Privacy Policy

A summary of this document, written for young people, is available here.

Version 1.0

Date: 27 Feb 2024

HERE ARE THE KEY FACTS:

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

• visit Our websites;

• access Our mobile platform;

• access Our published games from streaming services via your social networks ID; or

• access any of Our products and services

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Who are We?

We are a UK videogames developer and publisher called Jagex. Our address is 220 Cambridge Science Park, Cambridge, England, CB4 0WA. You can contact Us at [e-mail]

You can always:

• ask Us for a copy of the information We have about you;

• ask Us to update the information We have about you;

• ask Us to delete the information We have about you; or

• ask Us questions about how We use your information.

Please click on the links below to find out more about each topic below:

Table of contents

1. PURPOSE OF THIS PRIVACY POLICY

2. CONTACT DETAILS

3. YOUR DUTY TO INFORM US OF CHANGES

4. THIRD-PARTY LINKS

5. THE DATA WE COLLECT ABOUT YOU

6. LEGAL BASIS FOR PROCESSING

7. HOW WE COLLECT YOUR DATA

8. HOW WE USE YOUR PERSONAL DATA

9. DISCLOSURE OF YOUR PERSONAL DATA

10. INTERNATIONAL TRANSFERS

11. DATA SECURITY

12. DATA RETENTION

13. YOUR LEGAL RIGHTS

14. ADDITIONAL INFORMATION FOR NON-UK AND NON-EU RESIDENTS

    • BRAZIL

    • USA

15. POLICY UPDATES

1.0 PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to inform you how We collect and process your Personal Data. It is important that you read this privacy policy to fully understand how and why We are using your data.

Jagex Limited, or the applicable group company named below, acts as the Controller and is responsible for your Personal Data (collectively referred to as "Company", "We", "Us", or "Our" in this privacy policy).

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

• "Comply With A Legal Obligation" means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that We are subject to;

• "Controller" means the organisation that exercises overall control over the purposes and means of processing Personal Data;

• "Data Protection Laws" means the UK Data Protection Act 2018 and all other globally applicable legislation relating to privacy or data protection (including the EU General Data Protection Regulation, the California Consumer Privacy Act and the Brazil Lei Geral de Proteção de Dados Pessoais);

• "Explicit Consent" for external marketing means your Personal Data will not be disclosed to any third party unless you have given your explicit consent to such disclosure;

• "Legitimate Interest" means the interest of Our business in conducting and managing Our business to enable Us to give you the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your Personal Data for Our legitimate interests. We do not use your Personal Data for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on you in respect of specific activities by contacting Us;

• "Performance of Contract" or "Contractual Necessity" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;

• "Personal Data" means any information relating to natural persons who can be identified or who are identifiable directly from the information in question; or who can be indirectly identified from that information in combination with other information; and

• "Special Category" or "Special Categories" of Personal Data means: (a) Personal Data revealing racial or ethnic origin; (b) Personal Data revealing political opinions; (c) Personal Data revealing religious or philosophical beliefs; (d) Personal Data revealing trade union membership; (e) genetic data; (f) biometric data (where used for identification purposes); (g) data concerning health; (h) data concerning a person's sex life; and (i) data concerning a person's sexual orientation.

2.0 CONTACT DETAILS

Jagex

• Full name of legal entity (Controller): Jagex Limited

• Registered Office Address: 220 Cambridge Science Park, Cambridge, England, CB4 0WA

• Name of appointed Data Protection Officer: Pembroke Privacy Limited

• DPO Email address [e-mail]

Pipeworks

• Full name of legal entity (Controller): Pipeworks Inc.

• Registered Office Address: 133 W. Broadway, Eugene, Oregon 97401, USA

• Name of appointed Data Protection Officer: Pembroke Privacy Limited

• DPO Email address: [e-mail]

Gamepires

• Full name of legal entity (Controller): Gamepires d.o.o

• Registered Office Address: Slavonska Avenija 6A, Zagreb, Croatia.

• Name of appointed Data Protection Officer: Pembroke Privacy Limited

• DPO Email address: [e-mail]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: [phone] (local rate) or 01625 545 745 if you prefer to use a national rate number Fax: [phone] Live Chat Link

If you're a customer within the EU, you can file a complaint to your local member state data protection authority listed here.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or local DPA, so please get in touch with Us in the first instance.

3.0 YOUR DUTY TO INFORM US OF CHANGES

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

4.0 THIRD-PARTY LINKS

This website includes links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our website, We encourage you to read the privacy policy of every website you visit.

5.0 THE DATA WE COLLECT ABOUT YOU

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

• Identity Data includes but is not limited to first name, last name, username or similar identifier, title, and date of birth;

• Contact Data includes postal address, email address and telephone numbers;

• Financial Data includes bank account, payment card details, and payroll data;

• Marketing and Communications Data include your preferences in receiving marketing from Us and Our third parties and your communication preferences.

• Profile Data information including your username and password, interests, preferences, records of your correspondence and engagement with Us and feedback and survey responses;

• Technical Data commonly known as online identifiers and includes internet protocol (IP) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI), type of device, your login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from Us;

• Usage Data includes information about how you use Our website, mobile platforms, products, and services;

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

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

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

We use mobile analytics software to allow Us to understand better the functionality of Our mobile software on your device. This software records information such as how often you play Our games, the events that occur within the games, aggregated usage, performance data, and where the games were downloaded from. We do not link the information We store within the analytics software to any personal information you submit within the games.

SOCIAL GAMING PLATFORMS

(A) GAME PUBLISHING PLATFORMS

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

(B) MOBILE PLATFORMS

If you play Our games on your mobile device or tablet, We receive information about you from the IOS or Android app stores and other mobile platform providers. This information includes your username or device ID but does not include any financial information. Some of Our mobile platforms send information to Us that you authorise them to provide. We will only retain your data for as long as your account is linked to your Jagex Account.

(C) SOCIAL NETWORK LINKED ACCOUNTS

When you link your social network account via Google, Facebook, or Apple to play Our games on Our mobile platform or website, We receive information about you from your social network provider. This information includes your name, email address, language preference, and profile picture. We will only retain your data for as long as your account is linked to your Jagex Account.

(D) JAGEX AS A PUBLISHER

Where We enter into publishing arrangements with game development studios to publish their games on gaming platforms, both developer and publisher (Jagex) will process Personal Data and operate as separate controllers. Titles falling under these arrangements can be seen here. We advise you to read both this privacy policy and the privacy policy on the developer studio website.

IF YOU FAIL TO PROVIDE PERSONAL DATA

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

6.0 LEGAL BASIS FOR PROCESSING

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

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

• Consent when placing cookies on your device on the web (through Our cookie consent manager) to send you email marketing or to deliver third-party targeted advertising to you on Our services;

• Our Legitimate Interests to process your information when providing you with customer service support, to serve targeted marketing of Our services (where you have subscribed for an account with Us or purchased goods or services from Us and you have not opted out of receiving that marketing), for fraud prevention and security purposes; and

• Contractual Necessity to process information when you create a Jagex Account to enable Us to provide you with Our services.

7.0 HOW WE COLLECT YOUR DATA

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

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

• purchase Our products or services;

• create an account on Our website, or via Our mobile app or play Our games;

• link your social account to your Jagex Account;

• subscribe to Our service or publications;

• request marketing to be sent to you;

• request support for Our products;

• enter a competition, promotion, or survey; or

• give Us some feedback.

Automated technologies or interactions. As you interact with Our website, We automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing Our cookies. Please see Our Cookie Policy for further details.

Third parties or publicly available sources. We receive Personal Data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:

  • analytics providers such as Google based inside AND outside the UK and the EU.

  • advertising networks such as Facebook based inside AND outside the UK and the EU, and

  • search information providers such as Google based inside AND outside the UK and the EU.

• Contact and Transaction Data from providers of technical, payment and delivery services based inside AND outside the UK and the EU.

• Identity and Contact Data from data brokers or aggregators based inside AND outside the UK and the EU.

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK and the EU.

8.0 HOW WE USE YOUR PERSONAL DATA

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

• for the Performance of a Contract that We are about to enter into or have entered into with you;

• where it is necessary for Our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests;

• where We need to Comply With A Legal Obligation; or.

• where We have your Explicit Consent.

Generally, We do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting Us using the details at section 2 (Contact Details). The withdrawal of consent will not affect the lawfulness of any processing that took place before the withdrawal.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways We may use your Personal Data, and which of the legal bases We rely on to do so. We have also identified what Our Legitimate Interests are where appropriate.

Note that We may process your Personal Data for more than one lawful ground depending on the specific purpose for which We are using your data.

Purpose/Activity	Type of data	Lawful basis for processing including basis of Legitimate Interest
To register you as a new customer	Identity Contact Technical Profile Usage	Performance of a Contract with you
To process and deliver your order including: Manage payments, fees and charges Obtain consent for marketing activities performed by third parties	Identity Contact Transaction Marketing and Communications	Performance of a Contract with you Explicit Consent
To manage Our relationship with you which will include: Notifying you about changes to Our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a Contract with you Necessary to Comply With a Legal Obligation Necessary for Our Legitimate Interests (to keep Our records updated and to study how customers use Our products/services)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a Contract with you Necessary for Our Legitimate Interests (to study how customers use Our products/services, to develop them and grow Our business)
To administer and protect Our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical Transaction Usage Profile Data	Performance of Contract Necessary for Our Legitimate Interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to Comply With a Legal Obligation Necessary for Our Legitimate Interests to detect or prevent unlawful acts
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Explicit Consent where cookies, beacon technology, or similar software is used. In all other cases necessary for Our Legitimate Interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy)
To use data analytics to improve Our website, products/services, marketing, customer relationships and experiences	Technical Usage Marketing and Communications Profile	Explicit Consent where cookies, beacon technology, or similar software is used. in all other cases necessary for Our Legitimate Interests (to define types of customers for Our products and services, to keep Our website updated and relevant, to develop Our business and to inform Our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Explicit Consent where cookies, beacon technology, or similar software is used. In all others cases necessary for Our Legitimate Interests (to develop Our products/services and grow Our business)
To ask you to take part in research to improve Our game platform	Identity Contact Transaction Technical Profile Usage	Necessary for Our Legitimate Interests (to develop Our products/services and grow Our business)
To process your job application to work with Us	Identity Contact	Performance of a Contract with you
To facilitate a duty of care to you	Identity Contact Transaction Profile Usage	Necessary for Our Legitimate Interest (to help you manage aspects of your activities when interacting with Our products/services)

MARKETING

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

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

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

THIRD-PARTY MARKETING

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

OPTING OUT OF MARKETING

You can ask Us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting Us at any time using the details at section 2 (Contact Details).

OPTING OUT OF ADVERTISING ID

The Identifier For Advertising (IDFA) is a unique, user-resettable ID for advertising, provided by the mobile device's operating system. We may use this ID to enhance serving and targeting capabilities, re-target specific campaigns, or pass the ID to Our partners. Advertising ID does not reveal any information about the user or the device. If you prefer to opt-out or reset your IDFA, please follow these standard instructions:

• iOS - Opt out of interest-based ads in the App Store and Apple News

• Android - Opt out of seeing personalized ads

OPTING OUT OF THIRD-PARTY TAILORED ADVERTISING

We use marketing services to advertise to you after you have accessed or visited Our services. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize your Device and understand how you use Our services so that We can improve Our services to reflect your interests and serve you advertisements that are likely to be of more interest to you.

These third-party vendors collect, store, use, process, and transfer information about your activity on our services in accordance with their Privacy Policies and to enable Us to:

• measure and analyze traffic and browsing activity on Our services;

• show advertisements for Our products or services to you on third-party websites or apps; and

• measure and analyze the performance of Our advertising campaigns.

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

• The Network Advertising Initiative's opt-out platform: http://www.networkadvertising.org/choices/

• The European Interactive Digital Advertising Alliance's opt-out platform: https://youronlinechoices.eu/

• The Digital Advertising Alliance's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on your mobile device such as Limit Ad Tracking (iOS) and opt Out of Ads Personalization (Android). See your mobile device help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our services with these third-party vendors. This allows Our third-party vendors to recognize and deliver you ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the privacy policy of each vendor listed below. The third-party vendors We use are:

• Google Ads (AdWords) remarketing services is provided by Google Inc.

  • You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

  • Google also recommends installing the Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

• Facebook remarketing services is provided by Facebook Inc.

  • You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266. To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

  • Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

OPTING OUT OF GEOLOCATION

If you have previously allowed Us to access your geolocation data, you can stop making geolocation available to Us by visiting your mobile device's settings for the games or the "settings" page for the games.

OPTING OUT OF OTHER COMMUNICATIONS

When you install Our games on your mobile device you can choose to receive push notifications, which are messages Our games send you on your mobile device even when the game is not on. You can turn off notifications by visiting your mobile device's "settings" page.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie Policy.

CHANGE OF PURPOSE

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

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

9.0 DISCLOSURE OF YOUR PERSONAL DATA

We may share your Personal Data with third parties set out below for the purposes set out in the table in section 8 (How We Use Your Personal Data) above:

• Specific marketing partners listed here.

• We may seek to acquire other businesses or merge with them or Our business or part of Our business may be sold. If a change happens to Our business, then your Personal Data may be disclosed to Our advisers and those of any prospective purchaser or partner, and the new owners or partners may use your Personal Data in the same way as set out in this privacy policy. Your data will only be disclosed for the purposes identified in this privacy policy (as may be updated from time to time) unless a law or regulation specifically allows or requires otherwise. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow Our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with Our instructions. All Our third-party processing partners are vetted under Our third-party due diligence process and have signed data processor contracts with Us.

10.0 INTERNATIONAL TRANSFERS

Some of Our external third parties are based outside the UK and the European Economic Area (EEA), so their processing of your Personal Data will involve a transfer of data outside the UK and the EEA.

External Party Category	Transfer Purpose	Lawful Basis
a) Technical partner	a) Provide technical processing services	a) Contract
b) Marketing partner	b) Provide marketing services	b) Consent

Whenever We transfer your Personal Data out of the UK and the EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries deemed to provide an adequate level of protection for Personal Data by the UK Secretary of State or the European Commission (as appropriate);

• appropriate safeguards are in place in accordance with Data Protection Laws . These safeguards include the use of standard contractual clauses/ data protection clauses approved by the UK Secretary of State or the European Commission (as appropriate) or binding corporate rules; or

• the transfer is otherwise allowed under Data Protection Laws (including where We have your consent or the transfer is necessary for the Performance of a Contract with you).

11.0 DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, disclosed or being unavailable. In addition, We limit access to your Personal Data to those employees, agents, professional advisers, contractors, and other third parties who have a business need to know on the principle of least privilege (PoLP). They will only process your Personal Data on Our instructions, and they are subject to a duty of confidentiality. We periodically review all privacy and security policies and update them when necessary, in line with changes in Data Protection Laws or when new technologies are introduced into Our business.

Where the introduction of new technologies results in a high risk to your Personal Data, We will perform a data protection impact assessment and will only proceed if We are able to mitigate any identified high risks. Methods of collecting Personal Data are reviewed by management before they are implemented to confirm that Personal Data is obtained:

a) fairly, without intimidation or deception, and

b) lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to the collection of Personal Data.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.

12.0 DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your Personal Data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. A copy of Our Data Retention Schedule is available upon request.

To determine the appropriate retention period for Personal Data, We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which We process your Personal Data and whether We can achieve those purposes through other means, and the applicable legal requirements.

By law, We have to keep basic information about Our customers (including Contact, Identity, Financial and Transaction Data) for six tax years plus the current tax year as part of Our legal obligations to do so. In some circumstances, you can ask Us to delete your data: see Request erasure below for further information.

In some circumstances, We may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

DATA DISPOSAL

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

13.0 YOUR LEGAL RIGHTS

Under certain global Data Protection Laws (including UK and EU Data Protection Laws) and under certain circumstances, you have rights in relation to your Personal Data. We set out below a brief description of such rights:

• To be informed : Individuals have the right to be informed about the collection and use of their Personal Data. This is a key transparency requirement under UK and EU Data Protection Laws. This privacy policy and Our cookie policy meet this requirement.

• Request access to your Personal Data (commonly known as a "data subject access request"): This enables you to receive a copy of the Personal Data We hold about you subject to certain exemptions.

• Request rectification of your Personal Data : This enables you to have any incomplete or inaccurate data We hold about you corrected, though We may need to verify the accuracy of the new data you provide.

• Request erasure of your Personal Data : This enables you to ask Us to delete or remove Personal Data where there is no good reason for Us to continue to process it. You also have the right to ask Us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where We may have processed your Personal Data unlawfully or where We have a legal obligation to erase your Personal Data. Note, however, that the right to request erasure is not absolute, and there are circumstances where We do not need to comply with the request, which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Data : This enables you to object to processing where We are relying on Our Legitimate Interest (or those of a third party) to process your Personal Data or where We are processing your Personal Data for scientific or historical research or statistical purposes. We do not need to stop processing if We can give strong and legitimate reasons to continue processing your Personal Data. You also have the right to object where We are processing your Personal Data for direct marketing purposes. This is an absolute right but does not automatically mean that We need to erase all of your Personal Data, and in particular, We may put your details on a suppression list to ensure We don't send you direct marketing in the future.

• Request restriction of processing your Personal Data : This enables you to ask Us to suspend the processing of your Personal Data in certain scenarios, including (a) if you want Us to establish the data's accuracy; or (b) you have objected to Our use of your data, but We need to verify whether We have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to you or a third party : We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to Personal Data you have provided to Us, which you initially provided consent for Us to use or where We used the Personal Data to perform, or take steps prior to performing, a contract with you and where the processing is automated.

• Withdraw consent at any time where We are relying on consent to process your Personal Data : However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case when you withdraw your consent.

Please note that the above rights are not all absolute and are subject to applicable Data Protection Laws and may be subject to conditions and provisions set out in applicable Data Protection Laws. For further information or if you wish to exercise any of the rights set out above, please get in touch with Us.

NO FEE IS USUALLY REQUIRED

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, We may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help Us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if your request is particularly complex or you have made a number of requests, in which case We will inform you of an extension period of up to 2 months. In this case, We will keep you informed on progress.

14.0 ADDITIONAL INFORMATION FOR NON-UK AND NON-EU RESIDENTS

Brazil

YOUR RIGHTS

The Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais or LGPD) was passed by the National Congress of Brazil on 14 August 2018 and came into effect on 15 August 2020. The information set out in this section only applies to the processing of the Personal Data of individuals in Brazil.

RIGHT OF CONFIRMATION OF THE EXISTENCE OF THE PROCESSING OF YOUR DATA

You may request confirmation of the processing of your data.

• RIGHT TO ACCESS Users have the right to access their data being processed by Us by completing a data subject access form. Users have the right to be informed about the origin of the data, the purpose of the processing and the existence of any records.

• DATA PORTABILITY You have a right to the portability of your data to another service or product provider, upon express request, in accordance with the regulations of the national authority and subject to commercial and industrial secrets and any data which has been anonymised.

• RECTIFICATION You have the right to have your Personal Data rectified if it is inaccurate, outdated, or incomplete.

• ANONYMISATION You are entitled to request the anonymisation, blocking or elimination of unnecessary or excessive Personal Data or of any data that is not being processed in compliance with LGPD.

• DELETION You have the right to have your Personal Data deleted if the data is unnecessary or excessive or if the processing of that data was based on consent.

• INFORMATION You have the right to be informed about the duration of the processing of your data, the specific purpose of the processing, the sub-processors and other third parties that access or process your Personal Data. You also have the right to be informed about your consent choices and the consequences of refusing consent.

• REVOCATION OF CONSENT You have the right to revoke or withdraw consent.

• BRING A COMPLAINT You will have the right to lodge a complaint with the ANPD (the National Data Protection Authority).

• OBJECT You have the right to oppose the processing of your Personal Data where there is non-compliance with the provisions of the law or if you revoke your consent, as above.

• REQUEST REVIEW You have the right to request the review of decisions made solely on the basis of automated processing of Personal Data which affect your interests. If you wish to action any of the above requests, please email Us at [e-mail].

Please note that not all of the above rights are absolute. You will not be discriminated against or suffer any sort of detriment if you exercise any of your rights.

USA

This section should be read together with the rest of Our general privacy policy. All defined terms have the same meaning as in the rest of Our general privacy policy.

OUR SERVICES

Description of the Services

• Websites

  • Web content and solution for personalized games, educational and entertainment content, etc.

• Mobile platforms

  • Customized mobile platforms that provide you with access to the published games.

• Published games

  • Game publishing platforms that provide you, via your social networks ID, various of published games that are made available to you from streaming services, such as Valve (Steam), Apple (iOS), and Google (Android).

CATEGORIES OF PERSONAL INFORMATION

In this section, the terms "Personal Information" or "Personal Data" refer to information that identifies an individual or relates to an identifiable individual or as otherwise defined under US Privacy Laws, including –

• the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020;

• the Virginia Consumer Data Protection Act of 2021;

• the Colorado Privacy Act of 2021;

• the Connecticut Data Privacy Act of 2022;

• the Utah Consumer Privacy Act of 2023;

• the Nevada Revised Statutes Chapter 603A entitled Security and Privacy of Personal Information of 2021; and their implementing regulations, as further amended from time to time (together "US Privacy Laws").

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Information which We may collect or may have been collected from US residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the US Privacy Laws:

• Identifiers: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, date of birth or other similar identifiers;

• Personal information categories applicable to the processing: name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

• Commercial information: records and history of products or services purchased or considered; and

• Internet or other similar network activity: Interaction with Our services or advertisement.

This does not mean that all examples of that category of Personal Information were in fact collected by Us but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if You provided such Personal Information directly to Us.

CATEGORIES OF SENSITIVE PERSONAL INFORMATION

Sensitive personal information

• Account Login Data: information used for accessing your account.

• Financial Data: bank account, payment card details, and payroll data.

• Transaction Data: details about payments to and from you and other details of products and services you have purchased from Us.

SOURCES OF PERSONAL INFORMATION

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from the forms you complete on Our services, preferences you express or provide through Our services, or from your purchases on Our services.

• Indirectly from you. For example, from observing your activity on Our services.

• Automatically from you. For example, through cookies We or Our service providers set on your Device as you navigate through Our services.

• From service providers. For example, third-party vendors to monitor and analyze the use of Our services, third-party vendors to deliver targeted advertising to you, third-party vendors for payment processing, or other third-party vendors that We use to provide the services to you.

USE OF PERSONAL INFORMATION

We may use or disclose Personal Information We collect for business purposes or commercial purposes, which may include the following examples:

• To provide and maintain Our services: including to monitor the usage of Our services.

• To manage your Account: to manage your registration as a user of the services. The Personal Information you provide can give you access to different functionalities of the services that are available to you as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with Us through the services.

• To contact you: to contact you by email, telephone calls, SMS, push, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide you with news, special offers and general information: about other goods, services, and events which We offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

• To manage your requests: to attend and manage your requests to Us.

• To deliver targeted advertising to you. We may use Personal Information related to you to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.

• For business transfers: to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Us about Our services users is among the assets transferred.

• For other purposes: data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and evaluating and improving Our services, products, marketing, and your experience.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• For internal administrative and auditing purposes.

• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

CHILDREN'S PRIVACY

If you are under the age of 13, you are not allowed to use Our services.

We do not knowingly collect Personal Information from minors under the age of 16 through Our services, although certain third-party websites that We link to may do so.

These third-party websites have their own terms of use and privacy policies, and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

If you have reason to believe that a child under the age of 13 has provided Us with Personal Information, please contact Us with sufficient detail to enable Us to delete that information.

DISCLOSURE, SALE, AND SHARING OF PERSONAL INFORMATION

Disclosure and Sharing of Personal Information

We may use, share, or disclose Personal Information related to you, and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes: identifiers; Personal Information categories applicable to the processing; commercial information; or internet or other similar network activity.

When We disclose Personal Information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

We do not sell Personal Information as the term sell is commonly understood. We do allow services providers to use Personal Information related to you for the business purposes described in Our general privacy policy, for activities such as advertising, marketing, and analytics.

We may sell and may have sold in the last twelve (12) months the following categories of Personal Information: identifiers; Personal Information categories applicable to the processing; commercial information; or internet or other similar network activity.

At any time, you can opt-out of the collection of Personal Information by Our service providers by contacting Us or visiting the "do not sell my personal information" page, available at: https://support.runescape.com/hc/en-gb/articles/360001370829 .

RETENTION OF PERSONAL INFORMATION

We retain Personal Information related to you for the length of time required for Us to achieve the purposes defined in this section, and as further detailed in the rest of Our privacy policy.

YOUR RIGHTS AND CHOICES

US State Data Protection Laws provide residents of certain states with specific rights regarding their personal information. If you are a resident of the US, US State Data Protection Laws may grant some or all of the rights set out below.

• The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.

• The right to know/access. You have the right to request that We disclose information to you about Our collection, use, sale, disclosure for business purposes and share of Personal Information. Once We receive and confirm your request, We will disclose to you:

  • The categories of Personal Information We collected about you.

  • The categories of sources for the Personal Information We collected about you.

  • Our business or commercial purposes for collecting or selling that Personal Information.

  • The categories of third parties with whom We share that Personal Information.

  • The specific pieces of Personal Information We collected about you.

  • If We sold Personal Information related to you or disclosed Personal Information related to you for a business purpose, We will disclose to you the categories of Personal Information categories sold or disclosed.

• The right to say no to the sale or sharing of Personal information (opt-out). You have the right to direct Us to not sell Personal Information related to you. To submit an opt-out request, please see the "Sale of Personal Information" section or contact Us.

• The right to correct Personal information. You have the right to correct or rectify any inaccurate Personal Information about you that We collected. Once We receive and confirm your request, We will use commercially reasonable efforts to correct (and direct Our service providers to correct) Personal Information related to you, unless an exception applies.

• The right to limit use and disclosure of sensitive Personal information. Jagex does not use or disclose Sensitive Personal Information for purposes that, under applicable law, require Us to offer consumers a "Right to Limit" the use or disclosure of Sensitive Personal Information.

• The right to delete Personal information. You have the right to request the deletion of Personal Information related to you under certain circumstances, subject to certain exceptions. Once We receive and confirm your request, We will delete (and direct Our services providers to delete) Personal Information related to you from Our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for Us or Our services providers to:

  • Complete the transaction for which We collected the Personal Information, provide a good or services that you requested, take actions reasonably anticipated within the context of Our ongoing business relationship with you, or otherwise perform Our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the relevant US State Data Protection Law applicable to the processing under this section.

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

  • Denying goods or services to you.

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.

  • Providing a different level or quality of goods or services to you.

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Rights

To submit a verifiable request to exercise any of your rights (including your right to opt out of the sale of your Personal Information) please click here: https://support.runescape.com/hc/en-gb/articles/360001370829 .

Only you, or a person registered with the competent Secretary of State that you authorize to act on your behalf, may make a verifiable request related to Personal Information related to you.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify you are the person about whom We collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the required information if We cannot:

• verify your identity or authority to make the request; and

• confirm that the personal information relates to you.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Personal Information related to you that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

15.0 POLICY UPDATES

Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least annually, and whenever changes to such laws and regulations are made, privacy policies and procedures are revised to conform with the requirements of applicable laws and regulations.

END OF POLICY