Privacy Policy

PRIVACY AND DATA POLICY ISSUED BY Broken Arms Games s.r.l.
Last Update 09/04/2026

1. INTRODUCTION AND GENERAL TERMS
   These terms apply to the use of games and other products developed by Broken Arms
   Games s.r.l. (‘Broken Arms Games / ‘we’ / ‘us’). Our office is at Via Giuseppe Garibaldi 6,
   Acqui Terme, AL, Italy. We are a company registered in Italy, with company number
   IT02557050065.
   This privacy and data (“Privacy Policy”) applies and has effect in respect of all games,
   related online services and other software and products made available by us (together the
   “Game(s)”).
   If you have any questions or comments about this Privacy Policy please contact us via email
   at contact@brokenarmsgames.com, using the following as mail subject: “Privacy Policy
   [GameName] – [Platform]”
   Broken Arms Games is committed to protecting and respecting your privacy. The Privacy
   Policy explains the basis on which personal information we collect from you will be
   processed by us. Where we decide the purpose or means for which personal data you
   supply through these online services is processed, we are the “data controller.” We will
   comply with all applicable data protection laws, including the General Data Protection
   Regulation 2016/679. Please read this Privacy Policy carefully as it contains important
   information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.
  By accessing a Game you authorise us to collect, store, access, transfer and use your
  information as described in this Privacy Policy. We may make changes to this Privacy Policy
  in future, which will be posted on this page.
  You should check this page from time to time to ensure you are aware of any changes.
  Where appropriate we may notify you of changes by email or through the Games.

1. INFORMATION WE MAY COLLECT ABOUT YOU
   We collect and process the following information which may include your personal data:
   Information provided by you when using the Game or the Online Service (“Submitted
   Information”) We may ask you for, or you may submit (including without limitation through
   voice or text features) personal and non-personal information and data to us through the
   Online Service and/or the Game whenever you contact us, submit User Content in the Game
   or on the Online Service. This may include:

• your email address (in the case of subscription to the newsletter service and access to the
  customer support service);
• your username and account in respect of the platform on which you are using the Game
  (for instance your Online ID for PlayStation®4 and your Apple Game Centre username and
  account details for iOS).
  We may also obtain other personal data about you if you voluntarily supply it through the
  Game and/or the Online Service.
  How you use our Services (“Analytics”) We may collect technical information about your use
  of the Game /or the Online Service through the use of tracking technologies and analytics.
  By way of example, data we may collect includes the following Analytics:
• how many times you access the Game;
• traffic data;
• the devices that you use to access the Game;
• your internet service provider; and
• the actions you take when playing the Game.
  When you install, uninstall or update the Game, a unique application number and information
  about your installation, for example, the type of operating system, may be sent to us.
  We use the following third party analytics providers (“Third Party Providers”):
• Google Analytics – https://policies.google.com/privacy
• Game Analytics – https://gameanalytics.com/privacy
• Facebook – https://www.facebook.com/about/privacy
• Playfab – https://playfab.com/privacy/
  The third party analytics providers listed above will collect Analytics on our behalf and in
  accordance with our instructions, and their applicable privacy notice. You can find out more
  about the way the Third Party Providers collect and process this information by following the
  above links to the privacy notice and/or terms and conditions for each applicable third party
  analytics provider. Broken Arms Games DOES NOT USE data regarding the use of tracking
  technologies and analytics for marketing, advertising or profiling the data subject for
  commercial purposes.
  Information about you collected from your device or Third Parties (“Content Information”)
  We may collect information about you which you make available to us and which is stored on
  your console, device, or your Facebook or other social media profiles. This might include
  images (photographs/screenshots), video or other digital content such as records of your
  gameplay. When you use your Online ID, Xbox Gamertag, Stadia Name and/or Apple Game
  Centre account details to access our Games and / or linking your PlayStation™Network,
  Xbox Live, Stadia™, Steam and / or Apple Game Center account to our Games, additional
  information is shared from the Apple Game Center profile. They will be used in accordance
  with Apple’s policies and this Privacy Policy.

1. HOW WE USE INFORMATION WE COLLECT ABOUT YOU
   We will use any information that we collect about you, including any personal data, for the
   purposes described to you at the time that we collect such information, and for the following
   purposes: Submitted Information

• to help us identify you and to open, run and monitor any accounts you hold with us;
• administration;
• to process your orders of Virtual Items and enquiries;
• to analyze technical information about the use of the Game /or the Online Service by the
  Users through tracking technologies and analytics for the improvement of our games, only
  using aggregated and non-personalized information.; and
• in the case of subscription to newsletter services or acceptance of our cookies, to send you
  information about, and updates concerning, the Online Service and/or the Game;
• in the case of subscription to newsletter services or acceptance of our cookies, to provide
  you with information about other games and services we offer that are similar to those that
  you have already purchased;
• to make suggestions and recommendations to you and other users of the Game about
  goods and services that may interest you or them;
• to allow you to participate in interactive features of the Game when you choose to do so;
  and
• to notify you about changes to the Game or the services we provide.
  Analytics
• to remember you and your player profile, including your avatar and saved data;
• to understand how, and how often, users play the Game and use the Online Service;
• to administer the Game and for internal operations, including troubleshooting, data
  analysis, testing, research, statistical and survey purposes; and
• to help us improve the Game and the Online Service to ensure that content is presented in
  the most effective manner for you and for your device; and
• as part of our efforts to keep any multiplayer elements for the Game safe and secure.
  Content Information
• to allow you to share your gameplay with other users of the Game and your friends;
• to allow you to participate in interactive features of the Game when you choose to do so;
• to make suggestions and recommendations to you and other users of the Game about
  goods and services that may interest you or them; and
• in the case of subscription to newsletter services or acceptance of our cookies, to provide
  you with information about other games and services we offer that are similar to those that
  you have already purchased.

1. WHY WE COLLECT INFORMATION ABOUT YOU
   To provide our Games and the Online Service to You As applicable, we will use information
   about you (including Submitted
   Information, Content Information and Analytics) for delivering our Games and the Online
   Service to you under the Terms of Use agreed between us, as well as:

• responding to your enquiries; and
• contacting you about matters requiring your attention.
  This processing of Submitted Information, Content Information and Analytics is necessary for
  us to pursue our legitimate interests of making our Games and the Online Service available
  to you, and ensuring that our Games function properly so that you have the best experience
  when playing any one of our Games and using the Online Service. To understand how users
  play our Games and use our Online Service We process information (including Submitted
  Information, Content Information and Analytics) to understand how players use our Games
  or our Online Service, and to compile Analytics and statistical aggregated and
  non-personalized reports regarding that activity. This processing is necessary for us to
  pursue our legitimate interests of (i) ensuring that our Games function properly so that you
  and other users have the best experience when playing any of our Games and using the
  Online Service, and (ii) improving the quality of our Games and our services, and providing a
  better experience to our users. Marketing We use various forms of marketing to provide you
  with promotional materials about our Games and/or the Online Service. We will not process
  your information for the purposes of marketing or pass your information on to third parties for
  the purposes of such marketing unless you give your consent or you have given it already.
  Direct Marketing: We might send you marketing emails (Newsletter) about products or
  services which are similar to or related to our Games or Online Service, but only following
  your voluntary subscription to the newsletter service. Advertising: We may use the
  information we collect about you to serve you advertisements via our Games or the Online
  Service, about other games and services we offer that are similar to those that you have
  already purchased and only following your Privacy Policy or Cookies acceptance. We work
  with the following third party providers to provide you with such targeted marketing:
• Facebook
  The processing of your information in this way is necessary for us to pursue our legitimate
  interests of ensuring that our Games remains accessible for all of our users.

1. DATA SHARING
   5.1 We will share your information with third parties only in the ways that are described in
   this Privacy Policy, including the third party analytics providers detailed in section 2 above. If
   you would like to find out more about how the third parties listed in this policy use your
   information, this should be set out in their respective privacy policies. 5.2 We keep your
   information confidential, but may disclose it to any member of our group (which means our
   subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of
   the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is
   reasonably necessary for the purposes set out in this privacy policy. However, this is on the
   basis that they do not make independent use of the information, and have agreed to
   safeguard this information. 5.3 In addition, we may disclose your information to the extent
   that we are required to do so by law (which may include to government bodies and law
   enforcement agencies); in connection with any legal proceedings or prospective legal
   proceedings; and in order to establish, exercise or defend our legal rights (including
   providing information to others for the purposes of fraud prevention). 5.4 If we are involved in
   a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email,
   account message and/or a prominent notice on our website of any change in ownership or
   uses of this information, as well as any choices you may have regarding this information. 5.5
   We may also disclose your personal information to third parties in order to enforce or apply
   the terms of agreements between us, to investigate potential breaches, or to protect the
   rights, property or safety of Broken Arms Games, our customers, or others. This includes
   exchanging information with other companies and organisations for the purposes of fraud
   protection and credit risk reduction.
2. CONSUMER CONTROL AND OPT-OUT OPTIONS
   If you do not wish to receive promotional or other marketing material from us or third parties
   then you can opt-out by changing your account settings in the Online Service at any time. In
   the case of subscription to the newsletter service, you can unsubscribe by clicking on the link
   in each communication sent. In the case of cookies, it is possible to activate the options to
   change the privacy choices by means of the functionalities available by each browser.
   Alternatively, you can contact us via the Support Service and let us know that you no longer
   wish to receive promotional or other marketing material from us or third parties.
3. YOUR RIGTHS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING
   TO YOU
   You have the following rights over the way we process personal data relating to you, as set
   out in the table below. We aim to comply without undue delay, and within one month at the
   latest. To make a request, please let our Data Protection Officer know via the Support
   Services . Ask for a copy of data we are processing about you and have inaccuracies
   corrected You have the right to request a copy of the personal information we hold about you
   and to have any inaccuracies corrected. We will use reasonable efforts to the extent required
   by law to supply, correct or delete personal information held about you on our files (and with
   any third parties to whom it has been disclosed to). Object to us processing data about you
   You can ask us to restrict, stop processing, or to delete your personal data if:

• you consented to our processing the personal data, and have withdrawn that consent;
• we no longer need to process that personal data for the reason it was collected;
• we are processing that personal data because it is in the public interest or it is in order to
  pursue a legitimate interest of Broken Arms Games, you don’t agree with that processing,
  and there is no overriding legitimate interest for us to continue processing it;
• the personal data was unlawfully processed;
• you need the personal data to be deleted in order to comply with a legal obligations;
• the personal data is processed in relation to the offer of a service to a child.
  Obtain a machine readable copy of your personal data, which you can use with another
  service provider
• If we are processing data in order to perform our obligations to you, or because you
  consented, if that processing is carried out by automated means, we will help you to move,
  copy or transfer your personal data to other IT systems.
• If you request, we will supply you with the relevant personal data in CSV format. Where it is
  technically feasible, you can ask us to send this information directly to another IT system
  provider if you prefer.
  Make a complaint to a Supervisory Authority
• If you are unhappy with the way we is processing your personal data, please let us know by
  contacting us via the Support Services.
• If you do not agree with the way we have processed your data or responded to your
  concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

1. Data Retention
   We will hold your personal information on our systems for as long as is necessary for the
   relevant service, or as otherwise described in this privacy policy. We consider that 12 months
   from the date of your last login an appropriate period of time to retain this data and after this
   date we will delete your details.
2. CHILDREN
   We do not use our Games and/or the Online Service to knowingly solicit data from or market
   to children under the age of 16. Our Terms of Use prohibit users aged under 13 years from
   accessing our Games and/or the Online Service. If a parent or guardian becomes aware that
   his or her child has provided us with information without their consent, he or she should
   contact us via the Support Services. We will delete such information from our files within a
   reasonable time.
3. Security
   10.1 We will take all reasonable technical and organisational precautions to prevent the loss
   misuse or alteration of your personal information. For example, our databases are password
   protected and encrypted using Transport Layer Security (TSL) and Secure Sockets Layer
   (SSL).
   10.2 Please be aware that, although we endeavour to provide reasonable security for
   information we process and maintain, no security system can prevent all potential security
   breaches.
4. ADVERTISEMENTS AND AD SERVING TECHNOLOGY
   11.1 Please note that we use third party providers of adverts and the adverts’ content is
   provided by these third parties and not Broken Arms Games. Examples of third party
   providers we may use from time to time are:

• AdMob https://www.google.co.uk/admob/
• AWIN https://www.awin.com/it
  11.2 If you are using an iOS device, you can find more information about how to opt out of
  personalised adverts by visiting https://support.apple.com/it-it/HT202074. 11.3 Third party ad
  providers may use precise methods to collect information as a result of ad serving through
  our Games and/or the Online Service. These entities may collect and use data for this
  purpose including software, applications, hardware, browser information, internet and on-line
  usage information and in-game information. This data may be used and disclosed in
  accordance with these Terms and this Privacy Policy of the company providing the ad
  serving technologies. You recognize and accept that the advertising companies who deliver
  ads for us may combine the information collected with other information they have
  independently collected from other services or products. These companies collect and use
  information under their own privacy policies. Although we take commercially reasonable
  steps to instruct such advertising companies to comply with these terms and conditions, we
  do not have access to or control of third party technologies.

1. INTERNATIONAL DATA TRANSFERS
   12.1 Information that we collect from you will be stored outside the European Economic Area
   (“EEA”) on a secured server in North Carolina, USA in the first instance. 12.2 As of the date
   of this Privacy Policy, the servers are owned and operated by Amazon Web Services
   (“AWS”). AWS has obtained approval EU data protection authorities to enable the transfer of
   data outside the EEA using EU-approved Data Processing Addendum and Model Clauses
   under which AWS commits to provide adequate protection to personal data of EEA citizens
   that processed and storeed on AWS servers. Broken Arms Games has entered into the
   EU-approved Data Processing Addendum and Model Clauses with AWS to ensure such
   protection.
   CONTACT INFORMATION
   All questions, comments or enquiries should be directed to Broken Arms Games via email at
   contact@brokenarmsgames.com. We will endeavour to respond to any query or questions
   within two business days. Broken Arms Games’s DPO/RPD can be contacted by email at
   contact@brokenarmsgames.com, that will analyze all the inquiries and will provide feedback,
   also through the Officer, within the provisions in the existing European Community legislation
   on personal data protection, Regulations UE 679/2016. © 2026 Broken Arms Games S.r.l.
   All trade marks are the property of the relevant owners. All rights reserved.