PRIVACY NOTICE

Last updated February 25, 2023

This privacy notice for the 2adventure Studios Ltd, a private limited company registered

under Companies Act 2006 in England ('Company', '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://2adventure-studios.com, or any website of ours that

links to this privacy notice

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

We are regulated by the Information Commissioner's Oﬃce with the registration

reference ZB510490.

Questions or concerns? Reading this privacy notice 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

suppor[email protected] or priv[email protected].

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

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

■email addresses

■mailing addresses

■billing addresses

■usernames

■passwords

■contact preferences

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make

purchases, such as your payment instrument number, and the security code associated

with your payment instrument. All payment data is stored by Stripe, PayPal, Braintree,

BlueSnap, GoCardless and Chargebee. You may ﬁnd their privacy notice link(s) here:

https://stripe.com/gb/privacy, https://www.paypal.com/webapps/mpp/ua/privacy-full,

https://home.bluesnap.com/privacy-policy/, https://gocardless.com/privacy/payers/,

and https://www.chargebee.com/privacy/.

Social Media Login Data. We may provide you with the option to register with us using

your existing social media account details, like your Facebook, Twitter, or other social

media account. If you choose to register in this way, we will collect the information

described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.

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 fulﬁl and manage your orders. We may process your information to fulﬁl 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 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 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 fulﬁl our

contractual obligations, to protect your rights, or to fulﬁl our legitimate business interests.

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. Click here to learn more.

■Performance of a Contract. We may process your personal information when we

believe it is necessary to fulﬁl 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

■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.

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 organisation 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:

■Cloud Computing Services

■Data Analytics Services

■Data Storage Service Providers

■Payment Processors

■Sales & Marketing Tools

■User Account Registration & Authentication Services

■Website Hosting Service Providers

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 honour this privacy notice. 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

access or store information. Speciﬁc information about how we use such technologies

and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account,

we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media

account details (like your Facebook or Twitter logins). Where you choose to do this, we

will receive certain proﬁle information about you from your social media provider. The

proﬁle information we receive may vary depending on the social media provider

concerned, but will often include your name, email address, friends list, and proﬁle

picture, as well as other information you choose to make public on such a social media

platform.

We will use the information we receive only for the purposes that are described in this

privacy notice or that are otherwise made clear to you on the relevant Services. Please

note that we do not control, and are not responsible for, other uses of your personal

information by your third-party social media provider. We recommend that you review

their privacy notice to understand how they collect, use, and share your personal

information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulﬁl the purposes outlined

in this privacy notice 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 notice, 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 six (6)

months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymise 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 organisational

and technical security measures.

We have implemented appropriate and reasonable technical and organisational 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 unauthorised 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 solicit data from or market to children under 18 years of age. 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.

Nevertheless, some of our services restrict minors to use them in their corresponding

ToS (Terms of Service). 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

privacy@2adventure-studios.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United

Kingdom (UK), 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.

In some regions (like the EEA and UK), 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; and (iv) if applicable, to data portability. 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 local data protection

supervisory authority. You can ﬁnd their contact details here:

https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities

are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal

information, 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 or updating your

preferences.

However, please note that this will not affect the lawfulness of the processing before its

withdrawal nor 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:

■Log in to your account settings and update your user account.

■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. To opt out of interest-based advertising by

advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at

privacy@2adventure-studios.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 recognising and

implementing DNT signals has been ﬁnalised. 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 notice.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted speciﬁc rights regarding

access to your personal information.

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 using the contact information provided

below.

If you are under 18 years of age, reside in California, and have a registered account with

Services, you have the right to request removal of unwanted data that you publicly post

on the Services. To request removal of such data, please contact us using the contact

information provided below and include the email address associated with your account

and a statement that you reside in California. We will make sure the data is not publicly

displayed on the Services, but please be aware that the data may not be completely or

comprehensively removed from all our systems (e.g. backups, etc.).

13. 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 notice from time to time. The updated version will be

indicated by an updated 'Revised' date and the updated version will be effective as soon

as it is accessible. If we make material changes to this privacy notice, 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 notice frequently to be informed of

how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data

Protection Oﬃcer (DPO), by email at priv[email protected].

If you have any further questions or comments, you may also contact us by post at the

following corporate address:

2adventure Studios Ltd

61 Bridge Street

Kington HR5 3DJ

United Kingdom

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

Based on the applicable laws of your country, you may have the right to request access

to the personal information we collect from you, change that information, or delete it. To

request to review, update, or delete your personal information, please submit a request

by email to priv[email protected].