APEIROGON GAMES PRIVACY POLICY Last Updated: October 6, 2022. Apeirogon Games, is headquartered in Vancouver, British Columbia, Canada. We are currently utilizing the Epic Online Services in all of our games, and as such our Privacy Policy mirrors that of Epic Games, Inc. If our (Apeirogon Games) own privacy policies differ from theirs (Epic Games, Inc.) in any way, we will specifically state where and how. This privacy policy describes the different ways Apeirogon Games and Epic Games, Inc. may collect, use, and share information on, through, or in connection with the Epic Services (see “What are the Epic Services?” below). If you have any questions, you can always reach out to us as described in “Contact Us” below or Epic Games, Inc. as described in “Contact Them” below. When we refer to “Epic” (or any similar terms like “they” or “them”) in this privacy policy, we mean the Epic Games entity that controls and is responsible for your information, including Epic Games, Inc. and its subsidiaries that help provide and support the Epic Services. You can also find details about the data controller for personal information they collect through different Epic Services in “Contact Them” below. 1. WHAT ARE THE EPIC SERVICES? They use the term “Epic Services” to describe any Epic products or services that directly link to this privacy policy. These include, for example: •games like Fortnite, Rocket League (through our subsidiary Psyonix), and Fall Guys (through their subsidiary Mediatonic); •websites and applications such as www.epicgames.com and the Epic Games Store, www.rocketleague.com (through Psyonix), and www.fallguys.com (through Mediatonic); and •developer tools, including the Developer Portal and Unreal Engine. Note that your use of the Epic Services may also be subject to additional terms and conditions. For example, you must review and accept the Fortnite End User License Agreement (link) to play Fortnite, the Psyonix Terms of Use (link) to play Rocket League, and the Fall Guys: Ultimate Knockout – End User License Agreement (link) to play Fall Guys. Please read this entire privacy policy. You should also carefully review any other agreements that apply to the Epic Services you use, and confirm you understand and agree to them, before using those products or services. 2. WHAT INFORMATION DO THEY COLLECT? The types of information they collect depend on how you interact with them. Generally speaking, they collect information in three main ways: A) when you provide it to them, B) automatically when you use the Epic Services, and C) from service providers and third parties. A. Information You Provide You can provide them with different kinds of information depending on how you interact with the Epic Services. Sometimes they’ll ask you to provide specific pieces of information, such as when they require it to provide parts of the Epic Services to you (for example, by prompting you to complete an online registration process). If they ask you to provide them with information in these cases and you choose not to, you may not be able to access the relevant Epic Services and/or some features may not operate as intended. For instance, in order to make purchases on the Epic Games Store and to play some of their games, you’ll need an Epic account. To create one, you’ll need to provide them with basic registration information like your name, a public-facing display name, password, the country you live in, and email address. If you want to make a purchase, they may ask you to provide payment-related information (like your credit card number and expiration date) to complete the transaction. They also collect the information you voluntarily provide to sign up for email alerts, use social features like forums or chat, register for early access to their games, use their developer tools (including to create and publish games and other content), complete surveys, or contact them through Player Support requests or customer service. If you enter a contest or competitive event, or participate in their Support-A-Creator program, they’ll collect your application information and other information they may need to help confirm your eligibility and process payouts. They collect whatever information you choose to provide to them in those or other similar cases. B. Information They Collect Automatically They collect some information automatically when you visit, access, or use the Epic Services. This includes information about your gameplay or application usage, purchases, entitlements, and other activity in the Epic Services, typically associated with your account (if you are logged into your Epic account or use a third-party account to access the Epic Services) or with an identifier they have assigned to your device or profile. While the specific types of information that they automatically collect may vary, they generally include: •Usage information and statistics about how you interact with the Epic Services, including the application you used or the game you played, how long you used or played it and when, gameplay attempts, progression and results, saved preferences, crash reports, the URLs of their websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, and platform type; •Technical information about your computer, device, hardware, or software you use to access their services, such as IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and •The general location of your device, which they typically derive from your device’s IP address. The Epic Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools that may be stored on your device. They help them, their service providers, and third parties recognize your device and provide information about how you use and interact with the Epic Services. For example, they support their ability to authenticate users, remember preferences, manage advertising, personalize experiences, and conduct data analytics. Please note that if certain features on the Epic Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Epic Services or others’ websites over time. These features are subject to those third parties’ privacy notices and policies. C. Information They Collect from Other Sources In some cases, they may also receive information about you from service providers and third parties in connection with your use of the Epic Services or your interactions with them on other platforms. For example, some other developers allow you to use your Epic account to log in to their service. And if you choose to link your Epic account with your account on a third-party social media (like Facebook), gaming (like Steam), or other similar website or service, or if you interact with an ad for one of the Epic Services on an external website or service, the company that operates that website or service may share some information with Epic in accordance with their own privacy practices. Your privacy settings on the other company’s website or service typically control the specific types of information they can share with Epic, so please be sure to review and update them regularly. Common examples for linked accounts might include your third-party account display name and user ID, as well as associated device information, name, and email address. For participants in their Support-a-Creator program, they may also collect the number of social media account followers you have for program eligibility purposes. You can also buy, download, or access some Epic Services on or through services operated by third parties. If you do, they may provide them with information to facilitate your access to and use of the Epic Services. This typically includes information like your display name, user ID, and device and region information. For example, you can choose to download and play games like Fortnite on gaming consoles (like PlayStation®, Microsoft Xbox, and Nintendo Switch) through your gaming console account. When you do, the company operating that platform or service may share some information with them, which helps them do things like facilitate your gameplay and track your progression and entitlements. D. Fraud Prevention & Anti-Cheat Providing users with a fair, balanced, and competitive experience on the Epic Services is extremely important to them. They strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity on the Epic Services. They use a variety of anti-cheat and fraud prevention technologies to help them identify and prevent malicious activity. These services may collect and analyze data about your computer and the software on your computer to detect cheating and may be provided by Epic or by service providers such as BattlEye. 3. HOW DO THEY USE INFORMATION? As a general matter, they use the information they collect (either individually or in combination with other information collected as described in this policy) to help them provide, improve, customize, analyze, and promote the Epic Services. This includes using it for purposes such as: •Creating, verifying, and managing user accounts and features; •Providing the Epic Services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates); •Developing, delivering, and improving the Epic Services and other offerings, some of which may be offered in partnership with other parties; •Personalizing your experience, including by presenting content or features better tailored to you or your interests, or their inferences about your interests (for instance, if you frequently play games in a certain genre, they may infer that you’d be interested in that genre and suggest similar games to you); •Promoting the Epic Services, including managing, customizing, and measuring the effectiveness of their advertisements, promotional offers, surveys, and events; •Managing alpha, beta, or early access tests (and collecting feedback); •Conducting data analytics (like analyzing how the Epic Services are used so they can better understand, improve, and personalize them); •Complying with their legal or contractual obligations and enforcing their terms; and •Securing the Epic Services, such as by detecting fraud and otherwise protecting Epic and other users from illegal or harmful actions. They may also process information that does not identify you individually, including aggregate or de-identified information that they create or collect from other sources. This information helps them better understand larger groups of users. If they combine this information with information that identifies you, they will treat it as described in this privacy policy. But please note that this privacy policy does not restrict their ability to process information that does not individually identify you, and they may use and disclose aggregated or de-identified information for any reason permitted by law. 4. HOW DO THEY SHARE INFORMATION? They may share some of the information they collect to help operate and improve the Epic Services. Depending on how you interact with them, common examples might include sharing: •With console and platform partners (for example, to facilitate gameplay when you access the Epic Services through a third-party console provider); •With other game developers (such as to enable features for games you acquire through the Epic Games Store); •With other users (like if you use social features such as chat); •Publicly (for example, your display name, content you create or share, basic game statistics, and other similar information may be generally accessible to others); •With service providers that operate on their behalf to help support the Epic Services in accordance with their instructions (for example, cloud storage providers, payment processors, or marketing and advertising partners); •When they believe they must in order to comply with the law or to protect you, Epic, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of their terms or policies, or if necessary to protect others from death or serious harm to body or property); •With other Epic entities (including to help provide support for the Epic Services internationally); •In connection with certain types of corporate transactions (like in the event of a restructuring or the sale of all or a significant part of their business); and •With your permission (for example, if you link external accounts with your Epic account, or use your Epic account to sign in to third-party games and services or participate in cross-promotional events). •They may also share information that does not identify you with third parties, including aggregate or de-identified information. Third parties you interact with through Epic Services may have different privacy practices than Epic, so they encourage you to review their privacy policies before sharing your information with them. 5. CHILDREN’S PRIVACY The Epic Services are intended to be appropriate for general audiences and are not directed to children (usually considered to be under 13, depending on where you reside). Epic does not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”). They may ask you to provide age-related information in order to help them comply with laws like COPPA. For example, they may request your date of birth to determine whether COPPA requires them to obtain verifiable parental consent from your parent or guardian before allowing you to access the Epic Services. If a user indicates they are a COPPA minor, they’ll require that user to complete a parental approval process before continuing to access the relevant Epic Services. This process is designed to notify parents that their child has requested access to the Epic Services, inform them about Epic’s privacy practices, offer them the opportunity to approve Epic’s collection and use of their child’s information as described in this policy, and describe the controls that they make available to them. Once a parent provides their consent, they’ll give them an opportunity to review and change important account settings that control how their child can interact with the Epic Services. To learn more, see https://www.epicgames.com/site/en-US/parental-controls. Parents are also generally free to change or revoke the choices they’ve previously made, and can review the personal information associated with their child’s account or request that they delete it from their systems. To submit these requests or ask them any other questions you may have about how they handle your child’s personal information, please see “Contact Them” below. Authorized child accounts are otherwise treated much like other Epic accounts unless the settings are adjusted through the parental controls available at https://www.epicgames.com/site/en-US/parental-controls. They can generally play approved games (such as Fortnite, Rocket League, or Fall Guys), access communications and social features (like chat and friends lists), and freely interact with most of the Epic Services (including downloading other games from the Epic Games Store). For additional details, please see “What Information Do They Collect?”, “How Do They Use Information?”, and “How Do They Share Information?” above. SuperAwesome & Kids Web Services The Epic Services use Kids Web Services (“KWS”) for parental and guardian verification purposes. KWS is a service focused on children’s safety that is offered by their subsidiary SuperAwesome. When you verify with KWS, SuperAwesome 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 SuperAwesome so that you won’t need to do so again. This means Epic and SuperAwesome are jointly responsible for how your personal information is used for parent verification services. You can learn more about SuperAwesome and KWS in SuperAwesome’s privacy policy here: https://www.superawesome.com/kws-privacy-notice/. 6. YOUR CHOICES AND CONTROLS They seek to provide you with meaningful choices about the personal information they collect. The specific choices available to you often vary depending on the exact nature of their relationship with you, such as the Epic Services you use. Common examples include: •You can request that they provide access to, or that they correct or delete, personal information they’ve collected from you. Please submit requests to access, update, or delete personal information associated with your Epic account by reaching out to them as described in “Contact Them” below. Note that they may ask you for additional information to help them verify who you are before completing your request. •You can change your email marketing preferences at any time, such as by using the opt-out mechanism provided in their marketing emails, updating your Epic account settings, or contacting them with your request (see “Contact Them” below). •You can change your privacy settings on other parties’ websites (such as social networks) or platforms (like console providers) to limit the information they may share with them. •You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause the Epic Services not to work as intended and some features may not be available. •If you’re under the age of 18 and have an Epic account, you can ask that they remove or anonymize certain content you’ve provided on the Epic Services. Please direct requests to help delete or edit content on the Epic Services to Epic as described in “Contact Them” below. •Parents and guardians can adjust the settings for their child’s Epic account by visiting https://www.epicgames.com/fortnite/en-US/parental-controls. Some parts of the world provide individuals with specific choices related to their personal information by right under local law. 7. THEIR GLOBAL OPERATIONS Epic Games, Inc. is based in the United States, but they operate globally to help provide users all around the world with a better experience on the Epic Services. They have subsidiaries, offices, service providers, and partners worldwide to support these operations in a number of different ways -- for example, the developer of Fall Guys is a subsidiary called Mediatonic Limited that is based in the United Kingdom. This means that Epic may process the information they collect in connection with your use of the Epic Services in places outside the region where you reside. A. Data Transfers When you use the Epic Services, your information may be transferred to or stored in the United States or other countries where they or their service providers operate. The data protection laws and rules in these countries may be different than those where you live. They rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you’re authorizing Epic to process your information in any of the locations where they operate (including the United States) by using the Epic Services. To learn more about the Epic entity responsible for operating the Epic Services you use, see “Contact Them” below. B. California Residents The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information they collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights. You or your authorized agent may make these requests by contacting them as described in “Contact Them” below. Note that they may ask you for additional information to help them verify who you are before completing your request. If they receive your request from an authorized agent, they may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. They will not discriminate against you if you exercise your rights under the CCPA. In the past 12 months, they have collected the following categories of personal information, as described in the CCPA: •Identifiers (such as email addresses); •Demographic information (like ages); •Commercial information (including entitlements or purchase history); •Internet or electronic network activity (for example, gameplay or website usage details); •Audio, electronic, visual, or similar information (like voice chat); •Geolocation information (such as may be derived from your IP address or included in your billing information); •Other “personal information” as defined under California law (like your credit or debit card information); and •Inferences drawn from any of these categories (for example, about the genres of games you may prefer to play based on your purchase history). For details about the precise data points they collect and the categories of sources where they got that information, please see “What Information Do They Collect?” above. They collect personal information for the business and commercial purposes described in “How Do They Use Information?” above. Epic does not sell the personal information they collect. They do, however, disclose personal information as described in this policy (see “How Do They Share Information?” above). In the past 12 months, they have disclosed personal information to the following categories of recipients: •Business partners (for example, if you request that they share your email address with the developer of a game you purchase on the Epic Games Store); •Other Epic entities (like to subsidiaries that may help support certain Epic Services); •Other users (for example, if you use chat or social features on the Epic Services); •Service providers (as described in “How Do They Share Information?” above); •Operating systems and platforms; and •Government entities or other third parties in response to a legal request. C. Residents Of The European Economic Area, The United Kingdom, And Switzerland If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed. Data Subject Rights You may have the right to access, correct, or delete personal data they have collected about you through the Epic Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to their data processing, you have the right to withdraw consent. You also have the right to make a complaint against them by contacting your local supervisory authority for data protection (if one exists in your country). They would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to them first. Please see the “Contact Them” section below to learn more about reaching out to Epic with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows: •EEA: https://edpb.europa.eu/about-edpb/board/members_en •UK: https://ico.org.uk/global/contact-us/ •Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html Basis for Processing The legal bases they rely on to process your personal data depend on the Epic Services you use and how you interact with them. They primarily include: •Contractual Necessity: they process personal data to perform the Epic Services you requested under their Terms of Service or other similar contractual agreements with you. For example, they process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the Epic Services; detect and prevent fraud, cheating, or other similar misuse; facilitate features like cross-progression that allow you to play a game on one platform and continue your progress on another, which may require them to share your information with third-party partners; and contact you about your account, transactions, or other updates. They also rely on performance of a contract to manage their relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to their applicable terms or policies. •Legitimate Interests: they process personal data as needed for Epic’s business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand their users and their preferences; personalize your experience, save your preferences, authenticate their users, and provide similar user experience features; develop, deliver, and improve the Epic Services and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; secure and protect the Epic Services; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis. •Legal Obligations: they process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes. •Consent: they process personal data when you provide them with your consent to do so. You aren’t required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time. Retention Because the specific personal data they process and their reasons for doing so often vary depending on how you use the Epic Services, how long they retain it can also vary. They generally store personal data for as long as they reasonably need it for the purposes described in this policy (like complying with their legal obligations, managing internal records, enforcing their terms, and resolving disputes), unless a long retention period is required or permitted by law. The main criteria they consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the data is required to prevent fraud or similar abuse of the Epic Services (including to enforce prohibitions against cheating and other unauthorized behavior). For example, if you create an Epic account, they will generally store the personal data associated with your Epic account for as long as needed to maintain your account, provide the Epic Services you requested, enforce any terms that apply and govern your use of the Epic Services, and maintain appropriate records to reflect how they deliver the Epic Services to you. To learn more about requesting that Epic delete your personal data, please see “Your Choices and Controls” and “Data Subject Rights” above. 8. SECURITY They maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature they offer, and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected. 9. UPDATES They’ll update this policy from time to time to reflect changes in their practices or relevant laws. When they do, they’ll change the date noted at the top of the policy. In some cases they may also notify you of the relevant changes by email or within the Epic Services. Please review this policy regularly to make sure that you understand your relationship with Epic and the ways they may collect, use, and share information in connection with the Epic Services. 10. CONTACT THEM If you have questions or concerns about the Epic Services (such as game-related issues, trouble accessing your Epic account, bugs or other technical problems, payment matters, or content and entitlement issues), please contact their Player Support teams. You can learn more about submitting support requests for products and services from: •Epic Games (like Fortnite) here; •Psyonix (such as Rocket League) here; and •Mediatonic (including Fall Guys) here. If you want to learn more about their privacy practices or this policy, please email your questions about products and services from: •Epic Games to privacy@support.epicgames.com; •Psyonix to privacy@psyonix.com; and •Mediatonic to privacy@mediatonicgames.com. You can also contact them via postal mail (marked “Attn: Legal Department”) to Epic Games, Inc., located at 620 Crossroads Blvd., Cary, NC 27518, USA. 11. CONTACT US If you have questions or concerns about Aperigon Games, such as game-related issues, or general inquiries), you may email us at info@apeigon-games.com