Online Privacy Policy

KLUGE INTERACTIVE.   |   ONLINE PRIVACY POLICY

Version 1.3 (June 2, 2025)

We respect your privacy and are committed to protecting it through compliance with this Privacy Policy. Our Services are operated by Kluge Interactive, (“we”, “us” or “our”).

We are a U.S. company, and the data controller responsible for your personal data with its registered address at: 4751 La Villa Marina Unit K Marina del Rey CA 90292.

Please note that this Privacy Policy (“Policy”) explains how we collect, use, and protect your Personal Data when you interact with our websites, applications, and games (“Services”). It also outlines your rights and how you can manage your data, including deletion, updates, transfers, and access.

This Policy applies to information we collect on our websites,(including klugeinteractive.com, synthridersvr.com, and finalfuryvr.com), in-game (including Synth Riders and Final Fury) and through electronic communications between you and our team. If you do not agree with our practices, please immediately refrain from using our Services. Please note that continued use of our Services after changes to this Policy constitutes acceptance of those changes. For questions or to exercise your data rights, email us at [email protected]. We typically respond within one to three business days.

Before using our Services, you have an obligation to read and acknowledge the following policies, which govern your rights and responsibilities:

• Kluge Terms of Services. https://klugeinteractive.com/terms/
• Kluge Privacy Policy. https://klugeinteractive.com/privacy-policy/
• Kluge Cookies Policy. https://klugeinteractive.com/cookie-policy/
• Synth Riders EULA. https://synthridersvr.com/eula
• Synth Riders Privacy Policy. https://synthridersvr.com/privacy-policy
• Synth Riders Code of Conduct. https://synthridersvr.com/code-of-conduct
• Synth Riders Health and Safety Warning: https://synthridersvr.com/health-and-safety  
• Final Fury EULA. https://finalfuryvr.com/eula/
• Final Fury Privacy Policy. https://finalfuryvr.com/privacy-policy/
• Final Fury Code of Conduct. https://finalfuryvr.com/code-of-conduct/
• Final Fury Health and Safety Warning. https://finalfuryvr.com/health-and-safety/

I. OUR ROLES

We function in both capacities of a Data Processor and a Data Controller, managing personal data, device data, and other data we may receive (collectively, your “Personal Data”) with respect to the nature of interaction with our Services. By continuing to use our Services, you acknowledge and agree to this dual-role structure and understand how your rights may vary depending on our role.

A. DATA PROCESSOR. As a Data Processor, we process Personal Data on behalf of third-party platforms (e.g., Community Platforms, Distribution Platforms) following their specified instructions. This role is focused on supporting our game titles and partnerships through data processing activities determined by these third-parties, without making decisions regarding the objectives or methods of data use. In this capacity, we do not make decisions about how your data is used, and any rights requests related to such data should be directed to the respective platform or service that controls your data.

B. DATA CONTROLLER. When acting as a Data Controller, we determine the purposes and means of processing Personal Data. This applies to interactions directly with our Services, including decisions on data collection, use, security, and storage, in compliance with applicable privacy legislation. Understanding our dual roles is important for you to know how and when you can exercise your privacy rights. As a Data Processor, your rights in relation to the data processed on behalf of third-parties should be directed to the respective data controllers. As a Data Controller, we directly manage how Personal Data is used, allowing you to exercise your rights with us directly, such as requesting access to, correction, or deletion of your Personal Data. If you are a resident of the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, and interact with our Services, please note that we may be required to appoint a local representative pursuant to Article 27 of the GDPR. You may contact us at [email protected] to request further information or confirm our representative contact details.

II. DATA COLLECTION.

We may collect Personal Data through the Services about your use and how you use them.

A. AGE REQUIREMENTS.  Our Services are intended for a wide range of ages. We provide age-rating information on the platforms where our games are distributed to help you assess whether they are appropriate for your children. Certain DLC, expansions, or future updates may carry a different or higher age-rating than the base Game.

1. Children’s Privacy. We do not knowingly collect personal information from children without verifiable parental consent. 

Parents or guardians are responsible for ensuring that their child uses our Services in compliance with this Policy. We require verifiable parental consent before collecting Personal Data from children under 13 years of age, as defined under the Children’s Online Privacy Protection Act (COPPA), and we comply with parental rights regarding review, deletion, and refusal of further data collection as mandated by COPPA.

If we discover that we have collected data from an individual under the age of majority without proper consent, we will immediately initiate a documented deletion process to remove this data from our records within thirty (30) days. If you believe we have collected information from someone under the age of thirteen (13), please contact us at [email protected], and we will take immediate steps to ensure compliance with applicable laws.

This policy is designed to comply with international data protection regulations, including but not limited to the Children’s Online Privacy Protection Act (“COPPA”), the General Data Protection Regulation (“GDPR”), and the California Consumer Privacy Act (“CCPA”). If you are located in the European Economic Area (EEA), we do not process Personal Data of children under the age of 16 unless we have obtained consent from the holder of parental responsibility, as required under Article 8 of the GDPR. We may adjust our practices to align with local legal requirements in different jurisdictions to ensure full compliance.

B. DATA CATEGORIES 

The following are examples of the types of Personal Data we may collect depends on which Services you use and how you use them. 

• Identifiers / Contact Data. Name, username, gamertag, postal and email address, phone number, unique personal and device identifiers (e.g., mobile device ID, platform ID, gaming service ID, advertising ID like IDFA and Android ID), first IP address, current IP address, last played date, created date, and IP address.

• Protected Characteristics. Age and gender. Please note that we only collect this information where permitted by law and where necessary to provide our Services.
• Commercial Data. Purchase and usage history, preferences (including gameplay data), shipping preferences and history, as well as survey and poll responses related to our Services.
• Billing Data. Transaction data (purchase history, delivery) and billing address. While Kluge does not collect sensitive payment information (such as credit card details), we do collect transaction history related to the game, Downloadable Content (“DLC”), or merchandise, including the date of purchase, purchase amount, item purchased, and username or unique platform/device ID.
• Internet / Electronic Activity. Web and app browsing and gameplay data relevant to the Services; interactions with our Services; details about the games and platforms utilized, including engagement data with content (e.g., likes, follows, comments), subscription data, community engagement data, advertisement interactions, leaderboard interactions, multiplayer service authentication data, and social moderation data (anti-cheat, player bans).
• Device and Usage Data. Device type, software and hardware details, language settings, browser type and version, operating system, and data about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls), platform-specific data, device performance data.
• Profile Inferences. Inferences made from your data and web activity to help create a personalized profile so we can identify goods and services that may be of interest. (We do not use this information to make automated decisions that produce legal or similarly significant effects as defined under GDPR Article 22.)
• Audio / Visual Data. Profile photos, images, avatars, audio data via chat features and functionality, and gameplay recordings and video footage (such as when you participate in playtesting or beta testing). Gameplay recordings may also include voice recordings, visual characteristics, and player movements, particularly in multiplayer testing or when using Mixed Reality features.
• Sensitive Data. Contents of communications via chat features and functionality, including recorded audio and gameplay voice data when participating in multiplayer testing or game-related activities. This may include data subject to special protections under applicable law, such as under the CPRA or GDPR. We implement strict safeguards for all such data.
• Geolocation Data. Inferred geographic location data derived from your device or network. We do not collect precise geolocation unless explicitly permitted through your device settings.
• Professional or Employment-Related Data. For individuals applying through our Careers page, this includes employment history, resumes, and, where applicable, background check data. Such data is collected solely for employment-related purposes and not used for marketing.

III. DATA SOURCES

The way we obtain Personal Data depends on how you use the Services. For example, we collect Personal Data:

• When you provide data directly to us, such as when you interact with our Services, sign-up for marketing, or contact us.
• From third-parties, such as advertising networks, business partners, third-party data providers, and other players; from third-party platforms, such as when you play our games or access our Services with third-party accounts.
• Automatically, including through cookies and similar tracking technologies.

A. FROM YOU

You provide us with Personal Data when you use the Services, such as when you: 

• Use our Services;
• Subscribe to marketing and communications;
• Comment on our message boards, forums, chat rooms, feeds, websites, or other Services;
• Purchase or redeem one of our products or Services;
• Download, install, or access demos, games, or other software;
• Contact us for support or other purposes;
• Use our email or share features;
• Participate in events, giveaways, contests, promotions, surveys, or playtesting;
• Participate in an activity where you provide your data;
• Apply for a job with us; or
• Partner with us in a shared business, promotion, or charity.

We do not link or combine your Personal Data across platforms or devices, meaning your data remains unique to the specific platform or device you use. However, certain core functional data, such as leaderboard scores, may be aggregated across all platforms and devices to ensure consistent gameplay features. Additionally, we aggregate de-identified analytics data across certain platforms and devices where permitted by the platform. Where required by law, we will provide clear notices and obtain appropriate consent prior to collecting Personal Data.

B. FROM THIRD-PARTIES

We collect data when you access our Services with third-party platform accounts, such as a gaming platform account, gaming network service account, or social networking service account. When you access our Services in this way, the third-party platforms provide us with data about you.  For example, depending on your use of, or activity on the third-party platform, we receive your username, your friends list, or account data necessary to provide the Services. The third-party platform may allow you to control what data is provided to us. We are not responsible for the terms, policies, disclosures, or actions of any third-party platforms.

We receive data from third-parties to update the data that we collect about you. We may receive data from public databases, platform manufacturers, analytics providers, game developers, and other business partners involved in providing the Services to you, that includes demographic data and data about your interests.  We may collect publicly available data, including from social media, to protect our users, employees, facilities, and Services, and to aid investigations. We also receive data from other individuals who use our Services. This may include data about you if you are mentioned in comments on the Services or an individual sends us a direct message.

When we collect Personal Data about you from a third-party source, and not directly from you, we will provide you with the required notice of collection under Article 14 of the GDPR or CCPA §1798.100, either at the time of collection or within the required time period (generally within thirty (30) days), unless an exemption applies.

C. FROM AUTOMATIC TOOLS

To enhance your experience and maintain the functionality and security of our Services, we use a variety of automatic tools to collect data as you interact with our platforms. This data is gathered directly from your device or through tracking technologies and helps us personalize your content and improve our features.

1. From Your Device

When you use our Services, we automatically collect data about your experience, including device and usage data, gameplay data, log data, and location data.

• Device and usage data. We may collect device and usage data, such as your IP address, device type, operating system, browser type, and usage data.
• Gameplay data. This includes your platform ID or gaming service ID, game achievements, scores, IP address, MAC address, and other device identifiers. We may combine this data with other information we have about you. We also use anti-cheat technologies to detect and prevent cheating.
• Log data. We collect details on how you use our Services, including device information and event data. This helps us diagnose issues and improve our Services.
• Location data. With your permission, we may collect location data through your device settings to provide location-based services, such as relevant content or ads.

2. From Cookies and Similar Technologies.
   Our Services use cookies and similar technologies to collect data, enhance your experience, and improve our Services. We use cookies (small text files stored on your device) to recognize you and personalize your experience on our Services. You can manage or delete cookies through your browser settings, though refusing cookies may limit your access to certain features. We also allow third-parties, such as social media and analytics providers, to use cookies and other tracking technologies on our Services. Please see our Cookie Policy, available at https://klugeinteractive.com/cookie-policy/, for more information about the cookies we use, including how to manage and delete cookies. Please note that under applicable laws, we provide you with clear information about our use of cookies, and where legally required, we obtain your prior consent (e.g., via cookie banners) before setting non-essential cookies. Again, you may opt out or manage your preferences at any time using the tools provided in our Cookie Policy.

IV. DATA PROCESSING

We use Personal Data collected from our Services to provide, maintain, and improve our Services, to develop new Services and offerings, and to protect us and our users.

A. PURPOSES

A. Business Purposes

We use Personal Data to support and enhance the delivery of our Services. This includes:

• Responding to Inquiries and Fulfilling Requests. Addressing your inquiries and fulfilling service requests.
• Personalizing User Experiences. Tailoring experiences by remembering your preferences and settings.
• Providing Technical Support. Offering technical support and resolving service-related issues.
• Analyzing Service Usage. Refining existing services and developing innovative new products.
• Conducting Internal Reviews. Performing marketing studies and demographic analyses.
• Ensuring Security and Integrity. Safeguarding our services against fraud and managing risk.
• Interacting with Third-Party Platforms. Facilitating connections with third-party platforms as authorized by you.
• Processing Activities. Engaging in processing activities explicitly agreed upon by you at the point of data collection.
• Legal Compliance. Adhering to all applicable legal requirements and enforcing our Terms of Service.

B. Commercial Purposes

For commercial endeavors, we use Personal Data to:

• Deliver Personalized Content. Providing tailored content, promotions, and advertisements across various platforms and channels.
• Inform About New Services. Keeping you updated about new services, features, and promotional offers.
• Administer Promotional Events. Managing rewards programs, surveys, and contests.
• Targeted Marketing Strategies. Using aggregated or anonymized Personal Data for precise marketing strategies and audience analysis.

B. LEGAL BASIS

For users in jurisdictions requiring a clear legal basis for data processing:

• We process data to fulfill our contractual obligations, provide requested Services, and facilitate online gameplay.
• Data processing is carried out in compliance with legal obligations.
• We pursue legitimate interests or those of our partners to enhance our offerings, understand user preferences, perform marketing activities (where consent is not required), support our operations, and enforce our policies.
• To protect the vital interests of users or others where necessary.
• With explicit user consent for specific processing activities, including marketing communications and integration with third-party services.

Where our use of your Personal Data requires your consent, you can provide such consent: at the time we collect your Personal Data following the instructions provided; through in-game consent mechanisms that prompt you to agree to data collection and usage; or by informing us by email, post or phone using the Contact Details set out in this Privacy Policy.

V. DATA SHARING

We share Personal Data under specific circumstances to support our Services, comply with legal requirements, and enhance user experience.

A. GENERALLY

We share your data for the following reasons:

• With Consent. We share information with companies, organizations, or individuals outside of Kluge Interactive when we have your explicit consent.
• For Service Provisioning. Trusted partners and affiliates process information on our behalf, based on our instructions and in line with our privacy practices, to support our service delivery and operations.
• Legal and Safety Reasons. Information is disclosed to meet legal requirements, protect our rights, and ensure the safety of our users and the public. This includes responding to legal processes or addressing fraud and security issues.
• Business Transfers. In events like mergers or asset sales, your information may be part of the transferred assets. We will notify you in such cases.
• Analytical and Advertising Needs. We partner with third-parties for analytics and targeted advertising, sharing aggregated or non-personally identifiable information to improve our Services and offer relevant advertisements.
• Public Forums and Community Engagement. Participation in open communities may lead to public sharing of any information disclosed by you either over public forums (like Discord) or at community events.
• Collaborative Efforts. Information may be shared with third-parties for collaborative services or promotions, with clear communication at the point of collection for your informed decision.

We may “share” your personal information as defined under the California Consumer Privacy Act (CCPA/CPRA), including with advertising or analytics providers, to deliver personalized ads or content. You have the right to opt out of this type of sharing at any time by contacting us at [email protected] or following the instructions in Section IX.

Please note that we do not “sell” Personal Data as defined under the CCPA, meaning we do not exchange your Personal Data for money. Where we engage in any activity that could be construed as a “sale” or “share” under CCPA/CPRA definitions, we will provide appropriate opt-out rights and notice at collection.

You have control over your Personal Data, including choices about how we share your Personal Data with third-parties for advertising and analytics. For more details, see Section YOUR CONTROLS.

B. CATEGORIES OF THIRD-PARTIES

We disclose your Personal Data for business purposes to the following categories of third-parties: 

• Authorized Representatives. Individuals or entities authorized by you to act on your behalf, including but not limited to, legal advisors, agents, or other representatives managing transactions, disputes, or legal matters.
• Affiliates. This category includes companies within the Kluge Interactive family, such as subsidiaries, parent companies, or other entities under common control, sharing resources to provide and improve Services.
• Service Providers. External organizations that provide essential services on our behalf, including but not limited to, web hosting, data analytics, payment processing, customer support, email distribution, and marketing efforts.
• Advertising and Analytics Partners. Third-party advertisers and analytics providers that collect information to serve targeted advertising and to furnish us with analytical insights concerning service usage and user preferences.
• Legal and Regulatory Authorities. When required by law or to protect our rights and safety, Personal Data may be shared with law enforcement, regulatory agencies, or other governmental bodies.

We are committed to partnering with entities that uphold robust privacy practices. However, our Privacy Policy does not cover third-party services or products linked from our Services. We do not oversee the privacy policies or settings of third-party websites, including Community Platforms, Distribution Platforms, and Payment Processors. For further information, please see Section YOUR CONTROLS for the relevant privacy policies for each third-party we work with. 

C. PUBLIC INTERACTIONS

When participating in our services or engaging on platforms that host our services, be aware that certain information, such as your username and profile details, may become publicly visible. This visibility extends to your activities within social networks, including your username, profile, and associations, which may be displayed on our services. 

Additionally, posting Personal Data, images, or videos in public forums, or including Personal Data in your username or ID, makes this information accessible to others. Public forums offer no expectation of privacy, so we advise against sharing sensitive Personal Data in these areas.

You are responsible for any data or content you publicly post using our services. We strongly urge you to exercise caution and consider the public nature of the information shared through these platforms.

D. THIRD-PARTY LINKS 

Our Services may contain links to third-party websites and services. Please remember that when you use a link to go from our Services to another website or you request a service from a third-party, this Privacy Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third-parties linked to our Services. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to Personal Data collected by us through our Service and does not apply to these third-party websites and third-party service providers.

VI. DATA STORAGE & RETENTION

We store and process your data in the United States. We’ll keep your data for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

A. STORAGE

When you access our Services, including when available on third-party platforms, your Personal Data is generally collected by us directly and processed in the United States. Personal Data we may collect may be subsequently stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which we, our subsidiaries, or third-party agents operate. 

Specifically:

• General Data Storage. Most Personal Data collected, including data related to gameplay and leaderboard events, is stored on Kluge-managed AWS services located in the United States.
• China-specific Data Storage. For players accessing our Services from China via the Pico platform, Personal Data is collected and processed on a Pico-owned AWS service located within China, complying with local data storage regulations.
• Organizational and Employee Data Storage. Organizational records, including employee data, financial records, and other operational documents, are stored on secure servers managed by our company and/or trusted third-party service providers, primarily located in the United States.

By consenting to the transfer of your Personal Data outside of your country of residence, you acknowledge that your Personal Data may be transferred to recipients in the United States, China, and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

B. RETENTION

We retain the data we collect in accordance with our Retention Policy, for as long as necessary to provide our Services, and we may retain that data beyond that period if necessary for legal, operational, or other legitimate reasons.

• Account Data. Retained while active and for 5 years after account termination or a request for deletion. Deleted thereafter.
• Transactional Data (e.g., financial records). Retained for 7 years. Archived or deleted thereafter.
• Biometric Data. Stored only momentarily as required by applicable law for operational purposes (such as authentication) and deleted immediately after use. Retained up to 3 years if necessary for legal compliance. Deleted thereafter.
• Communications and Inquiries Data. Retained for 2 years after resolution. Deleted thereafter.
• User Generated Content. Retained while active and for 2 years after inactivity. Deleted or anonymized thereafter.
• Marketing Data. Retained until opt-out or withdrawal of consent. Deleted thereafter.
• Legal and Compliance Data. Retained as required by applicable laws. Archived or deleted thereafter.

If you wish to request that we no longer use your Personal Data to provide Services to you, please see Section YOUR RIGHTS on how to exercise your rights or contact us at [email protected].

We may retain some Personal Data for a reasonable time to resolve disputes; enforce our terms and policies; administer Services; comply with technical and legal requirements; and maintain security, integrity, and operation of Services.

Where possible, we de-identify, anonymize, or aggregate data for business purposes as permitted by law. De-identified data is not subject to access or deletion requests under CCPA or GDPR.

VII. DATA SECURITY

We are committed to keeping your Personal Data secure and take reasonable precautions to protect your Personal Data from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the Personal Data that we have under our control from:

• Unauthorized access;
• Improper use or disclosure;
• Unauthorized modification; and
• Unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your Personal Data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of Personal Data, are obliged to respect the confidentiality of the Personal Data of all users of our Services.

Despite our best efforts, no security measure is entirely foolproof. We cannot guarantee the security of your Personal Data, and we cannot be responsible for unauthorized access to or theft, alteration, or destruction of your Personal Data. You are responsible for keeping your login credentials and passwords confidential. If you suspect unauthorized activity related to your platform account, please contact the platform provider directly. For issues specific to our Services or data managed by us, please contact us at [email protected].

In case of a data breach affecting your Personal Data, we will notify you as required by law and take steps to mitigate the breach’s impact.

VIII. YOUR RIGHTS

We believe that respecting your privacy and providing you with control over your Personal Data is fundamental to our relationship with you. We understand that you have a right to make choices about how your information is used and shared. 

A. OVERVIEW

Depending on your location, you may have certain rights over your Personal Data, including:

• Right to Access. If you ask us, we’ll confirm whether we’re processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Right to Correct. If the Personal Data we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your Personal Data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Personal Data with so that you can contact them directly.
• Right to Delete. You can ask us to delete or remove your Personal Data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your Personal Data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your Personal Data with so that you can contact them directly.
• Right to Object. You can ask us to stop processing your Personal Data, and we will do so, if we are: (1) relying on our own or someone else’s legitimate interests to process your Personal Data, except if we can demonstrate compelling legal grounds for the processing; or (2) processing your Personal Data for direct marketing.
• Right to Withdraw Consent. If we rely on your consent (or explicit consent) as our legal basis for processing your Personal Data, you have the right to withdraw that consent at any time. We will assess any deletion request on a case-by-case basis and will endeavor to respond as soon as possible, at most within thirty (30) working days.
• Right to Restrict Processing. You can ask us to ‘block’ or suppress the processing of your Personal Data in certain circumstances such as where you contest the accuracy of that Personal Data, or you object to us processing it. It won’t stop us from storing your Personal Data though. We’ll tell you before we lift any restriction. If we’ve shared your Personal Data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your Personal Data with so that you can contact them directly.
• Right to Opt-Out of Automated Decision-Making and Profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
• Right to Data Portability. With effect from 25 May 2021, you have the right, in certain circumstances, to obtain Personal Data you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third-party of your choice.
• Right to Lodge a Complaint. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your Personal Data, you can report it to the FTC (Federal Trade Commission). You can find details about how to do this on the FTC website at https://reportfraud.ftc.gov/#/.

Under the CCPA/CPRA, California residents may also request to know the categories and specific pieces of personal information we have collected about them, request deletion, opt out of sharing or selling personal information, and limit the use of sensitive personal information. These rights apply regardless of how the personal information was collected (online or offline).

For parents or legal guardians of users under 13 (under COPPA), you may request access to your child’s Personal Data, request its deletion, or withdraw your prior consent at any time.

B. EXERCISING YOUR RIGHTS

You can make a data rights request in relation to your Personal Data by contacting us at [email protected]. We will respond to data requests within a month. We may take steps to verify your identity before we can respond to your request. To opt out of online personalized advertising more broadly, please see the controls available in the next Section YOUR CONTROLS. We will not discriminate against you for exercising any of these rights.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

To the extent these rights apply to you, they may be limited in some situations, e.g., when we are under a legal requirement or have a compelling interest in processing your Personal Data, or when the Personal Data is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a privacy authority. A list of privacy authorities is available at https://globalprivacyassembly.org/participation-in-the-assembly/list-of-accredited-members/. 

If you are located in the EEA, UK, or other jurisdiction with equivalent protections, and are unsatisfied with our response, you have the right to file a complaint with your supervisory authority.

IX. YOUR CONTROLS

A. WITH US

Privacy Settings

Where applicable, you can manage privacy settings within our Services and customize preferences to opt-in or opt-out of Personal Data collection. We provide in-game and account-based settings where applicable to control how your data is shared, including visibility to other users and third-party integrations.

Communications/Advertising

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested.  We may also send you non-promotional communications regarding us and our Services regarding our Services or updates to our Terms or this Privacy Policy. If you prefer not to receive marketing messages or sponsored content, please contact us at [email protected] and we will ensure your preferences are updated accordingly. You may also use opt-out tools made available through our Cookie Policy.

Do Not Sell or Share My Personal Information (CCPA)

If you are a resident of California, you have the right under the California Consumer Privacy Act (CCPA) to opt out of the sale or sharing of your personal information. To exercise this right, please contact us at [email protected] with your request.

B. WITH THIRD-PARTIES. Our Services integrate with various third-party providers, including Community Platforms, Distribution Platforms, Marketing Providers, Payment Processors, and Security and Performance Providers. You can customize your privacy settings within your account settings through these providers to control the data that is shared with us. We are not responsible for the privacy practices of third-party services, and your interactions with those platforms are governed by their respective privacy policies. We encourage you to review their corresponding Terms of Service and Privacy Policy through the links below:

Community Platforms

• Discord (Discord Inc.). Terms of Service (https://discord.com/terms); Privacy Policy (https://discord.com/privacy)
• Patreon (Patreon Inc.). Terms of Use (https://www.patreon.com/policy/terms); Privacy Policy (https://www.patreon.com/policy/privacy)
• X / Twitter (X Corp.). Terms and Conditions (https://twitter.com/en/tos); Privacy Policy (https://twitter.com/en/privacy); X / Twitter Personalization Settings (https://twitter.com/personalization)
• Facebook (Meta Platforms, Inc.). Terms of Service (https://www.facebook.com/terms.php); Privacy Policy (https://www.facebook.com/policy.php)
• Instagram (Meta Platforms, Inc.). Terms of Use (https://help.instagram.com/581066165581870); Privacy Policy (https://privacycenter.instagram.com/policy)
• Reddit (Reddit Inc.). User Agreement (https://www.redditinc.com/policies/user-agreement); Privacy Policy (https://www.redditinc.com/policies/privacy-policy)
• Vimeo (Vimeo Inc.). Terms of Service (https://vimeo.com/terms); Privacy Policy (https://vimeo.com/privacy) 
• YouTube (Google LLC). Terms of Service (https://www.youtube.com/t/terms); Community Guidelines (https://www.youtube.com/howyoutubeworks/policies/community-guidelines/)

Distribution Platforms

• Meta Platform Technologies (Meta Platforms, Inc.). Terms of Service (https://www.meta.com/legal/terms-of-service/); Privacy Policy (https://www.meta.com/legal/privacy-policy/)
• Apple Arcade (Apple Inc.). Terms of Service (https://www.apple.com/legal/internet-services/terms/site.html); Privacy Policy (https://www.apple.com/legal/privacy/en-ww/)
• Steam (Valve Corporation). Terms of Service (https://store.steampowered.com/subscriber_agreement/); Privacy Policy (https://store.steampowered.com/privacy_agreement/) 
• PlayStation (Sony Interactive Entertainment). Terms of Service (https://www.playstation.com/en-us/legal/terms-of-service/); Privacy Policy (https://www.playstation.com/en-us/legal/privacy-policy/) 
• Viveport (HTC Corporation). Terms of Service (https://www.viveport.com/legal/); Privacy Policy (https://www.viveport.com/legal/privacypolicy/)
• Pico (ByteDance Ltd.). Terms of Service (https://www.pico-interactive.com/us/terms-of-service); Privacy Policy (https://www.pico-interactive.com/us/privacy-policy)
• Play Store (Google Play). Terms of Service (https://play.google.com/about/play-terms/index.html); Privacy Policy (https://policies.google.com/privacy)

Marketing Providers

• Google Analytics (Google LLC). Terms of Service (https://marketingplatform.google.com/about/analytics/terms/us/); Privacy Policy (https://policies.google.com/privacy); Google Analytics Opt-Out (https://tools.google.com/dlpage/gaoptout)
• Google Tag Manager (Google LLC). Terms of Service (https://marketingplatform.google.com/about/tag-manager/terms/); Privacy Policy (https://policies.google.com/privacy)
• Facebook Pixel (Meta Platforms, Inc.). Terms of Service (https://www.facebook.com/legal/terms); Privacy Policy (https://www.facebook.com/privacy/explanation); Facebook Pixel Ads Preferences (https://www.facebook.com/ads/preferences/)
• Mailchimp (The Rocket Science Group LLC). Terms of Service (https://mailchimp.com/legal/terms/); Privacy Policy (https://mailchimp.com/legal/privacy/)
• Redbubble (Redbubble Limited). Terms of Service (https://www.redbubble.com/agreement); Privacy Policy (https://www.redbubble.com/privacy)

Payment Processors

• PayPal (PayPal Holdings, Inc.). Terms of Service (https://www.paypal.com/us/webapps/mpp/ua/legalhub-full); Privacy Policy (https://www.paypal.com/us/legalhub/privacy-full)

Security and Performance

• Amazon AWS S3 (Amazon Web Services, Inc.). Terms of Service (https://aws.amazon.com/service-terms/); Privacy Policy (https://aws.amazon.com/privacy/)
• Cloudflare (Cloudflare, Inc.). Terms of Service (https://www.cloudflare.com/terms/); Privacy Policy (https://www.cloudflare.com/privacypolicy/)
• Unity Analytics (Unity Technologies). Terms of Service (https://unity.com/legal/terms-of-service); Privacy Policy (https://unity3d.com/legal/privacy-policy)
• bHaptics (bHaptics Inc.). Terms of Service (https://www.bhaptics.com/legal/terms-of-service); Privacy Policy (https://www.bhaptics.com/legal/privacy-policy)
• Twitch (Twitch Interactive Inc.) Terms of Service (https://legal.twitch.com/en/legal/terms-of-service/); Privacy Policy (https://legal.twitch.com/legal/privacy-policy)

X. GENERAL PROVISIONS

A. POLICY UPDATES

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your Personal Data, we will update this Privacy Policy to reflect any changes to our use of your Personal Data. We may also make changes as required to comply with changes in applicable law or regulatory requirements.

We will make available to you here any significant changes to the policy, whether based on a change of law or otherwise. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your Personal Data. Where required by law, we will notify you of material changes before they take effect and, where applicable, obtain renewed consent, as provided for in this Policy, for changes involving new purposes of processing.

B. CONTACT US.  If you have questions about this Policy or our privacy practices, please contact our Data Protection Team at [email protected].

C. CONTACT A DATA PROTECTION AUTHORITY (DPA). If you have a concern about how we may collect and use data, please contact us. You also have the right to contact your local Data Protection Authority (“DPA”) if you prefer. 

To contact your local DPA, refer to the links below: 

• EEA. DPA Directory (https://edpb.europa.eu/about-edpb/about-edpb/members_en)
• UK. Information Commissioner’s Office (ICO) (https://ico.org.uk/global/contact-us/)
• Canada. Office of the Privacy Commissioner (OPC) (https://www.priv.gc.ca/en/privacy-topics/information-and-advice-for-individuals/reporting-concerns-and-filing-complaints/)

Where appropriate, your local DPA may also forward the matter to the Department of Commerce or FTC for consideration.

Acceptance. By selecting “I Agree,” “Accept,” “Agree/Continue,” “OK,” or any localized equivalent, or by downloading, installing, accessing, or using the Service, you affirmatively accept and agree to be bound by this Privacy Policy. If you do not agree to the terms of this Policy, you may not access or use the Service. Do not install, launch, or use the Game unless you accept all of the terms and conditions contained in this Policy.

Last Updated: June 3, 2025 

©2025 Kluge Strategic, Inc.  Kluge Interactive, the Synth Riders and the Final Fury logos are trademarks of Kluge Strategic, Inc., in the U.S., and other countries. All rights reserved.