PRIVACY POLICY

PURPOSE

Formation Games Studio Limited (“FGS” / “The Company”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we process your personal data on our website and when you subscribe and register to use our services on our CLUB app. This privacy notice also tells you about your privacy rights pursuant to the Data Protection Act 2018 and UK GDPR (“Data Protection Laws”).

When installing our app please ensure you follow the consent process for downloading the app and consider the End User License Agreement.

CONTROLLER FOR PERSONAL DATA

A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise FGS is the controller of your personal data.

This privacy notice applies to the processing of personal data by us in connection with any:

• Users and potential users: For the provision of services by us.

• Suppliers: For the provision of products and services to us by suppliers or service providers.

• Visitors: For the provision of services to us as a visitor on our website.

TYPES OF PERSONAL DATA

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

FGS may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

• Identity Data includes first name, last name, username or similar identifier and title.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Device Data includes the type of mobile device you use, a unique device identifier for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details for the provision of services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

• Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website and app services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any sensitive data about you this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

HOW WE COLLECT YOUR PERSONAL DATA

Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms or signing up to our website (ii) by leaving ratings and comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.

This includes personal data you provide when you:

• Register to become a member of our website.

• Subscribe to our service or publications.

• Request marketing to be sent to you.

• Give us feedback or contact us.

• Participate in our marketing or other promotional events.

• Contact us if you have any concerns.

From use of our website

FGS gathers information and statistics collectively about visitors to the Company's website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you.

From use of our app

When you use our app we will automatically collect personal data including Device, Content and Usage Data.

From website and app use

We use cookies and/or other tracking technologies to distinguish you from other users of the app and our website. This helps us to provide you with a good experience when you use the app or browse our website and also allows us to improve the app and website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies please see our Cookie Notice.

Indirectly: Third-party sources:

We receive Identity Data, Contact Data, Financial Data, about you from third parties when we:

• Provide our services or other parties send us your personal data to enable the provision of those service.

• You provide your personal data to a third party for the purpose of sharing it with us.

• We interact with governmental or regulatory bodies or other authorities in relation to you or on your behalf.

• Publicly available sources:

• Public registers of individuals such as electoral registers.

• Public registers of companies such as Companies House in the United Kingdom.

• Professional networking sites available on the Internet such as LinkedIn.

Providing personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide that information when requested we may not be able to perform the contract we have or are trying to enter into with you for example to provide you with our services. In this case we may have to cancel our service but we will notify you if this is the case at the time.

How we use your personal data

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

• Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you. For example when you sign up to our services.

• Legal obligation: Where we need to comply with a legal obligation. For example for accounting or legal purposes.

• Legitimate interests: Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.

• Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at privacy@formation.games to withdraw consent. Please also see Marketing communications.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING COMMUNICATIONS

FGS may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.

Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.

How we share your personal data

We may have to share your personal data with the parties set out below:

• Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.

• Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.

• Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.

• Advertising networks and analytics service providers: This is to support and display ads on our website, app and other social media tools.

• Third parties: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy notice.

INTERNATIONAL TRANSFERS

How we safeguard personal data when we transfer it internationally

We ensure a similar degree of protection is afforded whenever we transfer personal data out of the UK by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or

2. We will use where applicable specific contracts approved for use in the UK which give personal information the same protection it has in the UK. For example, the use of Article 46 UK/EU GDPR safeguard mechanisms to transfer personal data.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

We may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you

CHILDREN DATA

This website or use of the app is not intended for children and we do not knowingly collect data relating to children. Pursuant to Data Protection Laws this means to individuals under the age of 13.

DATA SUBJECT RIGHTS

Under certain circumstances, you have rights under Data Protection Laws. You can:

Request access to your personal data: This is known as a "data subject access request" and enables you to receive a copy of the personal data we hold about you.

Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. See also Marketing communications.

Request restriction of processing your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information's accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.

Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making which produces legal or similarly significant effect.

KEEPING PERSONAL INFORMATION ACCURATE AND CURRENT

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal data please contact us. See Contact us.

CARRYING OUT YOUR DATA SUBJECT RIGHTS

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated

If you wish to exercise any of the rights set out above, please contact us at privacy@formation.games.

CONCERNS AND COMPLAINTS

We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

CHANGES TO OUR PRIVACY NOTICE

This notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.

CONTACT US

If you would like more information about the way we manage personal information that we hold about you please contact us at:

Email address: privacy@formation.games

Postal address: 63-66 Hatton Garden, Suite 23, Fifth Floor, London, EC1N 8LE.

VERSION

This version was last updated on 20th March 2022.