PRIVACY POLICY

Effective Date: January 1, 2019

Last Updated: October 16, 2019

Your privacy is important to us, and we take our responsibility of caring for it seriously. This policy describes what information Surge Innovations (Pty)Ltd collects when you use the mobile, online and downloadable products and services offered by Surge Innovations (Pty)Ltd and/or attend live events hosted by or in connection with Surge Innovations (Pty)Ltd ("products").

1. Information We Collect

The information we collect depends on what products you use and how you use them. Please see below for more details.

Information You Give Us Directly

We collect information you provide us, including:

When you participate in online multiplayer games, your in-game profile information, gameplay, and statistics are visible to all. In competitive game modes, we may record your gameplay, and your controller button inputs, and replay these together with your in-game profile information and game statistics to other players in-game.

Other Information We Collect When You Use Our Products

We collect other information automatically when you use our products, including:

We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.

Information Provided to Us by Third Parties

Mobile Platforms. If you play or purchase our games on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.

Other Third Parties

We may receive information from third parties, like Facebook or Game Center, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us.

We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.

Legal Basis for Processing

If you are a resident of the European Union, we rely on a number of legal grounds to process information about you. For example, 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 rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you create a Surge Account. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via the options in Section 11 below.

2. How We Collect Information

We collect some information from you when you provide it to us directly, such as via an online form or when you talk with our customer experience team via chat, email and telephone. We and third parties also use certain technologies described below to collect information to deliver excellent experiences.

Cookies and Similar Technologies

Cookies are small text files stored on your Internet browser. We use cookies and similar technologies to help us understand things like what web pages, features or ads you view and what games you play. This information helps us keep track of your shopping cart, measure the effectiveness of our advertising, make sure you don't see the same ad repeatedly and otherwise help enhance your user experience. You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you'd like help in managing your cookie preferences.

We also use Analytics, Advertising, Anti-Cheat and Anti-Fraud technologies in our products that utilize the same cookies and similar mechanisms. These technologies are described below.

Analytics Technologies

We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.

For instance, Surge Innovations may collect and store data from your computer or device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), information about your feature usage, gameplay and usage statistics, system interactions and peripheral hardware for purposes described in section 3, below. If you play a game offline, this data will be stored on your device and transmitted to Surge Innovations when your device connects to the Internet. If you participate in online services, Surge Innovations also may collect, use, store, transmit and publicly display your persona and/or statistical data regarding your game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.

Third party analytics services integrated into our products may combine the information they collect in connection with Surge Innovations' services with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies.

Ad Serving Technologies

Some of our products employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different websites, mobile apps and devices. The ads can be tailored to your interests. For instance, you may be presented with an offer for a game we think you might enjoy. Or if you express interest in a game, you might receive an advertisement later for that game or similar products on Surge Innovations or third party sites. Other in-game advertising technologies enable advertising to be temporarily uploaded to your game, web browser, or mobile device and later replaced while you are online.

These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes:

Third party advertising companies may combine the information collected in the context of delivering an ad to you via our products with other information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. A list of ad serving companies that operate their own networks on our sites and online and/or mobile products and/or services as well as how to opt out to the extent applicable can be found at privacyappendix.ea.com.

3. How We Use Your Information

We use your personal and non-personal information, both individually and combined together, in the following ways:

To operate our business and to enhance and personalize your game experience including to:

To provide you support, including to:

To personalize our communications with you, including to:

We retain the information we collect for as long as necessary to provide our products and services, and we may retain that information beyond that period if necessary for legal, operational or other legitimate reasons.

4. Information We Share with Third Parties

We do not share personal information that directly identifies you (such as your name, e-mail or postal address) with third parties for their own use without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona and game stats on leaderboards or to show trends about use of our products.

We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys, facilitating credit card processing, or sending emails. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.

We do not knowingly disclose directly identifying personal information from children under 18 years of age to independent third parties even with consent.

However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.

We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook "Like" button.

5. Where We Hold Your Information

Personal information we collect may be stored and processed for the purposes set out in this Privacy and Cookie Policy in South Africa or any other country in which Surge Innovations , or third party agents operate. By using our products, you acknowledge that your personal information may be transferred to recipients in South Africa and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

6. How We Protect Your Personal Information

Security of our players' information is a priority at Surge Innovations, and we take a range of measures to help protect it, including encryption of sensitive financial information. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.

7. Children

Protecting children's privacy online is extremely important to Surge Innovations . Many Surge Innovations online or mobile products and services are intended for general audiences and do not knowingly collect any personal information from children. When users identify themselves as being children we will: (1) not provide a path for them to input personal information, (2) collect certain information for limited purposes only, (3) block or restrict the child from accessing relevant; and/or (4) obtain consent from parents for the use of their children's personal information, all according to applicable law. When we say children, we mean under the age of 13 or the minimum age in the relevant territory if that age is older than 13. Through our mobile applications your child will be able to receive local in-app notifications, which do not collect any personal information.

Please note that if you grant consent for your child to use Surge Innovations' online or mobile products and services, this may include such general audience communication services as email, instant messaging, and online groups, and your child will be able to communicate with, and disclose personal information to, other users of all ages.

If you are a parent and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, contact the appropriate Privacy Policy Administrator for your country.

Information collected is secured in a manner consistent with this Privacy and Cookie Policy. If we make material changes to how we use, collect, or share your child's personal information, we will notify parents by email or by in-game notice in order to obtain verifiable parental consent for the new uses of your child's personal information.

We encourage you to talk with your children about communicating with strangers and disclosing personal information online.

Under no circumstances do we condition a child's participation in an activity—like contests—on the child's disclosure of more personal information than is reasonably necessary to participate in the activity. On certain sites, we may not permit children to participate at all regardless of consent.

8. Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of information. For example, you can update your account information and preferences, choose to opt in or out of Surge Innovations marketing emails. If you would like to opt out at any time after providing your consent, contact the appropriate Privacy Policy Administrator for your country.

You also can review and change most of your preferences through your Surge Account settings. If you need additional assistance, please contact support. If you no longer wish to receive marketing emails from Surge Innovations, you may also click the unsubscribe link included in the footer of every marketing email we send. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time.

You may deactivate your Surge Account or delete the personal information associated with your account by contacting Support or your Privacy Policy Administrator in your. If you do so, you will no longer have access to the Surge Innovations games or services associated with your account. Note that Surge Innovations may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you services, create and improve our products, comply with the law, and to run our business.

You can access the personal information we hold about you. To request access, please contact Support. Before we process any request, we may ask you for certain personal information in order to verify your identity.

You may have additional rights under local law, including the right to request erasure or portability of personal information and the right to object to or restrict processing of information. Where applicable, you can exercise these rights by contacting Support.

You also may adjust your browser settings to block certain online tracking, such as cookies, as further described in section 2.

9. Third Party Services

Our websites and products may contain advertising or third party services (such as the Facebook Like button or links to third-party websites). If you click on those links, including an advertisement, you will leave the Surge Innovations website and go to the site you selected. If you visit a third party website or use a third party service, you should consult that site's or service's privacy policy.

10. Changes to Our Policy

We may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice on our home page thirty days before they go into effect. If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this policy.

11. Contact Us

If you have a complaint or question about this policy, please send an email to info@surgeinnovations.co.za

12. Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer.