SORA STREAM PRIVACY POLICY

The Sora Stream Platform is owned and managed by Ludium Lab, SL with registered address at C/Roger de Flor 73,1-2, 08913, Barcelona, Spain. You can contact our Data Protection Officer via email to privacy@sorastream.com.

1. Introduction

At Sora Stream we want to provide you with the best possible experience to ensure that you enjoy our service today, tomorrow and in the future. In order to do so, we need to know your gaming habits, so that we can offer you an exceptional and personalized service.

Having said that, the privacy and security of your personal data is of great importance to us. For this reason, we want to clearly explain how and why we collect, store, share and use your personal data, and show you the controls and options available for you to choose when and how you share your personal data.

That is our goal and we will explain it in more detail in this Privacy Policy ("Policy”).

2. About this Policy

This Policy provides essential information regarding the use that Ludium Lab, S.L (owner of the Sora Stream platform, hereinafter “SoraStream“) makes of your personal data. The Policy applies to all SoraStream services and associated services (hereinafter the "SoraStream Service"). The terms governing the use of the SoraStream Service are defined in our Terms of Use and EULA.

Regularly, we may develop new services or offer additional services. If the introduction of these new or additional services generates any kind of change in the way we collect or process your personal data, we will provide you with more information and additional conditions or policies. Unless otherwise indicated, when these new or additional services are introduced, they will be subject to this Policy.

The main goal of this Policy is:

1. Ensure that you understand what personal data we collect about you, the reasons why we do so, and with whom we share it;
2. Explain the way in which we use the personal data that you share with us in order to control, manage and ensure the functionality of the Sorastream Service when you use it; and
3. Explain your rights and options regarding the personal data we collect and process about you and how we will protect your privacy.

We hope this helps to understand our commitment to your privacy.

If you have any questions or comments related to the processing of your data, you can send an email to privacy@sorastream.com. If you do not agree with the content of this Policy, remember that you decide if you want to use the SoraStream Service.

3. Your rights and preferences: options and control

As you may already know, the new European Union regulation known as the General Data Protection Regulation (“GDPR”) gives people certain rights related to their personal data. The rights granted to people are:

• Right of access: the right to be informed and request access to the personal data we process;
• Right to rectification: the right to request that we correct or update your personal data, when they are inaccurate or incomplete;
• Right to erasure: the right to request that your personal data be deleted;
• Right to restriction of processing: the right to request that the processing of all or some of your personal data be temporarily or permanently stopped;
• Right of opposition:
  • the right, at any time, to object to the processing of your personal data for reasons related to your particular situation;
  • the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit such data for use in the service of a third party;
• Right not to be subject to automated individual decision-making: the right not to be subject to decisions based solely on automated decision-making, including profiling, when the decision may have a legal effect on you or produce a similar significant effect.
• Right to revoke at any time the consent granted through the Privacy Settings panel.

In order to allow you to easily exercise these rights and record your preferences regarding how SoraStream uses your personal data, we will provide you with access to the following settings through the Account Settings page:

• Privacy settings: it allows you to control some of the categories of personal data that we process and it allows you to access your personal data, change your avatar, as well as consent or revoke your consent regarding the commercial communications that you may receive from SoraStream.

You can contact Ludium Lab, S.L (Sora Stream) at C/ Llauder 1, ent - 1A, 08003, Barcelona, Spain or you can contact us through privacy@sorastream.com, Ref: Data Protection, to exercise your rights. You must indicate the rights you want to exercise and prove your identity as an applicant when appropriate. Likewise, we inform you that you have the right to file a claim before the Spanish Data Protection Agency if you consider that there has been some type of violation in relation to the processing of your personal data.

4. How do we collect your personal data?

We collect your personal data as follows:

1. Checking in to SoraStream Service: When you register to create an account in the SoraStream Service, we collect certain personal data so you can use the SoraStream Service, such as an email and, afterwards, an username (alias) and coarse birth date (i.e. month and year). In those plans that require payment for their use, the data regarding the payment method is also collected and, therefore, the payment platform that uses the SoraStream Service ensures its correct protection.
2. Use of the SoraStream Service: when you use the SoraStream Service, we collect personal data about the use of the SoraStream Service, such as what games you have played, when you have done it and how long have you been playing each one, as well as what games have been selected as favorites from the SoraStream Service catalog. Each game has a classification of the minimum age that the user must be to be able to access and play the game. This classification is determined by the official classification, known as Pan European Game Information (“PEGI”), which establishes the appropriate minimum age to play video games according to their category. The PEGI has the purpose of guiding the consumer about the suitability of playing a specific game through the minimum age recommended by the PEGI. Therefore, when collecting data about the games the user plays, we can also collect PEGI data.
3. Collect personal data that allows us to provide you with additional features / functionalities: from time to time, we also offer you the possibility to provide us with additional personal data or to give us your permission to collect it; for instance, to provide you with more features or functionality.

We use anonymous and additional information for purposes that include testing our computer systems, research, data analysis, marketing and promotion modeling, improving the SoraStream Service, and developing new functionality and features within the SoraStream Service. However, since the data is anonymised, it dissociates itself from the person who owns the data, preventing its identification.

5. How and what personal data do we collect from you?

We have established in the tables below the categories of personal data that we collect and use about you:

Personal data collected when you register with the SoraStream Service

Personal data collected through your use of the SoraStream Service

Personal data collected with your consent to enable us to provide you with additional features or functionality

6. For what purpose do we use your personal data?

When you use or interact with the SoraStream Service, we use different technologies to process your personal data for various reasons. The following table shows the purposes of the processing of your personal data, the associated legal bases which allows us to process your personal data, and the categories of personal data (identified in section 5 " How and what personal data do we collect from you?") used for the following purposes:

7. Shared use of your personal data

This Section introduces the different categories of the recipients of the personal data collected or generated through your use of the SoraStream Service.

Publicly available information

The following personal data will always be publicly available on the SoraStream Service: Avatar and username that will be shared with other SoraStream users who use the service.

Information that we can share

8. Data retention and erasure

We retain your personal data only for the time necessary to provide the SoraStream Service and for legitimate and essential business purposes, such as maintaining the performance of the SoraStream Service, making data-driven business decisions about new features and offerings, complying with our legal obligations and resolving disputes. We retain some of your personal data while you are a user of the SoraStream Service.

Upon request, we may delete or anonymize your personal data so that you are not identified, unless, we can or are legally required to retain certain personal data, including the following cases:

• If there is an unresolved issue related to your account, such as pending payments on your account or an unresolved claim or dispute, we will retain the necessary personal data until such issue is resolved;
• When we are obliged to retain personal data to comply with our legal, tax, accounting and auditing obligations, we will keep the necessary personal data for the period required by applicable law; and/or
• When necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

9. Transfer to other countries

SoraStream does not share your personal data with other companies located outside the territories of the EU and SA.

10. Links

We may display third party advertisements and other content linked to third party websites. We cannot control or be responsible for the privacy practices and content of third parties. If you click on a third-party advertisement or link, you understand that you are leaving the SoraStream Service and any personal information you provide will not be covered by this Policy. Please read the privacy policies of the third parties responsible for the website you access to find out how they collect and process your personal data.

11. Protection of your personal data

We are committed to protect the personal data of our users. We implement the appropriate technical and organizational measures to help protect the security of your personal data. However, keep in mind that no system is completely secure. We have implemented various policies including pseudonymization, encryption, access and retention policies to protect against unauthorized access and unnecessary retention of personal data on our systems.

The password protects your user account, so we recommend that you use a unique and firm password, to limit access to your computer and browser, and log out after using the SoraStream Service.

12. Conditions applicable to child's consent in relation to Soras Stream services

Pursuant to the GDPR the processing of a child's personal data is lawful when the child is at least 16 years old. If the child is under 16 years of age, such process shall only be considered lawful if and only to the extent that consent was given or authorized by the holder of parental authority or guardianship over the child. Member States may provide by law for a lower age for such purposes, provided that it is not less than 13 years. In the case of Spain it is set at 14 years. Sora Stream will make reasonable efforts to verify that consent was given or authorized by the holder of parental or guardianship over the child, taking into account available technology. In case you have any doubt or comment regarding SoraStream's parental control process or you want to inform us about any aspect related to a child, you can do it by email (using the email privacy@sorastream.com. SoraStream will act with total confidentiality in the analysis of the information provided.

THIRD PARTY SERVICES: DISCLAIMER OF WARRANTIES AND LIABILITIES

Sora Stream offers to its users a Free to Play access to other third party games that are not related to Sora Stream. That means that Sora Stream may contain links or facilitates access to third party websites and platforms Sora Stream which may also collect, use and share information about you and your device and your usage of the game while you are on that third party site. In this sense, you must take into consideration that Sora Stream’s terms and conditions and privacy policies do not cover nor regulate nor control any third parties’ products, actions or services. For more information about third-party practices, please consult their own terms and conditions and privacy policies.

If you access third party sites through Sora Stream, you do it freely and without any responsibility for Sora Stream. Sora Stream will process the correspondent data at all times according to our Privacy Policy, which you can visit here.

Sora Streams reserves the right to terminate your access to the third party website or platform through Sora Stream, as well as the provision of any or all content provided through it at any time and without notice, for technical, security, maintenance or power failure reasons or any other reasonable cause. Accordingly, Sora Stream does not guarantee the reliability, availability or continuity of a third party site or its content, so that the use of them by users is done at their own risk, and Sora Stream cannot be held accountable for the discontinuance or unavailability of such services.

In accordance with the above, Sora Stream is in no way responsible for any damages caused and disclaims any and all warranties or conditions, express, statutory and implied, including, by way of example and without limitation:

1. by errors or missing information in the content published by third parties;
2. by temporary unavailability of the third party website, app or platform;
3. warranties or conditions of uninterrupted or error-free access or use;
4. for the content of the information collected in the third party website or platform, nor for those opinions, comments, insights or other communications that are not issued directly by Sora Stream;
5. for any banned user account of the third party website or platform done by the third party, due to the user’s misbehavior or any other reason, such as the detection of viruses, use of automated software or bots, perform in-game services, suspicious IP addresses, etc, as stated in the Terms and Conditions of the correspondent third party, for which Sora Stream has no control nor liability;
6. for the unsuccessful access to the third party website or platform through Sora Stream;
7. vii. by any situation considered fortuitous or by unforeseen circumstances, despite having adopted all the reasonable technological measures necessary to avoid is, as defined in clauses 5.3 and 8 of Sora Stream’s EULA;

The exclusion of damages under this paragraph is independent of your exclusive remedy and survives in the event such remedy fails of its essential purpose or is otherwise deemed unenforceable.

These limitations and exclusions apply without regard to whether the damages arise from (a) breach of contract, (b) breach of warranty, (c) negligence, or (d) any other cause of action, to the extent such exclusion and limitations are not prohibited by applicable law. In case you do not agree with any of the above, or you have any dispute or claim against Sora Stream or its suppliers with respect to the above, then your sole and exclusive remedy is to discontinue using the Sora Stream Platform, its data, its brand and related links.

14. Avatar or Profile Picture

We inform you that if you add your own image as a profile picture, it will be public and any person or user will be able to access and view it. To configure the Privacy of the profile picture you have chosen, you must access the Profile Settings.

15. Changes to this Privacy Policy

Occasionally, we may make changes to this Policy. If we make material changes, we will provide you with a prominent notice under the circumstances, for example, by displaying one in the SoraStream Service or by sending you an email. We can notify you in advance.

Therefore, be sure to read any notification carefully.

16. How to contact us

If you have any questions about this Policy, please contact our Data Protection Officer by email to privacy@sorastream.com or by writing at the following address:

Ludium Lab, S.L (Sora Stream)
C/ Llauder 1, ent - 1A
PC 08003
Barcelona, Spain
The Data Controller is Ludium Lab, S.L (owner of the Sora Stream Platform).