Privacy Policy

Effective Date: April 10, 2024

Last Updated: April 10, 2024

This privacy notice for DIGIEDEN TECH SGP PTE.LTD. ("DigiEden";,";Company";, "we";, "us";, "our";), describes how and why we might collect, store, use, and/or share ("process";) your information when you use our services ("Services";).

This privacy and data policy ("Privacy Policy") applies and has effect in respect of all of our apps, related online services (including online network play connectivity and interactivity) and other software and products made available by us, as well as any other online features relating to the Games, our websites (including, without limitation, privacy@digi-eden.com) (the "Websites"). Together, the Games and Websites are referred to herein as the "Online Services".

TABLE OF CONTENTS

1.Information We may Process

2.Why We Collect Information about You

3.Cookies and Similar Technologies

4.Information Sharing

5.Third-Party Services

6.Your Rights and Choices

7.Data Security

8.Data Retention

9.International Data Transfers

10.Children

11.Changes to Our Privacy Policy

12.How to Contact Us

1.Information We may Process

Personal Information. 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
• usernames
• passwords
• language
• age bracket
• physical demographic information (including your gender and your weight bracket)
• voice data (if you use your microphone for voice chat)

Movement Information. When you use a VR Client to access our Platform, we may gather data related to the physical movements of your fingers, hands, head, and other body parts, contingent upon the devices you employ. It’s important to recognize that we only collect Movement Information from the devices or services you actively decide to utilize or activate alongside the Platform.

Eye Movement Information. Should you activate the eye tracking feature, we may gather data concerning your eyes’ location and movement. To be clear, the information we receive pertains solely to the relative positioning and movement of your eyes, as detected by your headset or other hardware. We do not engage in collecting or scanning your retinas or eyes directly to obtain this data.

Analytics Information. Through tracking technologies and analytics, we gather technical details regarding your interaction with our Online Services. The personal data collected in this manner varies based on how you use the Online Services and your settings, and may include the following:

• ip address and mac address
• user/account ID with us
• device country
• time, date and install source of your Game download/usage
• session start, duration and end timings
• workout-related information such as ‘calorie burn’ data (which are estimates only and not collected using a medical device)
• identifying information about crashes and defects
• device information (e.g. device type, device unique ID and browser)
• system, browser and device settings and information (including make, model and operating system of your device, device properties such as orientation, country, language and locale settings)

We does NOT collect or display the player’s real name, physical address or contact information.

2.Why We Collect Information about You

We process your personal information for a variety of reasons, tailored to your interaction with our Services, such as:

• Account Management: Your information is used for account setup, login, and maintenance to ensure smooth operation.
• Service Delivery: We process your data to deliver the services you request efficiently.
• User Support: Your inquiries and any service issues are addressed by processing your information.
• Administrative Updates: Information about our services, terms, policies, and other relevant updates is communicated to you.
• Facilitating User Interaction: We enable communication between users if you opt to use such features.
• Feedback Solicitation: To enhance our Services, we might use your data to seek your feedback.
• Marketing Communications: With your consent, we use your information for marketing purposes. You can unsubscribe from marketing communications at any time.
• Service Security: Your data aids in our efforts to secure our Services, including monitoring for and preventing fraud.
• Trend Analysis: Analyzing how you use our Services helps us understand user trends and improve.
• Emergency Situations: In critical situations, we might process your data to protect vital interests, such as preventing harm.

3.Cookies and Similar Technologies

In this Privacy Notice, "cookie"; encompasses both cookies and similar technologies that we employ for information storage. A cookie is essentially a small text file placed on your computer or mobile device by a website’s server, which only that server can access or read. Each cookie is browser-specific, containing anonymous details like a unique identifier, the website’s name, and some numbers and letters.

Virtually every website or app, including ours, utilizes cookies to enhance your user experience. They allow a website or app to "remember"; you, for the span of your visit with a "session cookie"; or for subsequent visits with a "persistent cookie.";

Cookies streamline your interactions with a website or app. For instance, they facilitate efficient page navigation and remember your preferences, making your interaction quicker and smoother. Without cookies, the website or app would treat you as a new visitor upon every page change. Cookies also support targeted advertising and the analysis of your website browsing behavior.

4.Information Sharing

We may disclose Personal Information to third parties in the following circumstances:

• Vendors and Service Providers: We collaborate with third parties offering essential services, including Platform security, web and app development, hosting, payments, maintenance, marketing, and advertising. When necessary for the provision of their services to us or directly to you, some of these parties may access and process your Personal Information.
• Digital Content Stores: If you download our Game through a third-party store like Steam or Oculus, we may share your personal data with these platforms to facilitate in-game purchases.
• Legal Requirements and Law Enforcement: We may disclose your Personal Information if legally required or in a genuine belief that such action is needed to comply with legal processes, respond to court orders, or cooperate with law enforcement and other government agencies.
• Legal Claims Enforcement: We may disclose your Personal Information to prevent liability, protect against fraudulent, abusive, or unlawful activities, defend against third-party claims, ensure the security and integrity of the Platform, or protect our or others’ rights, property, or safety.
• Business Transfers: In the event of a merger, acquisition, sale of assets, insolvency, bankruptcy, or receivership, your Personal Information may be transferred to a new owner as one of our business assets. We will inform you about such transfers as required by law and seek your consent where necessary.

5.Third-Party Services

Our Services enable registration and login through your third-party social media accounts, such as Facebook or Twitter. When you opt for this feature, we obtain specific profile details from your social media provider. The type of profile information we receive can vary by provider but typically includes your name, email address, friends list, profile picture, and any other information you’ve made public on the platform.

The information obtained will be utilized solely for the purposes outlined in this privacy notice or as explicitly communicated to you within the relevant Services. It’s important to recognize that we do not oversee or bear responsibility for the further handling of your personal information by your third-party social media provider. We advise reviewing their privacy policy to grasp how they manage, utilize, and disclose your personal information, and how to adjust your privacy settings on their platforms.

6.Your Rights and Choices

You possess specific rights regarding your personal data, including:

• Access Right: You can request access to the personal data we hold about you.
• Data Portability: You have the right to receive some of your personal data in a structured, commonly used, and machine-readable format.
• Rectification: You can have any inaccurate or outdated personal data corrected.
• Consent Withdrawal: If our processing relies solely on your consent, you have the right to withdraw this consent at any time.
• Erasure: Under certain conditions, such as when the data is no longer needed, consent is withdrawn, unlawful processing, or a legal requirement, you can request the deletion of your personal data.
• Objection to Processing: If we process your data based on our legitimate interests, you can object. However, we may continue processing if there are compelling reasons that outweigh your rights.
• Automated Decision-Making: You have the right to understand the logic behind any decisions made solely through automated processes.
• Direct Marketing and Profiling: You can opt-out of direct marketing and object to profiling related to direct marketing either through your account settings or by using the opt-out feature in the communication.

For inquiries or concerns about your privacy rights, contact us at privacy@digi-eden.com

7.Data Security

We have implemented appropriate and reasonable technical and organizational 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 unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. We are committed to doing everything in our power to secure your personal information, but we must caution that sending personal information to and from our Services carries inherent risks. We advise accessing our Services only within a secure environment to minimize these risks.

8.Data Retention

We ensure the removal of your Personal Information or its conversion into a non-identifiable format once it’s no longer needed for the purposes it was processed for, except when legal obligations necessitate a longer retention period. The retention duration is determined by considering factors such as the service type rendered to you, the duration and nature of our relationship, and any legal retention requirements and statutes of limitations.

Your Movement Information and Eye Movement Information are exclusively utilized for real-time animation of your avatar, and we do not keep any records of this information.

9.International Data Transfers

Our servers are located in the United States and we are a company incorporated in Singapore with global business and service nature, which means that your data might be transferred to, stored, and processed in US, Singapore, or be accessed by our affiliates which are located outside of your jurisdiction of residence. To the extent permitted by applicable law, by accepting this privacy notice, you agree to the cross-border transfer of your information to any country where our affiliates and/or servers are located.

For those residing in the European Economic Area (EEA) or the United Kingdom (UK) or other regions of the world with laws governing data collection and use that may differ from the law of the countries where our affiliates and/or servers are located, it’s important to note that such countries may not offer the same level of data protection laws as your home country.

Nonetheless, we are committed to safeguarding your personal information in line with this privacy notice and all applicable and relevant laws. For instance, to ensure the personal information of the EEA or UK residents is handled in accordance with the data protection standards as required by applicable law, we utilize the European Commission’s Standard Contractual Clauses for data transfers where such personal information is shared with a party outside the EEA or UK and based in a country which is deemed not to have adequate data protection safeguards in place. We are ready to provide our Standard Contractual Clauses upon request. Similarly, we’ve established appropriate safeguards with our third-party service providers and partners, with more details available upon request.

10.Children

We do not intentionally gather information from or target children under 13 years old through our Online Services. Should we discover that we have inadvertently collected personal data from a child under the age of 13, we will promptly delete such information. If you suspect that we may have data from or about a child under 13, please reach out to us at privacy@digi-eden.com

11.Changes to Our Privacy Policy

We periodically update this privacy notice and will publish any modifications on this page once they’re available. To stay informed about how we safeguard your information, we recommend regularly reviewing this privacy notice.

12.How to Contact Us

If you have any questions, comments or enquiries about the Privacy Policy,please contact us at privacy@digi-eden.com We are committed to addressing your questions and enquiries promptly.