SORA STREAM PRIVACY POLICY

The Sora Stream Platform is owned and managed by Ludium Lab, SL with registered address at C/Llauder 1, Entlo 1 08003 Barcelona, Spain. You can contact our Data Protection Officer via email to privacy@sorastream.com.

1. Introduction

At Sora Stream we want to provide you with the best possible experience to ensure that you enjoy our service today, tomorrow and in the future. In order to do so, we need to know your gaming habits, so that we can offer you an exceptional and personalized service.

To use Sora Stream you need a proper internet connection. Sora Stream is always improving and may release updates without notice. You may need to update the App or third-party software (e.g browser) from time to time in order to use Sora Stream. In general, multiplayer and online games could be more affected by the network connection compared to single and offline games. Currently, Sora Stream is available in Europe so we cannot guarantee the proper experience outside our area. Also, as a consequence of the location, the functionality and experience more or less seamlessly, user digital environment, network conditions,hardware, software etc. could be different, considering in any case that should comply with the requirements set specified in our FAQs.

Having said that, the privacy and security of your personal data is of great importance to us. For this reason, we want to clearly explain how and why we collect, store, share and use your personal data, and show you the controls and options available for you to choose when and how you share your personal data.

That is our goal and we will explain it in more detail in this Privacy Policy ("Policy").

2. About this Policy

This Policy provides essential information regarding the use that Ludium Lab, S.L (owner of the Sora Stream platform, hereinafter "SoraStream") makes of your personal data. The Policy applies to all SoraStream services and associated services (hereinafter the "SoraStream Service"). The terms governing the use of the SoraStream Service are defined in our Terms of Use and EULA.

Regularly, we may develop new services or offer additional services. If the introduction of these new or additional services generates any kind of change in the way we collect or process your personal data, we will provide you with more information and additional conditions or policies. Unless otherwise indicated, when these new or additional services are introduced, they will be subject to this Policy.

The main goal of this Policy is:

1. Ensure that you understand what personal data we collect about you, the reasons why we do so, and with whom we share it;
2. Explain the way in which we use the personal data that you share with us in order to control, manage and ensure the functionality of the Sorastream Service when you use it; and
3. Explain your rights and options regarding the personal data we collect and process about you and how we will protect your privacy.

We hope this helps to understand our commitment to your privacy.

If you have any questions or comments related to the processing of your data, you can send an email to privacy@sorastream.com. If you do not agree with the content of this Policy, remember that you decide if you want to use the SoraStream Service.

In case SoraStream detects Prohibited Activities (Section 13) or any violation of the Terms specify in our documents, SoraStream can terminate your account with no refund of any subscription and we shall not be liable for any loss or damage to you or any third party arising out of such termination.

3. Your rights and preferences: options and control

As you may already know, the new European Union regulation known as the General Data Protection Regulation ("GDPR") gives people certain rights related to their personal data. The rights granted to people are:

• Right of access: the right to be informed and request access to the personal data we process;
• Right to rectification: the right to request that we correct or update your personal data, when they are inaccurate or incomplete;
• Right to erasure: the right to request that your personal data be deleted;
• Right to restriction of processing: the right to request that the processing of all or some of your personal data be temporarily or permanently stopped;

• Right of opposition:

  • the right, at any time, to object to the processing of your personal data for reasons related to your particular situation;
  • the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit such data for use in the service of a third party;
• Right not to be subject to automated individual decision-making: the right not to be subject to decisions based solely on automated decision-making, including profiling, when the decision may have a legal effect on you or produce a similar significant effect.
• Right to revoke at any time the consent granted through the Privacy Settings panel.

In order to allow you to easily exercise these rights and record your preferences regarding how SoraStream uses your personal data, we will provide you with access to the following settings through the Account Settings page:

• Privacy settings: it allows you to control some of the categories of personal data that we process and it allows you to access your personal data, change your avatar, as well as consent or revoke your consent regarding the commercial communications that you may receive from SoraStream.

You can contact Ludium Lab, S.L (Sora Stream) at Llauder 1, Entlo 1 08003 Barcelona, Spain or you can contact us through privacy@sorastream.com, Ref: Data Protection, to exercise your rights. You must indicate the rights you want to exercise and prove your identity as an applicant when appropriate. Likewise, we inform you that you have the right to file a claim before the Spanish Data Protection Agency if you consider that there has been some type of violation in relation to the processing of your personal data.

We may occasionally send you emails for marketing reasons related to SoraStream. Here are the fundamental conditions for sending these messages:Email content remains relevant, solely concerning SoraStream and its associated services.

Your consent for email communication is obtained when agreeing to our Terms of Service.

You have the option to opt-out by sending an email to support@sorastream.com or reaching out to our support chat.

The user have the option to terminate their SoraStream user account and discontinue its usage without providing any explanation or notice.

4. How do we collect your personal data?

We collect your personal data as follows:

1. Checking in to SoraStream Service: When you register to create an account in the SoraStream Service, we collect certain personal data so you can use the SoraStream Service, such as an email and, afterwards, an username (alias) and coarse birth date (i.e. month and year). In those plans that require payment for their use, the data regarding the payment method is also collected and, therefore, the payment platform that uses the SoraStream Service ensures its correct protection.
2. Use of the SoraStream Service: when you use the SoraStream Service, we collect personal data about the use of the SoraStream Service, such as what games you have played, when you have done it and how long have you been playing each one, as well as what games have been selected as favorites from the SoraStream Service catalog. Each game has a classification of the minimum age that the user must be to be able to access and play the game. This classification is determined by the official classification, known as Pan European Game Information (“PEGI”), which establishes the appropriate minimum age to play video games according to their category. The PEGI has the purpose of guiding the consumer about the suitability of playing a specific game through the minimum age recommended by the PEGI. Therefore, when collecting data about the games the user plays, we can also collect PEGI data.
3. Collect personal data that allows us to provide you with additional features / functionalities: from time to time, we also offer you the possibility to provide us with additional personal data or to give us your permission to collect it; for instance, to provide you with more features or functionality.

We use anonymous and additional information for purposes that include testing our computer systems, research, data analysis, marketing and promotion modeling, improving the SoraStream Service, and developing new functionality and features within the SoraStream Service. However, since the data is anonymised, it dissociates itself from the person who owns the data, preventing its identification.

5. How and what personal data do we collect from you?

We have established in the tables below the categories of personal data that we collect and use about you:

Personal data collected when you register with the SoraStream Service

Personal data collected through your use of the SoraStream Service

Personal data collected with your consent to enable us to provide you with additional features or functionality

6. For what purpose do we use your personal data?

When you use or interact with the SoraStream Service, we use different technologies to process your personal data for various reasons. The following table shows the purposes of the processing of your personal data, the associated legal bases which allows us to process your personal data, and the categories of personal data (identified in section 5 " How and what personal data do we collect from you?") used for the following purposes:

7. Shared use of your personal data

This Section introduces the different categories of the recipients of the personal data collected or generated through your use of the SoraStream Service.

Publicly available information

The following personal data will always be publicly available on the SoraStream Service: Avatar and username that will be shared with other SoraStream users who use the service.

Information that we can share

8. Data retention and erasure

We retain your personal data only for the time necessary to provide the SoraStream Service and for legitimate and essential business purposes, such as maintaining the performance of the SoraStream Service, making data-driven business decisions about new features and offerings, complying with our legal obligations and resolving disputes. We retain some of your personal data while you are a user of the SoraStream Service.

Upon request, we may delete or anonymize your personal data so that you are not identified, unless, we can or are legally required to retain certain personal data, including the following cases:

• If there is an unresolved issue related to your account, such as pending payments on your account or an unresolved claim or dispute, we will retain the necessary personal data until such issue is resolved;
• When we are obliged to retain personal data to comply with our legal, tax, accounting and auditing obligations, we will keep the necessary personal data for the period required by applicable law; and/or
• When necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

9. Transfer to other countries

SoraStream does not share your personal data with other companies located outside the territory of the EU.

10. Links

SoraStream is a cloud and content provider, so you can only run the games that you already own or others that are not owned by the user. The user will not be able to run some games on SoraStream if they have not bought it from the official distributor. When the user run a third party game on SoraStream, the user must comply with all aplicable third party rules related to the use of this game. E.g you may be obliged to buy a game or a Publisher’s or retailer’s website and créate an account on a gaming platform such as Epic, Steam etc.

Prior to purchasing the SoraStream subscription, kindly review the catalog of available video games. Regrettably, refunds cannot be granted on the grounds that a specific game is unavailable after purchase.

From SoraStream, we do our best to update the games available on the platform including the games that make updates, but sometimes it may take us some time and we cannot guarantee that is always running the latest version of the game.

As we are a cloud and content provider, we cannot guarantee that a game can be unavailable at any time without notification.

Sometimes in case a game it is available in different platforms/stores, SoraStream cannot guarantee the availability of that game in both stores/platforms. In case of these games also, the user has to comply with the rules related to their content and intellectual property rules.

We may display third party advertisements and other content linked to third party websites. We cannot control or be responsible for the privacy practices and content of third parties. If you click on a third-party advertisement or link, you understand that you are leaving the SoraStream Service and any personal information you provide will not be covered by this Policy. Please read the privacy policies of the third parties responsible for the website you access to find out how they collect and process your personal data.

11. Protection of your personal data

We are committed to protect the personal data of our users. We implement the appropriate technical and organizational measures to help protect the security of your personal data. However, keep in mind that no system is completely secure. We have implemented various policies including pseudonymization, encryption, access and retention policies to protect against unauthorized access and unnecessary retention of personal data on our systems.

The password protects your user account, so we recommend that you use a unique and firm password, to limit access to your computer and browser, and log out after using the SoraStream Service.

Upon your request, we might access your SoraStream user account for technical upkeep and assistance. This access will not occur unless you explicitly request it or provide clear consent. For the context of this clause, "Consent" refers to your unambiguous request or positive affirmation if asked for permission to access your account

12. Conditions applicable to child's consent in relation to Soras Stream services

Pursuant to the GDPR the processing of a child's personal data is lawful when the child is at least 16 years old. If the child is under 16 years of age, such process shall only be considered lawful if and only to the extent that consent was given or authorized by the holder of parental authority or guardianship over the child. Member States may provide by law for a lower age for such purposes, provided that it is not less than 13 years. In the case of Spain it is set at 14 years. SoraStream will make reasonable efforts to verify that consent was given or authorized by the holder of parental or guardianship over the child, taking into account available technology. In case you have any doubt or comment regarding SoraStream's parental control process or you want to inform us about any aspect related to a child, you can do it by email (using the email privacy@sorastream.com. SoraStream will act with total confidentiality in the analysis of the information provided.

13. Third party services: disclaimer of warranties and liabilities

SoraStream offers to its users a Free to Play and Third Party Library access to other third party games that are not related to SoraStream. That means that SoraStream may contain links or facilitates access to third party websites and platforms SoraStream which may also collect, use and share information about you and your device and your usage of the game while you are on that third party site. In this sense, you must take into consideration that SoraStream’s terms and conditions and privacy policies do not cover nor regulate nor control any third parties’ products, actions or services. For more information about third-party practices, please consult their own terms and conditions and privacy policies.

If you access third party sites through SoraStream, you do it freely and without any responsibility for SoraStream. SoraStream will process the correspondent data at all times according to our Privacy Policy,

SoraStream reserves the right to terminate your access to the third party website or platform through SoraStream, as well as the provision of any or all content provided through it at any time and without notice, for technical, security, maintenance or power failure reasons or any other reasonable cause. Accordingly, SoraStream does not guarantee the reliability, availability or continuity of a third party site or its content, so that the use of them by users is done at their own risk, and SoraStream cannot be held accountable for the discontinuance or unavailability of such services

In accordance with the above, SoraStream is in no way responsible for any damages caused and disclaims any and all warranties or conditions, express, statutory and implied, including, by way of example and without limitation:

1. by errors or missing information in the content published by third parties;
2. by temporary unavailability of the third party website, app or platform;
3. warranties or conditions of uninterrupted or error-free access or use;
4. for the content of the information collected in the third party website or platform, nor for those opinions, comments, insights or other communications that are not issued directly by SoraStream;
5. for any banned user account of the third party website or platform done by the third party, due to the user’s misbehavior or any other reason, such as the detection of viruses, use of automated software or bots, perform in-game services, suspicious IP addresses, etc, as stated in the Terms and Conditions of the correspondent third party, for which SoraStream has no control nor liability;
6. for the unsuccessful access to the third party website or platform through SoraStream;
7. by any situation considered fortuitous or by unforeseen circumstances, despite having adopted all the reasonable technological measures necessary to avoid is, as defined in clauses 5.3 and 8 of SoraStream’s EULA;

The exclusion of damages under this paragraph is independent of your exclusive remedy and survives in the event such remedy fails of its essential purpose or is otherwise deemed unenforceable.

These limitations and exclusions apply without regard to whether the damages arise from (a) breach of contract, (b) breach of warranty, (c) negligence, or (d) any other cause of action, to the extent such exclusion and limitations are not prohibited by applicable law. In case you do not agree with any of the above, or you have any dispute or claim against SoraStream or its suppliers with respect to the above, then your sole and exclusive remedy is to discontinue using the Sora Stream Platform, its data, its brand and related links.

14. Prohibited Activities

1. You must not use SoraStream for illegal activities or attempt unauthorized access to its systems, accounts, or networks. Monitoring occurs for security purposes.

2. Prohibited activities on SoraStream include:

   • Violating any local, national, or international laws.
   • Accessing SoraStream from regions where it's illegal.
   • Engaging in criminal activities or sharing information about illegal acts.
   • Disrupting or damaging SoraStream, its servers, or networks using harmful software or methods such as viruses, cancelbots, Trojan horses, harmful code, flood pings, denial- of-service attacks, packet or IP spoofing,forged routing or electronic mail address information or similar methods or technology
   • Sharing personal information without consent, collecting user data, or promoting discrimination or harassment.
   • Misusing or sharing user accounts, impersonation, transfer, sell user account to another person/people.
   • Employing automated tools to interact with SoraStream or manipulate its content for commercial use.
   • Misusing or tampering with SoraStream's content, attempting reverse engineering, or creating derivative works.
3. SoraStream reserves the right to terminate accounts without refunds upon detecting any of these violations

15. Changes to this Privacy Policy

Occasionally, we may make changes to this Policy. If we make material changes, we will provide you with a prominent notice under the circumstances, for example, by displaying one in the SoraStream Service or by sending you an email. We can notify you in advance.

Therefore, be sure to read any notification carefully.

16. How to contact us

If you have any questions about this Policy, please contact our Data Protection Officer by email to privacy@sorastream.com or by writing at the following address:

We appreciate receiving your input and value your ideas for enhancing SoraStream. Regarding third-party submissions of ideas, comments, suggestions, improvements, proposals, or materials (referred to as "Feedback"), by providing us with Feedback, you grant us all rights to utilize such Feedback and agree to our unrestricted use of it. We treat all Feedback as non-confidential and non-proprietary. It's essential not to submit any information or ideas that you consider confidential or proprietary. You can write us in our Customer Center or to info@sorastream.com