Privacy Policy

HERE ARE THE KEY FACTS:

We are committed to protecting your information responsibly and using appropriate security measures. In this notice we explain how we look after your Personal Data (regardless of where you visit or access from) when you:

• visit our websites;
• visit and interact with our social media;
• access our published games;
• access any of our products and services;

ABOUT US:

We are a UK videogames developer and publisher called Primal Currents Ltd.

You can always:

• ask us for a copy of the information we have about you;
• ask us to update the information we have about you;
• ask us to delete the information we have about you; or
• ask us questions about how we use your information.

QUERIES AND COMPLAINTS

If you are unhappy with how we have handled your Personal Data, you also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (visit www.ico.org.uk, or call the helpline at 0303 123 1113). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us at [email protected] in the first instance.

You can also ask us or third parties to stop sending you marketing messages at any time by visiting primalcurrents.com/unsubscribe, or by following the opt-out links on any marketing message sent to you, or by contacting us at [email protected].

Primal Currents Privacy Policy

DEFINITIONS

Primal Currents Ltd acts as the Controller and is responsible for your Personal Data (collectively referred to as "Company", "we", "us", or "our" in this privacy notice).

For the purposes of this privacy notice, the following definitions shall have the following meanings:

• "Comply With A Legal Obligation" means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• "Controller" means the organisation that exercises overall control over the purposes and means of processing Personal Data.
• "Data Protection Laws" means the UK Data Protection Act 2018 and all other globally applicable legislation relating to privacy or data protection (including the EU General Data Protection Regulation, the California Consumer Privacy Act and the Brazil Lei Geral de Proteção de Dados Pessoais).
• "Explicit Consent" (where applicable) means your Personal Data will not be processed unless you have given your explicit consent to such disclosure (for example, disclosing to third parties for their marketing or where required by law).
• "Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• "Performance of Contract" or "Contractual Necessity" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• "Personal Data" means any information relating to natural persons who can be identified or who are identifiable directly from the information in question; or who can be indirectly identified from that information in combination with other information.
• "Special Category" or "Special Categories" of Personal Data means: (a) Personal Data revealing racial or ethnic origin; (b) Personal Data revealing political opinions; (c) Personal Data revealing religious or philosophical beliefs; (d) Personal Data revealing trade union membership; (e) genetic data; (f) biometric data (where used for identification purposes); (g) data concerning health; (h) data concerning a person's sex life; and (i) data concerning a person's sexual orientation.

THE DATA WE COLLECT ABOUT YOU

We collect, use, store and transfer different categories of Personal Data about you, which we have grouped together as follows:

• Identity Data includes but is not limited to first name, last name, username or similar identifier, title, and date of birth, video and photography at our events.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account, payment card details, and payroll data.
• Marketing and Communications Data include your preferences in receiving marketing from us and our third parties and your communication preferences.
• Profile Data includes your username and password, interests, preferences, records of your correspondence and engagement with us and feedback and survey responses.
• Technical Data commonly known as online identifiers and includes internet protocol (IP) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI), type of device, your login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Usage Data includes information about how you use our website, mobile platforms, products, and services (including text you disclose when using our social features).
• Game Data (to the extent constituting personal data - for example, when we take action against an account or remove chat data) includes information related to your game play and in-game activity, the services that you use and how you use them, and your devices and activities when you install or access our services, for example, in-game stats, history, progress, purchases, in-game socials and interactions. In most cases, this data reflects how your game character interacts within the game environment and not to you directly or indirectly as a real-world person.

If you decide to make a payment for any of our products and services, your Financial Data, which includes your bank account and payment card details, will be collected and processed by our external payment service provider. We will not have access to, collect, use, store or transfer your Financial Data.

We also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data is derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

LEGAL BASIS FOR DATA COLLECTION & PROCESSING

Our legal basis for processing your personal information varies depending on the type of information we collect and the context in which we collect it.

If you are a resident of the United Kingdom or of a jurisdiction where similar legal requirements may apply, such as Brazil, Switzerland, and the European Union, we rely on several legal bases to process information about you. We will process information about you where we have your consent, where we have a Legitimate Interest to do so, where the processing is necessary for the Performance of a Contract with you, and where we have a legal obligation to process your information. For example, we typically rely on the following:

• Consent when placing cookies on your device on the web (through our cookie consent manager and unless an appropriate exception applies), to send you email marketing or to deliver third-party targeted advertising to you on our services or when otherwise required by law.
• Our Legitimate Interests to process your information when providing you with customer service support, to market our services (where you have subscribed for an account with us or purchased goods or services from us and you have not opted out of receiving that marketing), to gain market insights and monitor player feedback for service improvements, for fraud prevention, security and anti-cheat purposes.
• Contractual Necessity to process information when you create a Primal Currents Account to enable us to provide you with our services.

HOW WE COLLECT YOUR DATA

We use different methods to collect data from and about you, including, but not limited to:

You may give us your Identity Data, Contact Data and Financial Data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

• purchase our products or services;
• create an account on our website, or play our game;
• link your social account to your Primal Currents Account or interact with our social channels (including on any social or gaming platforms);
• subscribe to our service or publications;
• request marketing to be sent to you;
• request support for our products;
• attend our events;
• enter a competition, promotion, or survey; or
• give us some feedback.

As you interact with our website and our products and services, we automatically collect Technical Data about your equipment, browsing actions and patterns.

Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to one of our games). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• for the Performance of a Contract that we are about to enter into or have entered into with you;
• where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to Comply With A Legal Obligation; or
• where we have your Explicit Consent.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you, where we use cookies, beacon technology, or similar software or where otherwise required by law. You have the right to withdraw your consent to relevant processing (e.g. for third party direct marketing) at any time by contacting us using the details provided above, or by changing your account preferences where available. The withdrawal of consent will not affect the lawfulness of any processing that took place before the withdrawal.

HOW WE HANDLE YOUR PERSONAL DATA

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, disclosed or being unavailable.

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In particular:

• Contact information (email addresses): Inactive contacts who have not engaged with us for 24 months will be removed. If you unsubscribe from emails, we keep a record of your email address and your consent so that we do not send you marketing communications again until your contact details are removed.
• Signed Non-Disclosure Agreements: for as long as the confidentiality obligations in them continue, which can continue after testing has ended and after the game is released. If you ask us to delete your information once testing ends, we will delete what we no longer need, but we will keep your signed agreement, as we may need it to establish, exercise or defend legal claims.
• Questionnaire answers, in-game surveys, and technical data held in server logs: for a period no longer than 24 months. If you ask us to delete your information once testing ends, we will delete what we no longer need.
• Your Primal Currents Account: until you ask us to delete it. We will review all accounts when each testing phase ends.

Once the data retention periods above expire, digital records are permanently destroyed or fully anonymised if retained for statistical or research purposes. In this case, all personal identifiers are removed permanently so individuals cannot be identified.

WHO ELSE HANDLES YOUR PERSONAL DATA

We use a small number of trusted service providers to run our website, our emails and our games. They process your Personal Data only on our instructions and under contracts that require them to keep it secure, and they may not use it for their own purposes. These include, but are not limited to:

• Cloudflare, Inc., based in the United States, operates a global network, which hosts our website and runs its server functions, and sends our automatic emails, such as the confirmation of your contact details, tester invitations and account support emails. Our contact list for email functionality is stored in the European Union, which the UK recognises as providing an adequate level of protection.
• Google Cloud EMEA Limited, which provides our email functionality. When you email us, your message and contact information are held there. Google may store and process the contents of our mailboxes in the United States and elsewhere, so your Personal Data may be processed outside the United Kingdom and the European Union. Where this happens, the transfer is protected by safeguards recognised under UK data protection laws.
• eSignatures.com. Any Non-Disclosure Agreements are held in the United Kingdom data region.
• DigitalOcean, LLC provides server hosting functions within the United Kingdom, where your Primal Currents Account and Game Data are held.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will notify you and obtain your consent to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

COMMUNITY ENGAGEMENT & GAME PUBLISHING PLATFORMS

When you interact with our social channels (such as BlueSky, Discord or Twitch), we receive information about you from your social platform provider. This information includes your name, email address, language preference, and profile picture. We will only retain your data for as long as your account is linked to your Primal Currents Account.

We use social listening tools and moderation technologies, to monitor publicly available conversations and content on online platforms, including on our Discord channel and other social media channels. This helps us to uphold our community standards through moderation, respond to community concerns and understand player sentiment to improve our games and services.

We do not use social listening data for profiling, advertising, or to target individuals in a way that could have legal or similarly significant effects. Additionally, this data is not shared with third parties for their own purposes.

We use AB Testing to enable us to separate users into groups to compare user interactions with different versions of our website and Primal Currents’ services. This allows us to collect information for statistical purposes about how users interact with our website and service so that we can improve them. We will use it to run experiments and limit access to new features so we can identify which features work best before permanently implementing any new features.

Where we enter into publishing arrangements with game development studios to publish their games on gaming platforms, both developer and publisher (Primal Currents Ltd) will process Personal Data and operate as separate controllers. We advise you to read both this privacy notice and the privacy notice on the developer studio website.

We collect Personal Data including Identity Data and contact information, player identifiers and email addresses, from publishing platforms that make our games available. These include but are not limited to Valve (Steam), Apple (iOS), and Google (Android) and Epic Games (Epic Online Services). The publishing platforms are responsible for your accounts and Personal Data on their platforms, and we encourage you to read their privacy notices. We will only retain your Personal Data for as long as your publishing platform account is linked to your Primal Currents Account.

MARKETING

We provide you with choices regarding our use of your Personal Data for marketing and advertising purposes. We have established the following Personal Data control mechanisms:

You will receive marketing communications from us if (a) you have opted into our marketing channels or (b) you have subscribed for an account with us or purchased goods or services from us and you have not opted out of receiving that marketing (save where local Data Protection Laws do not allow option (b)).

All of our marketing communications to you contain an opt out option and you can opt out at any time. Please note that the opt out will not affect the lawfulness of processing that has taken place before the opt out.

We will get your explicit opt-in consent before we share your Personal Data with any company outside Primal Currents Ltd for marketing purposes.

Last updated OCTOBER 1, 2026