PRIVACY POLICY UK/EEA

Last Updated: May 30, 2024

NEW UK/EEA Supplemental Notice to the Privacy Policy

INTRODUCTION

This UK/EEA Supplemental Notice to the Privacy Policy (“UK/EEA Privacy Policy”) supplements the privacy policy available at www.skydance.com (the main website of Skydance Productions, LLC and of its parent, subsidiaries and other affiliates under its control) and describes how Skydance Interactive, LLC (“SDI”) and Skydance Silicon Valley, LLC (“SDSV”) (collectively, “Skydance Games,” “we,” “our,” or “us”), use and protect personal information of those who visit our Skydance Games websites directed to the UK/EEA (the “Websites”) or uses interactive features or downloads that are owned or operated by Skydance Games, or interact with us by means of other than the Websites, for example, through the websites, mobile apps and interactive services and games of our distributors and business partners, (collectively, the “Services”) or that Skydance Games otherwise collects in connection with its UK/EEA marketing activities.

This UK/EEA Privacy Policy applies to all visitors, users, and others who access the Services, or whose personal information we otherwise collect in connection with our UK/EEA marketing or customer service activities (such as when we interact with you on our Discord channels or you engage on our third party social media pages, but note, however, the privacy policy of that third party service shall also apply to that interaction). Please read this UK/EEA Privacy Policy carefully to understand our practices regarding your personal information and how we will process it. In addition, please review the Websites’ Terms of Use (accessible via a link on the home page), which governs your use of the Websites, as well as any Services specific terms.

When we use the phrase “Personal Information” in this UK/EEA Privacy Policy, we mean information that is capable of being associated with or could reasonably be linked with you, such as your name, email address, or mobile telephone number, and such other data that is considered to be “personal data” under the General Data Protection Regulation (“GDPR”).

Who is the Data Controller of your Personal Information?
Personal Information we collect from/ about you.
Purpose and legal basis for the Processing.
Disclosure of Personal Information.
How long do we keep your Personal Information.
What are your rights relating to the Processing of your Personal Information.
Children’s privacy.
Changes to this UK/EEA Privacy Policy.
Contacting Skydance Games.

1. WHO IS THE DATA CONTROLLER OF YOUR PERSONAL INFORMATION?

For the purposes of this UK/EEA Privacy Policy the data controller of your Personal Information will be, depending on which entity publishes the Website and/or promotes the applicable game, either Skydance Interactive, LLC or Skydance Silicon Valley, LLC, both domiciled at 2900 Olympic Blvd., Santa Monica, CA 90404.

Our GDPR representative in the European Union is Skydance Animation Madrid, S.L.U., with tax identification number B-88576178 and address at Complejo Europa empresarial, C/ Rozabella 4, Edificio Bruselas, 28290 Las Rozas, Madrid.

Our UK GDPR representative in the UK is Skydance Animation UK Limited, Company number 14665524 and address at C/O Flb Accountants Llp 1010 Eskdale Road, Winnersh Triangle, Wokingham, United Kingdom, RG41 5TS.

2. PERSONAL INFORMATION WE COLLECT FROM / ABOUT YOU

We collect information about you in several ways:

A. Information collected automatically when you access our Services.

We may collect “Usage Information” about how you use and interact with the Services and our Websites (our ability to do this will greatly depend on your configuration of cookies).

For example, when you access the Services, we may log which pages of our Websites were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We may also collect information from the URLs from which you linked to our Services. Collecting such information may involve logging the IP address or other unique identifier (“Device Identifier”) for your computer, phone, tablet or other device used to access the Services (any, “Device”), operating system and browser software used by each user of the Services. We may be able to determine from an IP address a user’s Internet service provider and the geographic location of the user’s point of connectivity. We may also use third-party Service Providers (defined below) such as Google Analytics to automatically log information about you and your computer or mobile device, and how you use and interact with the Services.

We also may use cookies, web beacons and/or embedded scripts to help us determine and identify repeat visitors, the type of content and sites to which a user of our Services links, the length of time each user spends at any particular area of our Website, and the specific functionalities that users choose to use.

For additional information on cookies and tracking technologies, see the cookie policy statement available via a “Cookies” and/or “Your Privacy Choices” link on the footer of the homepage of applicable Websites.

You can set your cookie preferences using the cookie preference tool available on via a “Cookies” and/or “Your Privacy Choices” link on the footer of the homepage, or on the cookie banner, of applicable Websites.

B. Information you give us.

We may collect Personal Information you choose to provide to us.

You provide this information to us in a variety of ways, such as when you submit forms on our Websites, when you interact with our customer support team, or when you interact with our teams at trade shows and fan events.

You are responsible for ensuring the accuracy of the information you submit to us. Inaccurate information may affect your ability to use the Websites, the information you receive when using the Websites, and our ability to contact you. For example, your email address should be kept current because that is one of the primary ways in which we communicate with you.

C. Information from other sources.

We may receive Personal Information about you from other sources, including from social networks, via our Discord channels or third parties such as our distributors, business partners and vendors. When you engage with our us or our Services on or through third-party social networking sites, such as Facebook or X (formerly Twitter), you may also allow us to have access to information from your profile (e.g., name, email address, photo, gender, birthday, location, friends, followers, the posts or the ‘likes’ you make). You can control what data you disclose through privacy settings available on some social networking sites. For more information about how you can customize your privacy settings and how such third-party sites process your Personal Information, please refer to their privacy policies and terms of use.

You are only obliged to provide the Personal Information that is necessary for Skydance Games to be able to provide you with the requested Services or to make available the Websites features that you have requested.

3. PURPOSE AND LEGAL BASIS FOR THE PROCESSING.

Purposes	Legal Basis
To provide, support, personalize, and make our Services more relevant and useful to you and others.	Our legitimate interest in understanding the preferences of our users in order to more effectively present our Services and ultimately increase ours and our partners’ sales.
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity. This includes disclosing the Personal Information with third parties, such as the police, courts of justice, private investigators, legal advisors, IT consultants, insurance companies, financial entities, and commercial partners, where required.	Our legitimate interest in preventing fraudulent activity that could harm Skydance Games, you and others, and in protecting our and your commercial interests and reputation.
We collect and process Usage Information to (i) provide the Services, (ii) analyze usage trends and give us more information about how people use the Services and our interactive games to improve the user experience, and (iii) track your access to our partners’ websites from our Websites.	The contract with you arising from your use of the Services (for the essential/ functional cookies) or your consent (for non-essential/ functional cookies, such as marketing cookies).
If you opt to subscribe to our email updates and newsletters, you may be required to provide us with your name, email address.	The contract with you arising from your subscription/ request.
You may also provide us information, including your name, email and any other information you choose to include, when you send us an email message or otherwise contact us for support. We may use this information to respond to your request.	The legal basis for the processing is the contract with you arising from your request.
To send newsletters and personalized commercial communications: we will use your identification and contact information to send you personalized information about news on our Websites, news of interest about our games, promotions and offers of our products and services, as well as similar products and services of other entities of the Skydance Games. This information may be sent by post, telephone and/or electronic means, and may involve sending personalized information about our products or services. You should bear in mind that this data processing may involve the prior analysis of your user or customer profile to determine what your preferences are (see following purpose) and, therefore, which products and services may be the best fit with your browsing and purchasing habits when it comes to sending you information. For example, based on your browsing and purchase history, we may personalize our suggestions about products and services that we believe may be of interest to you.	In the case of registered users, the legal basis will be the legitimate interest to carry out promotional activities through the submission of commercial communications relating to their products and services in order to increase their sales.In the event of non-registered users, the legal basis will be consent.You can request to unsubscribe from receiving commercial communications now and at any time and at no cost. This is an absolute right.
To analyze product improvement, quality assurance and failure prevention processes (i.e. analysis of the use of our games to find and correct glitches), to provide technical and other customer support to game users, as well as to improve customer service and process quality and to store and consolidate data within the Skydance Games ecosystem.	Our legitimate interest in understanding and analyzing the development of the business and improving its products and services to increase user engagement and sales.
To ensure the security of our Websites, other Services and information. For this purpose, we shall process electronic data such as your IP address, device type and identification, browser type, the domain through which you access the Websites, browsing data, activity on the Websites and use of the Services.	Our legitimate interest in ensuring and providing you with a secure environment to prevent damage to our systems and to our users, as well as preventing unauthorized access and misuse.

4. DICLOSURE OF PERSONAL INFORMATION.

We will not disclose your Personal Information other than as described below.

We may disclose the Personal Information we collect from and about you:

Transfers	Legal Basis
To fulfill the purpose for which we collected it.	Under the same legal basis for the primary processing
For specific purposes as determined when collecting your consent.	Consent
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.	Compliance with a legal obligation
If another entity acquires us or our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.	Our and the third party’s legitimate interestin reorganizing our commercial and/or corporate structure in accordance with our interests and objectives.

Vendors. We may contract with third parties to perform functions related to the Services (“Vendors”). Vendors will have access to your Personal Information needed to perform their business functions but may not use or disclose that Personal Information for other purposes. For example, Vendors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Websites or Services.

5. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION.

Skydance Games will retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected, provided that you do not exercise your right to erasure. Your Personal Information will then be deleted, unless a longer retention period is required or permitted by law (e.g. to prepare, file or defend against claims), in which case such data will be kept in an adequately blocked state for the time necessary before being erased.

To determine an appropriate retention period for your data, we apply the following criteria:

The Personal Information collected through cookies will be retained according to their intended purposes. For additional information, please visit our Cookie Policy available on the applicable Websites.
The Personal Information necessary to provide you with information you have requested will be kept for the time necessary to deal with and process that request. Afterwards, it will be kept in an adequately blocked state during the limitation periods for bringing legal action as set forth in the applicable regulations. Once this period has expired, it will be permanently deleted.
The Personal Information necessary to send you our Newsletter and any other promotional communications will be processed until you notify us of your wish to stop receiving it. It will then be kept in an adequately blocked state during the limitation periods for bringing legal action as set forth in the applicable regulations. Once this period has expired, it will be permanently deleted.
Any registration data, if collected by us, will be retained indefinitely unless you request that the registered username is deleted. It will then be kept in an adequately blocked state during the limitation period for bringing legal action. Once this period has expired, it will be permanently deleted.
When you have provided your consent to any given processing, the data will be kept until you revoke your consent, or the processing activity is completed. It will then be kept in a blocked state during the limitation period for bringing legal action. Once this period has expired, it will be permanently deleted.
The data collected and processed for fraud prevention will be retained only for the time necessary for its analysis. It will then be kept in a blocked state during the limitation period for bringing legal action. Once this period has expired, it will be permanently deleted.

6. WHAT ARE YOUR RIGHTS RELATING TO THE PROCESSING OF YOUR PERSONAL INFORMATION.

Where your Personal Information we process is subject to the GDPR (and UK version of it), UK and EEA data subjects have a number of rights in relation to our collection and processing of your Personal Information. You may exercise these rights free of charge, except in cases where the requests are manifestly unfounded or excessive – particularly if they are repetitive. These rights are as follows:

Right to information: You have the right to be informed in a concise, transparent, intelligible and easily accessible manner, using clear and simple language, about the use and processing of your Personal Information.

Right to access: You have the right to ask us at any time to confirm whether we are processing your Personal Information, to provide you with access to your Personal Information and information on its processing, as well as to obtain a copy of your Personal Information. The copy of your Personal Information that we provide to you will be free of charge but requests for additional copies may be subject to a reasonable charge based on the administrative cost of doing so. We may ask you to provide proof of your identity or require further information that is necessary to process your request.

Right to rectification: You have the right to request that inaccurate, out-of-date or incomplete Personal Information relating to you be rectified. You may also request that Personal Information which is incomplete be supplemented, including by providing an additional declaration.

Right to erasure: You have the right to request the erasure of your Personal Information if, among other reasons, the data is no longer required for the purposes for which it was collected. However, this right is not an absolute right and Skydance Games may continue to retain it in an adequately blocked state in the cases provided for by applicable law.

Right to restriction of processing: You have the right to request that we restrict the processing of your Personal Information, meaning that we may continue to store it, but may no longer process it if any of the following conditions are met: (i) you challenge the accuracy of the data, in which case processing will cease for the period of time necessary to allow the controller to verify the accuracy of the data; (ii) the processing is unlawful and you object to the erasure of the data and request instead that its use be restricted; (iii) Skydance Games no longer requires the data for processing purposes, but you require the data to prepare, file or defend against claims; (iv) you have objected to the processing, in which case processing will cease while we verify whether Skydance Games’ legitimate basis has priority over yours.

Right to data portability: You have the right to have the data that you have provided to us transferred to another controller in a structured, commonly-used and machine-readable format. This right applies where the processing of your Personal Information is based on consent, or the performance of a contract and that processing is carried out by automated means.

Right to object: You have the right to object to the processing of your Personal Information, including profiling. We may only disregard this right when processing your Personal Information if we are able to provide compelling legitimate grounds for the processing or when they are required to prepare, file or defend against claims.

Right to withdraw your consent: Where we have obtained your consent to the processing of your Personal Information in connection with certain activities (e.g. for the purpose of sending you e-mail marketing information), you may withdraw your consent at any time.

Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with your local data protection authority.

We may ask you to provide proof of your identity or require further information that is necessary to process your request.

You can exercise your rights by sending us a communication at privacy@skydance.com and explain your relationship with Skydance Games and explain the nature of the request you are making . When contacting us, you must provide information or documentation allowing us to identity you and any necessary details for us to process your request.

7. CHILDREN’S PRIVACY.

We do not direct the Services to, nor do we knowingly collect any Personal Information from, children under the age of 18. Children under 18 are not eligible to use the Services. If we learn that a data subject is under 18 years of age, we will take steps to remove that user’s Personal Information from our databases as required by applicable law.

8. CHANGES TO UK/EEA PRIVACY POLICY.

We may modify this UK/EEA Privacy Policy from time to time. If we make any changes, we will change the Last Updated date above. We also may provide additional notice, as applicable, depending on the type of change. If you object to any changes, you may stop using the Services. Your continued use of the Services after we publish or otherwise provide notice about our changes to the UK/EEA Privacy Policy means that you are consenting to the updated UK/EEA Privacy Policy.

9. CONTACTING SKYDANCE GAMES

If you have any questions or comments about this UK/EEA Privacy Policy or our related data practices, please contact us at privacy@skydance.com.