Privacy Policy – No Straight Roads

INTRODUCTION
Sold Out Sales & Marketing Limited (hereinafter “Sold Out”, “we”, “our” or “us”) cares about the protection of your personal data and the respect of your privacy. The purpose of this privacy policy is to provide you with clear and transparent information on how we collect, process, store, share and transfer any information that can directly or indirectly identify you (hereinafter “personal data”).

DATA CONTROLLER
Sold Out Sales & Marketing Limited a company registered in England and Wales with company no 6989121 and registered office at 21 Whitefriars Street, London, EC4Y 8JJ, is the data controller of the processing of your personal data implemented as part of your use of our video games and/or websites and further described in this privacy policy.

KEY INFORMATION
Sold Out collects certain of your personal data via our video games and/or websites in particular to allow you to subscribe to our newsletter and video games related updates, benefit from the games and services you have requested, and receive promotional and commercial offers when you have given your consent.
Sold Out mainly collect identification information and information concerning your use of our video games, (your email address, your name, your username,Steam ID or other platform ID, your password, your IP address, your country and languages). The categories of information we collect in connection with your use of our video games and/or websites, products and services, the purposes and legal basis for which we collect it, are described in the table provided under Section 2 of this Privacy Policy.
You have rights of access to and rectification or erasure of your personal data and to restrict or object to its processing, as well as the right to data portability, which you can exercise at any time by making a written request to us. You also have the right to lodge a complaint about our processing of your personal data with the competent supervisory authority, such as the Information Commissioner’s Office in the United Kingdom (ICO). To the extent, the French data protection legislation is applicable; you have the right to establish instructions in respect of the retention, the deletion and the transmission of your personal data after your death. Where the processing of your personal data relies on your consent, you have the right to withdraw such consent at any time. For more information on your data protection rights, please read Section 4 of the privacy policy.

CHILDREN
Children under the age of 13 years old cannot subscribe directly to Sold Out websites or accounts relating to our video games. We do not intentionally collect personal information from children under the age of 13 years old. If we realise that we have collected personal information of a child under 13, or equivalent minimum age depending on jurisdiction concerned, we will delete any personal information related to such child.

CONTACT
If you have any questions or concerns with regard to the processing of your personal data, the exercise of your rights or this privacy policy, feel free to contact us by sending an email to our customer services at help@soldout.uk.com or by post at the following address: Sold Out Sales & Marketing Limited, 21 Whitefriars Street, London, EC4Y 8JJ. For more information on the way to contact us for any privacy questions or complaints, please read Section 11 of this privacy policy.

1. WHAT PERSONAL DATA WE COLLECT AND PROCESS
Sold Out collect certain of your personal data via our video games and/or websites in order to provide you with the best game experience, the use of our services and for marketing purposes with your consent. We mainly collect identification and usage information about you. Sold Out does not collect or process any transaction data concerning you (e.g. credit card details.
The table set out under Section 2 below describes the categories of personal data Sold Out may collect and process as part of the services, websites, or video games, the corresponding purposes and the related legal ground.

The mandatory or optional nature of the personal data collected directly by Sold Out will be indicated as such on each collection form made available by Sold Out. You should be aware that if you refuse to provide certain personal data whose collection is mandatory, you would not be able to benefit from all or part of the services or features of the video games offered.

2. FOR WHICH PURPOSE(S) AND ON WHICH LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

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3. HOW DO WE GET YOUR PERSONAL DATA?
3.1 Personal data you provide to Sold Out directly
When you use our video games and related services, you share some information with us, which may directly identify you. In particular:

Your age;
Your Steam ID; and/or
Any other identification number / information when registering via existing accounts created on third party platforms / digital stores such as Epic Games, GOG, where applicable.

In some cases, we may collect your first name, last name, email address and nickname when we organize a video game contest, conduct a survey about one or more of our video games or any other marketing campaigns.

3.2 Personal data Sold Out obtains indirectly

We may indirectly collect or receive certain of your personal data, in particular via:

Cookies and other tracking technologies used in our video games and/or websites to analyse your behaviour when using our video games and/or websites and to assess the performance of our video games (see Section 9 of this Privacy Policy);
Our third party distributors and business partners where you have expressly consented to the sharing of your email address for commercial and marketing (e.g. newsletters, promotional offers, etc.);
Your access to, or use of, some of our video games and services available on certain social networks or other platforms or websites owned by third parties.

(Collectively, the Third Parties).

Please note that this Privacy Policy does not apply to the processing of personal data implemented by Third Parties or on Third Parties’ platforms. Sold Out does not supervise or control their respective privacy practices. We recommend that you specifically review the privacy policies available on each of these Third Party Platforms, in particular regarding the sharing of your personal data.

In any event, Sold Out will only process the personal data received indirectly under the terms of this privacy policy.

4. YOUR RIGHTS
4.1 Your data protection rights

Your right of access: you have the right to ask us if we are using or storing your personal data. You can also ask us for copies of such personal data.
Your right to rectification: you have the right to ask us to rectify information you think is inaccurate and to complete information you consider is incomplete.
Your right to erasure: you have the right to request from us erasure of your personal data when:
- We no longer need your personal data;
- You initially consented to the use of your personal data, but have now withdrawn your consent;
- You have objected to the use of your personal data and your interests outweigh those of Sold Out,
- We have collected or used your personal data unlawfully; and/or
- We have a legal obligation to erase your personal data.
Your right to restriction of processing: you have the right to request from us the restriction of the processing of your personal data as follows:
- Temporarily limit when you have challenged the accuracy of your personal data; or you have objected to the use of your personal data; and /or
- Limit if we processed your personal data unlawfully without you wishing to delete it; and we no longer need your personal data but you wish us to keep it in order to defend or exercise legal claims.
Your right to object to processing: you have the right to object to the processing of your personal data if we are using your personal data for (a) a task carried out in the public interest, (b) our legitimate interests, (c) scientific or historical research or statistical purposes; or (d) direct marketing.
Your right to data portability: this right applies to personal data you have provided to us and where the processing is automated and based on your consent or made under a contract. You have the right to ask us, if technically feasible, to transfer your personal data to a third party or directly provide it to you in a way accessible and machine-readable.
You also have the right to withdraw consent at any time where the processing is based on your consent (e.g. cookies, marketing communications), without affecting the lawfulness of processing based on consent before such withdrawal. In particular, you may withdraw your consent for the receiving of commercial communications and marketing offers by clicking on the “Unsubscribe” link included in each marketing communication or by contacting Sold Out through the procedures described under Section 4.2 below.
You have the right to lodge a complaint before a supervisory authority – In United Kingdom, the Information Commissioner’s Office.

Where French data protection law is applicable, you also have the right to set guidelines for the retention and communication of your personal information after your death.

4.2 How to exercise your rights

You can exercise any of the above listed rights by sending an email at any time to our Customer Services at the following address: help@soldout.uk.com; or
By post to the following address: Sold Out Sales & Marketing, 21 Whitefriars Street, London, EC4Y 8JJ, United Kingdom; or
You can also directly exercise any of the above listed rights via the contact form directly available on our website.

5. HOW SOLD OUT PROTECTS YOUR PERSONAL DATA?
Sold Out has implemented and maintains adequate technical, physical and organisational measures to ensure the confidentiality and security of your personal information and to protect your personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. In particular, Sold Out relies on encryption mechanisms where technically feasible, restricted internal access and credentials, internal security and IT policies, back-up procedures, and strong contractual commitments and warranties when relying on third party providers.

6. HOW LONG WILL SOLD OUT KEEP YOUR PERSONAL DATA?
Sold Out will not keep your personal data for longer than necessary (i.e. 5 years from our first contact) and will immediately delete your personal information once the purpose for which they have been collected and processed is achieved.

For more information on the retention of your personal data collected via cookies and tracking technologies, please see Section 9 of this privacy policy.

7. WITH WHOM SOLD OUT SHARES YOUR PERSONAL DATA?
As a global organisation involved at all stages of the video game value chain, we may share your personal data with other trusted companies of the Enad Global 7’s group for administrative, technical and operational purposes in relation to the video games and related services offered by Sold Out. When trusted group companies (i.e. Toadman Interactive Game Development, Artplant LLC) have access to your personal data, Sold Out implements appropriate contractual, technical and organisational measures to ensure that your personal data are only processed to the extent necessary and only for the purposes set out above.
In addition, Sold Out may communicate or share certain of your personal data with our partner development studios, IT services providers and our suppliers acting as processors for technical purposes in order to allow us to offer you high-performance video games and quality services. In particular, the following third parties are involved in the processing of your personal data:

Amazon Web Services (hosting of gamers’ personal data);
Pugstorm AB (partner development studio);
Unity Technologies in relation to Cloud diagnostic solution; and
Hetzner Online GmbH (physical data server based in Germany).

Finally, Sold Out relies on external technologies and platforms to develop or publish its video games and make available its online services. In particular, we closely collaborate with the following business partners:

Valve Corporation in relation to the access to Steam platform;
Unity Technologies ApS in relation to the cross-platform game engine (Unity); and
Microsoft in relation to the use of GitHub NuGet open source tools.

Sold Out implements the necessary contractual and organisational measures to ensure that the processing of your personal data by these third party providers and business partners is strictly limited to the purposes defined in this privacy policy and to guarantee the confidentiality and security of your personal data.

8. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
Sold Out may transfer some of your personal data outside of the United Kingdom and of the European Economic Area (EEA) when necessary for technical and operational purposes, to enable us to offer you high-performance video games and to provide you with products and services you requested. In particular, we will share or give access to your personal data to our trusted affiliate company Artplant LLC located in Russia. These transfers will be made in compliance with applicable data protection regulations and will rely on appropriate safeguards recognised under the General Data Protection Regulation (GDPR).
In particular, when the transfer of your personal data cannot be based on an adequacy decision of the European Commission recognising an adequate level of protection, we put in place other appropriate transfer mechanisms and guarantees to ensure the protection of your personal data such as, for example, data transfer agreements including the standard contractual clauses approved by the European Commission or the Privacy Shield for processing carried out in the United States, as the case may be.

9. COOKIES, ANALYTICS AND TRACKING TECHNOLOGIES
Cookies are small text files that are placed on your computer and devices by us when you use our video games or visit our website. They are widely used in order to make the application and our website work, or work more efficiently, as well as to provide us with more information.
Sold Out uses cookies and other tracking technologies for authentication and security purposes. We would also like to use internal analytical tools or third party analytical metrics to provide you with personalized content and to improve our video games and services based on how you use such video games and services.
You can manage the use of optional cookies by as instructed in the video game or on the website.
In any event, cookies and tracking technologies will not be set for more than 6 months following which we will ask your consent again before setting again such cookies and tracking technologies.

9.1 Cookies/tracking technologies set by us and/or third parties
The table below explains the types of cookies and tracking technologies, we use and why:

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* Any further processing of your personal data by the third parties listed above will be governed by the privacy and cookie policies of the platforms concerned.

9.2 Social networks sharing buttons
Cookies that are set by the following social networks are intended to allow you to facilitate the sharing of content and to improve your experience on our dedicated pages on third parties social networks platforms.

Facebook: see Facebook’s privacy policy and cookies policy ; and
Twitter: see Twitter’s privacy policy and cookies policy.

Any further processing of your personal data by the social networks listed above will be governed by the privacy and cookie policies of the platforms concerned.

10. CHILDREN’S PRIVACY
We do not provide services or video games directly or proactively to children under the age of 13 years old nor do we intentionally collect their personal data. If we realise that we have collected personal data of a child under 13 years old, or equivalent minimum age depending on jurisdiction concerned, we will immediately delete any related personal data.

11. HOW TO CONTACT SOLD OUT

By sending an email to our Customer Services at the following address: help@soldout.uk.com;
By post to the following address: Sold Out Sales & Marketing, 21 Whitefriars Street, London, EC4Y 8JJ, United Kingdom; or
You can also directly contact us through the contact form directly available on our website.

12. HYPERLINKS TO OTHER WEBSITES
You may identify hyperlinks to access the websites of other organisations on our websites or in the content, we provide to you. Please note that this privacy policy does not cover how other third parties may process your personal data. We recommend you to read the privacy policies related to such third party platforms.

13. UPDATES AND CHANGES TO THE PRIVACY POLICY
We keep our privacy policy under regular review to ensure it is up to date and compliant with the applicable data protection regulation.
In case of significant changes or modifications, we will inform you of such changes and provide you with a hyperlink to the updated privacy policy 30 days in advance. This information will be provided to you by email and will be made available through a pop-up window when opening the game or visiting the website again.