Offworld California Consumer Privacy Act (CCPA) Privacy Policy

Last updated: September 12, 2023

In this California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”), we, Offworld Industries Ltd. (“Offworld”, “we”, “us”, “our”), disclose information about our information practices as required by the California Consumer Privacy Act of 2018 and its regulations (“CCPA”). This CCPA Privacy Policy supplements the disclosures in our other privacy policies and only applies to you if you reside in California. This CCPA Privacy Policy does not reflect our processing of California residents’ personal information where an exception applies under the CCPA.

1. Our Personal Information Handling Practices over the Preceding 12 Months

We have set out below the categories of “personal information” and “sensitive personal information” (as defined by the CCPA) that we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected and the categories of third parties to whom we disclosed the personal information and the purposes of such disclosures. The table is followed by a description of the purposes for which we collected personal information.

A “consumer” refers to a California resident. A “user” refers to a user of our website www.offworldindustries.com (the “Website”) or other online services such as our games (collectively, the “Games”). A “business contact” refers to a representative of our prospective, current or past suppliers, customers or partners. An “employee” refers to a prospective, current or past employee, contractors or other personnel of ours. We did not “sell” or “share” personal information as the CCPA defines these terms over the preceding 12 months.

We used the personal information collected from users for the following purposes, where applicable:

- Users of our Website:

• complying with corporate financial and regulatory responsibilities, including audit requirements (both internal and external) and cost/budgeting procedures, which involves the processing of identification information, contact details, information about customers, and job applications;
• to facilitate potential or actual acquisitions, disposals, mergers, or joint ventures, including enabling due diligence to be conducted by potential buyers or joint venture partners, and negotiations to take place, and enabling a buyer to prepare to comply with their future obligations;
• complying with applicable laws, regulatory, and employment-related requirements along with the administration of those requirements, which involves the processing of identification information, contact details, information about employees and customers;
• responding to and complying with requests and legal demands from regulators or other authorities in or outside of the home country of users which involves the processing of personal information, contact information, information about our employees and customers;
• providing IT systems and support to customers, job applicants, and users of our Website, and to enable us to identify and resolve issues in our IT systems, and to keep our systems secure against privacy-related breaches or unauthorized accesses to, or disclosures of, personal information;
• monitoring and ensuring compliance with applicable policies and procedures and laws, including conducting internal investigations or cooperating with external investigations, which involves the processing of personal information;
• communicating with users, which involves the processing of identification information, contact details, information about  job applications of users, respond to  questions of users, or any forms submitted on our Website;
• tailoring our Website and web forms to  preferences of users, which involves tracking pages  visited by users, and requests  made by users on our Website.
• confirming the identity of users for the purpose of responding to user requests and making hiring decisions;
• marketing of our products and services to users, if they have consented to receive marketing or other communications in electronic form, such as newsletters, special offers and general information about our products and services; and
• facilitating and coordinating  access to and compatibility for other third party service providers that may host our products or services.

- Users of our Games:

• hosting and administering game servers (including game server hosting, if applicable) and enabling and moderating  gameplay of, and use of, Games including processing of applications to become server hosts of the Game (if applicable), providing feedback and information about gameplay and progress, allowing  connection to our servers and playing with other players, ensuring smooth gameplay experience;
• if applicable, administering and hosting forums for Games, which provides the opportunity to voluntarily disclose user personal information to others, but which may need to be monitored by us for any illicit activities, compliance with this Privacy Policy, other policies, or the terms of use that govern your use of our Game. Game forums allow players to communicate and disclose their personal information for the purpose of enhancing the experience of the Game, and to allow players to answers questions, strategize, or build a community with other players of the Game.

• to communicate with users including but not limited to responding to questions or concerns, sending notifications, updates and emails to users about the Game, soliciting feedback from users about the Game, sending users administrative information such as updates to this Policy, and sending users news and general information about the Game and any other of our similar games, unless users have opted not to receive such information;
• providing IT systems and support to any Player of the Game to enable us to identify and resolve issues in our IT systems, keep our systems secure against privacy-related breaches, unauthorized accesses to, or disclosures of, personal information, respond to user requests and questions and provide overall support to users on the Game;
• facilitating and coordinating your access to and compatibility for other third party service providers that may host our products or services, or perform various functions on our behalf in relation to the Game. We may, from time to time, provide or transfer  personal information of users to affiliated and non-affiliated third party service providers who support the Game or our business, and perform various functions on our behalf, including without limitation cloud service and data storage providers, maintenance service providers, customer service providers, data and web analytics service providers, and technical support providers for the purpose of enhancing our Game, user experience, or for general support;
• improving our marketing efforts and monitoring usage and other analytics to improve and enhance our Game, which may include providing or transferring user personal information to third party services providers that determine the effectiveness of our marketing campaigns relating to the Game, or monitor, track, analyse and report data relating to the use of the Game (e.g. Amplitude, Microsoft Playfab);
• compliance with our legal and regulatory obligations, such as if we are asked or required to disclose any of user personal information to a regulator, judicial authority, law enforcement agency or any other applicable authorities;
• facilitating potential or actual acquisitions, disposals, mergers, or joint ventures, including enabling due diligence to be conducted by potential buyers or joint venture partners, and negotiations to take place, and enabling a buyer to prepare to comply with future obligations.
• improving the Game in light of the feedback and opinions you may provide; and
• protecting each Player and Offworld against fraud, cheating and spams relating to the Game, or to help prevent the loss of life or serious injury of anyone or any Player of the Game, which may include providing or transferring user personal information to third party service providers that provide services such as cheat prevention tools and player account authentication (e.g. Easy Anti-Cheat/ Epic Online Services).

We used the personal information collected from business contacts for the following purposes: exploring business opportunities (such as licensing of third party technology), general business development and for internal business purposes.

We used the personal information collected from employees for the following purposes:

• complying with corporate financial and regulatory responsibilities, including audit requirements (both internal and external) and cost/budgeting procedures, which involves the processing of identification information, contact details, information about customers, and job applications;
• complying with applicable laws, regulatory, and employment-related requirements along with the administration of those requirements, which involves the processing of identification information, contact details, information about employees;
• responding to and complying with requests and legal demands from regulators or other authorities in or outside of your home country which involves the processing of personal information, contact information, information about employees;
• providing IT systems and support to customers, job applicants, and users of our Website, and to enable us to identify and resolve issues in our IT systems, and to keep our systems secure against privacy-related breaches or unauthorized accesses to, or disclosures of, personal information;
• communicating with prospective or existing employees, which involves the processing of identification information, contact details, information about  job applications, respond to questions or any forms submitted on our Website;
• confirming  the identity of prospective or existing employees for the purpose of responding to  requests and making hiring decisions;

We did not use any sensitive personal information about California residents to infer characteristics about them. We do not have actual knowledge that we “sell” or “share” the personal information of minors under 16 years of age.

2. CCPA Rights

As a California resident, you have the following rights under the CCPA, subject to the conditions in the CCPA:

• The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• The right to delete personal information that we have collected from you.
• The right to correct inaccurate personal information that we maintain about you.
• The right to opt-out of the sale or sharing of your personal information by us. We do not “sell” or “share” personal information, as the CCPA defines these terms.
• The right to limit our use and disclosure of sensitive personal information to purposes specified at Subsection 1798.121(a) of the CCPA. We did not use or disclose any sensitive personal information.
• The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

3. How to Exercise CCPA Rights or Contact Us

• Methods of Submission and Instructions: To submit a request to exercise your rights to know, delete or correct, please submit an email request to privacy@offworldindusties.com and include “California Request to [Know/Delete/Correct]” in the subject line. Clearly specify the nature of your request, including the personal information about you that you would like to know, the personal information about you that you would like to have deleted, or the personal information about you that you would like to have corrected.
• Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by taking the steps outlined under “Authorized Agent” further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfill your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.
• Opt-Out Signals: We do not “sell” or “share” personal information or use or disclose “sensitive personal information” and therefore do not process opt-out signals.
• Authorized Agents: You can designate an authorized agent to make a request under the CCPA on your behalf if:
• The authorized agent is a natural person or a business entity and the agent provides proof that you gave the agent signed permission to submit the request; and
• You directly confirm with us that you provided the authorized agent with permission to submit the request.
• If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

• Contact Information: If you have any questions about this CCPA Privacy Policy or if you want to exercise your privacy rights, please contact us at:

Privacy Officer, Offworld Industries Ltd

privacy@offworldindusties.com