This Privacy Policy explains to you how your personal information is collected and stored and what happens to it regarding the IndieBI Services. If you have any queries you can contact us at support@indiebi.com.

1. WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS
   1. We are INDIEBI SPÓŁKA AKCYJNA (incorporated and registered in Poland) of Polskiej Organizacji Wojskowej 25, 90-248 Lodz, Poland (“IndieBI”).
   2. This Privacy Policy applies to IndieBI, our websites, user accounts, customer and technical support and other products and services - “IndieBI Services” for short.
   3. This Privacy Policy governs personal data (or, in the USA, personally identifiable information) and applicable non-personal information (or, in the USA, non-personally identifiable information), which we collect from you when you are using the IndieBI Services ("personal data" means information which, on its own or in combination with other information, can be used to identify you).
   4. You acknowledge and agree that in signing up and accessing the IndieBI Services, you are at least 18 years old. We do not knowingly collect personal data from children under 16 years old. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact support@indiebi.com.
   5. We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal information contained in this Privacy Policy which is used by IndieBI in connection with the IndieBI Services, IndieBI is the data controller under EU data protection legislation.
2. WHAT INFORMATION IS COVERED?
   1. When you sign up for or use the IndieBI Services then we may collect certain information from you. The information that we collect varies depending on the particular IndieBI Services used, but this may include:
      1. Technical Details. When you use or access the IndieBI Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any console device identifier; your operating system, browser type or other software; and your hardware or other technical details.
      2. Sales Data. As part of the IndieBI Service, you may upload data about your games to the IndieBI platform, this could include data such as sales, marketing and visibility.
      3. Your Activities. When you use or access the IndieBI Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences and time spent using.
      4. Your Communications. If you contact us (e.g. via email or call for customer support) or post in chat sessions, complete an order form, or other areas of the IndieBI Services, we may collect and maintain a record of your contact details and the content of your communications.
      5. User Accounts, Forums and Newsletters. To access the IndieBI Services, you may need to create a user account. Or if you sign up to a newsletter, you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable IndieBI Services (e.g. when you sign up for a newsletter) and may include your name, username, a photo or avatar, email address, country of residence and contact information.
      6. Payment Details. If you pay for access to the IndieBI Services, we may collect payment information that you provide to us (e.g. debit or credit card information) and other information necessary to transfer funds.

      Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used, and to look at games industry trends (which may mean this aggregated or anonymised data is published publicly).

   2. What about cookies? We and third parties on our behalf also collect information about you via cookies and other advertising tracking technologies. You can find out more about our use of cookies and such technologies in our Cookie Policy. The Cookie Policy forms part of this Privacy Policy.
3. WHERE IS YOUR INFORMATION STORED?

   Where will your information be stored? The information we hold will primarily be stored and processed in the EEA, but there may be circumstances where we need to work with trusted third parties outside of the EEA in order to provide the IndieBI Services to you. We will take all steps reasonably necessary to ensure that this information is treated securely and in accordance with this Privacy Policy.

   All information we hold is stored on our secure servers which we own or license from appropriate third parties. We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.

4. HOW IS YOUR INFORMATION USED?
   1. How might your information be used? We may use the information above in order to (for example):
      1. Perform our agreement with you: provide the IndieBI Services to you, including: to carry out our obligations arising from any contracts between you and us and allow you to use the IndieBI Services when you choose to do so.
      2. For our legitimate commercial interests: monitor the performance of the IndieBI Services; ensure that the IndieBI Services are presented in the most effective manner for you and your device(s); enforce our Terms of Service and other policies; notify you about changes to the IndieBI Services; provide, maintain, protect and improve the IndieBI Services; and to protect IndieBI and IndieBI Services users.
      3. Comply with our legal obligations: where we are required to do so by law; and comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
      4. Based on consent: provide you with marketing information about products or services that you request from us or which we feel may interest you where you have asked us to do so.
   2. Will we ever share any of your information with other parties?
      1. We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
      2. We may engage third party service providers in the course of providing the IndieBI Services to you (e.g. data storage, server hosting, customer and technical support, game analytics, advertising etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.
      3. We may work with third party service providers (e.g. ad network and measurement services) to display advertising on the IndieBI Services and to manage our ads on third party sites. We may share certain information (such as your email address, country of residence and your age) with third parties so that we can better target ads and content to you. You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device and you may be able to opt-out from the collection of information by some of our advertising partners as further detailed in our Cookie Policy.
      4. We may share your information within the IndieBI company group for the purpose of providing the IndieBI Services.
      5. In the unlikely event of a reorganisation or merger of IndieBI we may transfer personal information to an involved third party who will protect this to at least the same level as we do in this Privacy Policy.
5. HOW YOU USE YOUR INFORMATION AND THIRD PARTIES?

   Please remember that any communications you have via the IndieBI Services may reveal details about you. Also, any information you post publicly will be publicly available to other people. We are not responsible for your use of any otherwise private personal information which you make available, or the activities of other users or other third parties to whom you give or make available your information or content. The IndieBI Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.

6. DATA RETENTION

   How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all IndieBI Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.

7. YOUR RIGHTS
   1. Can you ask us to stop processing your personal information? You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications. Our Cookie Policy also details how you can deactivate certain types of cookies and other ad tracking technologies that may be used in providing certain IndieBI Services.
   2. What are your rights? You have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain IndieBI Services may no longer function properly or be completely unavailable to you, including IndieBI Services which you have paid to use.
   3. Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: SUPERHOT Sp. z o.o. at Kosciuszki 17, 90-418 Lodz, Poland. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.
   4. Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact: support@indiebi.com.
8. OTHER
   1. Will we ever change this Privacy Policy? if we do we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on you as of the date of publication (i.e. the new “Last Updated” date). You are welcome to contact us if you have specific questions about the changes at support@indiebi.com. If you do not agree to those changes, regardless of whether you email us then unfortunately you must cease using all IndieBI Services.
   2. Are there any other documents you should read? We'd also like to remind you that our Terms of Service has more information about how we operate the IndieBI Services .