page . Please reach out to us at privacy@singularity6.com or through our website if you have any other questions on how we handle your child’s personal information.

Learn more about KWS as well as your rights here: https://www.kidswebservices.com/privacy-policy

11. Can we update this Privacy Notice ?

We will change this Privacy Notice from time to time to reflect changes in any relevant laws or our privacy practices. In some cases, we may also notify you of the relevant changes by email or within the Services. The version published on this website is the current version. We encourage you to review this policy regularly to ensure you understand your relationship with us and the ways we may collect and process information in connection with the Services.

Last updated: January 22, 2024

12. Who is the controller for processing your data?

Singularity 6 Corporation, 11835 W Olympic Blvd Suite, 350E Los Angeles, CA 90064, is the controller for Singularity 6’s processing under this Privacy Notice, unless we tell you otherwise , for example in additional Privacy Notices, on a form or in a contract.

You may contact us for privacy concerns and to exercise your rights as follows:

• Singularity 6 Corporation

  11835 W Olympic Blvd

  Suite 350E

  Los Angeles, CA 90064

  Attention: Legal Department

Please contact us via the Privacy Form or at privacy@singularity6.com

We have appointed the following additional positions:

• Data Protection Officer according to articles 37 et seq. GDPR:

  Singularity 6 Corporation

  Data Protection Officer

  Attention: Legal Department

• Data Protection Representative in the EU according to article 27 GDPR:

  SIDD Datenschutz Deutschland UG (haftungsbeschränkt)

  Schellingstr. 109a

  80798 Munich

  Germany

• Data Protection Representative in Switzerland pursuant to article 14 DPA:

  Priverion GmbH

  Europaallee 41

  8004 Zurich

  Switzerland

• Data Protection Representative in the United Kingdom (UK) pursuant to article 27 UK GDPR:

  Priverion UK Ltd.

  3rd Floor, 120 Baker Street

  London, England, W1U6TU

You can also contact these parties for privacy concerns.