PlaySide Studios Ltd ABN 73 154 789 554 and its group companies (collectively PlaySide, "we," "us" and "our"), respects the privacy rights of our users and is committed to protecting the information collected through our software products, services and websites (including our website www.playsidestudios.com) (collectively, the "Online Services"), accessed through internet-capable hardware platforms including gaming consoles, personal computers, mobile computers, or mobile devices, or in-game applications or software platforms including those hosted by third-parties.

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This privacy policy (the "Privacy Policy") explains what personal information we may collect about you when you use or access the Online Services in connection with the video game software known as Game of Thrones: The War For Westeros ("Game") and how we collect, store, disclose, transfer, protect, and otherwise process that information for the purposes of operating and providing the Online Services. The application of this Privacy Policy is limited to the Game and does not otherwise replace, limit or supersede PlaySide's standard privacy policy.

Please read this Privacy Policy carefully as it sets out how we can use personal information submitted by you to us via any Online Service, via written correspondence or in person. By continuing to submit your personal information to us, you consent to us collecting, using and disclosing your personal information in accordance with the terms of this Privacy Policy. If you do not accept this Privacy Policy, you should cease submitting your personal information to us and cease using the Online Services immediately.

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This Privacy Policy supplements (and its terms are in addition to):

• any other terms of use, end user license agreements, limited software warranties or other terms and conditions between you and PlaySide (including any other privacy policies) relating to the Game; and 

• any privacy disclosures provided to you with your software product and/or by your console manufacturer.
   

​We reserve the right to make changes to this Privacy Policy in order to reflect any changes in data protection laws or our internal policies. We will endeavour to notify you of such changes but, in accepting these terms, you hereby undertake to regularly check for an updated version of this document at: www.playsidestudios.com/privacy-policy for as long as you use the Online Services.

If necessary, we will give you additional choices regarding such changes. As far as permitted by applicable law, your continued use of the Online Services in relation to the Game will signify your acceptance of these changes and this Privacy Policy as amended from time to time.

For the avoidance of doubt, this Privacy Policy is deemed to be a written agreement between us and you and in the event of any conflict with our then current terms and conditions of trade relating to the Game, this Privacy Policy will prevail. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

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PRIMARY VERSION OF THIS PRIVACY POLICY

We are committed to managing personal information in accordance with applicable privacy laws, including (without limitation):

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• The Australian Privacy Principles under the Privacy Act 1988 (Cth)

• The New Zealand Privacy Principles under the Privacy Act 2020 (NZ)

• European Union's General Data Protection Regulation (EU) 2016 / 679 ("GDPR")

• The United Kingdom's Data Protection Act 2018 ("UK GDPR")

• The California Consumer Privacy Act ("CCPA").

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Whilst this Privacy Policy may be translated into languages other than English, the English language version of this Privacy Policy is the primary and master version. Where this Privacy Policy has been translated into a language other than English, the English language version shall always prevail if there is any difference between a term of the English language version and that of the translated version.
 

WHAT DOES THIS PRIVACY POLICY APPLY TO?
 

This Privacy Policy applies to our Online Services and any websites, mobile applications, and other services that link to this Privacy Policy or display it in connection with the Game.
 

For the avoidance of doubt, this Privacy Policy does not apply to websites or services maintained by third parties (whether or not those websites or services promote our products and services or sell related items) and, other than where it is the controller, PlaySide cannot and does not guarantee the security of any personal information held by third parties.
 

In addition, please note that we may hire vendors (agents or contractors) to collect personal information on our behalf and in such cases,  vendors will be required to comply with this Privacy Policy (unless you accept separate privacy terms with them, in which case this Privacy Policy will apply in addition to those terms and, in the event of any conflict, the terms of this Privacy Policy will prevail as between you and PlaySide). 
 

We may use third-party service providers as our online official re-seller and for certain in-game sales functions so you should check their terms and conditions and other policies (as applicable) at the point of sale. Other third-party service providers may be connected to other in-game sales functions so please review the relevant terms and conditions for more details.
 

WHAT PERSONAL INFORMATION DO WE COLLECT?
 

The types of information collected in connection with the activities listed above will vary depending on the activity. The information we collect may include personal information.

When consenting to analytics features and sending crash reporting data via the game’s consent capture form, you’re agreeing to send us:
 

• Hardware configuration

• Console/Platform Identification

• IP address

• Country of access

• Pseudonyms/usernames
   

Outside of the game, you may optionally engage with PlaySide in ways that may request methods to contact you to facilitate offering technical support, or offering a mail list for product updates. In these circumstances, you may be asked to provide:
 

• An email address

  • Or seek a secondary contact method

• Your name or a preferred pseudonym

• Device and hardware details
   

If you use, purchase, or register for an Online Service through a third-party service such as a gaming console's network service or an internet based gaming service, or request that we associate a PlaySide account with a third-party service account, then limited user account personal information may be transferred to PlaySide as part of the registration process and we may be able to collect information about your use of the Online Services. For example, if you purchase a product through a gaming console service, that gaming console service will provide us with information to give effect to the transaction, including a means to identify your Online Service account. 

When you use certain software products published by PlaySide, information about your gameplay may be collected and transmitted to PlaySide through network services or any other internet connection method used by the hardware on which you play the Game (collectively and individually your "Internet Connection"). You may opt out of data and analytics tracking, and request data erasure at any time in the game settings menu. More information about your data rights that are not facilitated by the game can be requested at: support@playsidestudios.com.
 

We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.
 

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

 

Where the GDPR or UK GDPR applies, we rely on the following legal bases for processing your personal information:
 

Performance of a contract

We process certain personal information where it is necessary to provide the Game and Online Services to you. This may include:
 

• Delivering multiplayer features;

• Using matchmaking information to support balanced gameplay;

• Using IP address and connectivity information to connect you to appropriate servers;

• Processing server performance information to monitor memory load, performance, stability, and operational efficiency;

• Validating proof of purchase, maintaining transaction records, and facilitating purchases through the relevant platform.

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Consent

Where required, we ask for your consent before processing certain optional information. This may include:

• Crash reporting data, such as IP address, username, device information, hardware information, and client logs;

• Gameplay analytics data, such as information about your engagement with the Game, platform identifiers, hardware identifiers, and gameplay events;

• Marketing attribution data, such as IP address and platform identifier, used to understand what content or campaign may have helped you discover or purchase the Game.

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You may withdraw consent to optional analytics and crash reporting through the in-game settings where available, or by contacting us at support@playsidestudios.com.
 

Legal obligation and protection of users

We may process certain information where necessary to comply with legal obligations, assist lawful investigations, enforce our terms, or protect the rights, safety, and interests of players, PlaySide, or others. This may include reviewing and retaining chat logs or related player identifiers where abuse, harassment, fraud, cheating, or unlawful conduct is reported.
 

WHAT GAMEPLAY INFORMATION DOES PLAYSIDE COLLECT?
 

When you use products or services on internet-capable hardware, PlaySide may receive information regarding your gameplay without any additional notice to you or actions taken by you. PlaySide will not receive personal information such as your name and address, but may receive other information such as a console ID, gaming service ID, game achievements, game scores and performance, IP address, MAC address, or other device ID, other console/device use information, or other information and statistics regarding your usage of the products or services.
 

Information about gameplay may be collected while you are offline and transmitted to PlaySide when you next connect to the internet, whether or not you are currently logged into your Internet Connection from your console, handheld, mobile device, computer, or other gaming platform.
 

PlaySide may also monitor gameplay information by automated means to ensure that software and services are used in accordance with applicable policies, including any terms of use or end user licence agreement. PlaySide reserves the right to terminate your license if you violate these policies.
 

SPECIAL NOTES ABOUT CERTAIN INFORMATION PLAYSIDE USES FROM EXTERNAL (TO THE TITLE) SOURCES
 

1. Aggregated data

We may collect, use and share aggregated data such as statistical data for any purpose. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Game.
 

2. Public Information Including Message Boards, User Generated Content, Forums, News Blogs, Comments, User Profiles and Chat Rooms

Whenever you give out personal information in public areas of an Online Service, such as on a message board, chat room, comment field, or profile page, that information can be collected and used by other people. Information that you disclose in any of these forums is public information. You should be aware that any personal information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used for any purpose (for example, to send you unsolicited messages). Accordingly, to the fullest extent permissible by law, we shall have no responsibility for the controlling or processing of such data.
 

If you post a video, image, photo, or other content through an Online Service for public view, you should be aware that these may be viewed, collected, copied, and/or used by other users without your consent. If your screen name or an ID contains your real name, then that name will be made publicly available on leaderboards and elsewhere. Therefore, you are strongly encouraged not to use personal information to identify yourself while using public areas of an Online Service. You are responsible for any public information or content you post using our Online Services.
 

3. Email Correspondence

We may provide email addresses or forms which can be used to send us questions or comments or request customer support. In the process of receiving and responding to such requests, we may collect personal information about you, such as your name, email address or any other personal information contained in the body of your email message.

We only use such information for the purpose of responding to or dealing with your questions and/or comments or to provide customer support. In most cases, your message is deleted immediately after we've resolved your inquiry. However, in some instances copies of your requests may be kept on file for our records for quality control purposes or to provide any ongoing support services you have requested.

In addition to responding to your email correspondence and sending you any information you have requested via our email lists, we may send activation emails and other transactional emails to your email address as necessary in order to provide the products and services you request. If you do not wish to receive these emails, you have the option to deactivate your account.

If we have actual knowledge that the person with whom we're communicating is a child under the age of 13 years, we delete the child's email address and message immediately after responding.
 

​4. Children

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PlaySide does not knowingly collect personal information from children under 13 years old (or older, if an applicable law provides for different protections). If we become aware that a child has submitted information to PlaySide, we delete this information immediately. We encourage parents and guardians to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.
 

WHY DO WE STORE YOUR PERSONAL INFORMATION?

Your personal information helps us identify how you engage with our games, allowing us to make a variety of improvements, changes and informs how we can create additional content for the game, or even guide our future games. Outside of improving our games, we may store information to:
 

• Fulfil our reporting obligations to any regulatory bodies

• Properly perform our obligations to you in providing any goods or services

• Maintain accounts records, tracing and verification in accordance with our security and verification procedures.
   

WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?
 

We collect information classified as personal information when you grant consent to provide gameplay analytics, crash analytics or engage with multiplayer features. Methods where your data may be collected from outside of the analytics agreement in the game are: coordinate gameplay tests, accessing our online services to communicate with us, engaging with our advertising, or opt-in to extra communications about the games.
 

Examples of additional cases where we may collect your personal information outside of our games:
 

• Access and use our managed communities (including when you post in or comment on our message boards, forums, news blogs, chat rooms, or other Online Services)

• register for Online Services, products, contests, and special events

• Subscribe to newsletters or alerts

• Purchase our downloadable content for use with the Game

• Request technical support

• Download demos, playtesting builds, our programs, or software we publish

• Participate in polls, surveys, and questionnaires

• Interact with us through use of our software (including console products, personal computer products and online products) or through the use of online Services where personal information is required for use and/or participation.
   

WHAT HAPPENS WHEN WE'RE UNABLE TO COLLECT YOUR PERSONAL INFORMATION?
 

PlaySide implements data minimisation practices to ensure all data collected to deliver gameplay features required for the game is strictly limited to data required to allow you to use the features that define our game (such as using data for multiplayer server connection) without including any unnecessary or unauthorised data. This will be communicated to you at the point of transaction, and failing to agree to these terms may impact your ability to access or purchase this title. If you’ve purchased this title, and we’re unable to process the required data by enacting your data rights, we will inform you if this may put access to any of these features at risk.
 

Data collected through our explicit consent collection form will not impact your ability to access the title, if you choose to withdraw or decline consent. If you choose to remove data after previously supplying your consent, any relevant warnings about how it could impact your experience are shown to you. If no concerns are raised, it will not affect your ability to experience the title to the same degree as before.
 

​HOW DO WE STORE YOUR PERSONAL INFORMATION?
 

To protect your personal information, PlaySide follows generally accepted industry standards and maintains reasonable safeguards for ensuring the security, integrity, and privacy of the information you have provided. PlaySide has security measures and company roles in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal information collected by PlaySide is stored in secure operating environments that are not available to the public. To prevent unauthorized electronic access to personal information, PlaySide maintains information collected online behind a firewall-protected server and uses SSL encryption for purchases.

As no system can be 100% secure, we mitigate exposure risks by not storing sensitive information, and isolating access to your personal information to specialist teams. We utilise strict internal policies that work to identify these risks using the assumption that any personal information exposure can be potentially used for harm. In the unlikely event where your data is exposed, we will try and notify you through our game, our community messaging and in the cases where you’ve given us a contact method; your provided preferred contact method.
 

HOW WE USE YOUR PERSONAL INFORMATION
 

Your personal information collected or processed under this Privacy Policy can be used by PlaySide for the purposes of:

Within our game:
 

• Reporting on crash & hardware performances

• Upgrading, changing or planning gameplay content

• Providing you with access to product features such as multiplayer

• Fulfilling product orders for online titles, physical products or - if applicable - in game transactions.

• Providing you with methods to deliver feedback about your experience, including but not limited to forms, community posts and customer service experiences.

• Responding to questions, comments or technical problems

• Attributing your presence to marketing campaigns, platform wishlisting and other marketing activities.

• Carrying out other business activities in circumstances where you have, or ought reasonably to have, an expectation that we will process your personal information for a particular purpose (including the fulfilment of any arrangements or agreements between us).
   

In circumstances where extra notice is given; outside of the game:
 

• Getting your feedback from forms/surveys about your experience or impression of our products.

• Sending you promotional materials

• Fulfilling "tell a friend" or similar requests

• Market research and demographic studies
   

Additional website cookies & linkage tracking navigating outside of the game:

Online Services offer social networking site ("SNS") features and 'widgets', such as Facebook's "Like" or "Share" buttons. These third-party SNS features may set a cookie to enable the feature to function properly and may collect information about you when you use them, such as your IP address and which page you are visiting on our site. SNS features and widgets are either hosted by a third party or hosted directly by our Online Services. Your interactions with these features are governed by the privacy policy of the SNS providing the feature. Please review each SNS governing policy before using their services.
 

From time to time, PlaySide may engage vendors to perform services on PlaySide's behalf. These vendors provide internal support to PlaySide by operating some of the services we provide you such as contest entry collection and email services. Although these vendors, not PlaySide, may collect, use, or maintain the information in connection with the Online Services, PlaySide still requires that they adhere to PlaySide's stated privacy policies and that they not share your personal information with third parties or use such information for their own marketing purposes.
 

We may share your personal and other information with third parties in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or that may expose us to legal liability, including as required by law enforcement or other government officials. We also may share your personal and other information with third parties when we have reason to believe that such disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or when we believe that such disclosure is necessary to protect our rights, investigate, or enforce our policies, terms, and conditions, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on PlaySide. In addition, your personal and other information may be disclosed to a potential or actual successor or assigned in connection with a proposed or consummated merger, acquisition, reorganization, bankruptcy, or other similar event involving all or a portion of PlaySide.

We do not sell your personal information to third parties. However, we may share some of your data with our third-party partners in the provision of the agreed services with your consent. When this is done, our partners are obligated to only use your data for the reasons agreed with us and have committed to not misuse or sell your data in any way. 
 

Your personal information may be shared with partners with the following definitions:

• Our employees, contractors or service providers to the extent necessary to provide services to you

• Our business advisors including accountants, lawyers and other business professionals where reasonably required for them to fulfil their obligations to us

• If required by law, to any person or body authorised by such law.
   

We may also use your personal information for secondary purposes closely related to the primary purposes stated above and in circumstances where you would reasonably expect such use or disclosure. However, we will not use your personal information for marketing purposes where you have instructed us not to do so and you may unsubscribe from our emailing/marketing lists at any time by contacting us in writing.​

We are not liable for any loss, damage or claim arising out of a third party's use of your personal information where we were authorised by you or law to provide that third party with your personal information.
 

You may contact us to learn more about our current vendors, their privacy policies, and the ability to opt out of their tracking programs. We do not have access to or control of any third-party tracking technologies and we encourage you to review their privacy policies before disclosing information to such parties.
 

​HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION
 

You have the right to access your personal information stored by us at any time. Please contact us via our privacy support services by emailing support@playsidestudios.com. Please note as we operate in Australia primarily, we might not be able to reply immediately. Requests to access may require us to request more information from you which will support us with identifying your personal information. Additionally, we may ask for your country of residence to be provided to facilitate processing your request. It may take us a few days to process your request, and identify all of the information requested. Please ensure this is considered when making your request.
 

You have the right to be informed about how your personal information is being used. Subject to any conditions or requirements set out in any applicable law or regulation, you may have the following rights in relation to the personal information we hold about you:
 

• The right to request a copy of your personal information held by us

• The right to correct any inaccurate or incomplete personal information held by us 

• The right to request that we erase your personal information

• The right to request that we restrict the processing of your personal information

• The right to have your personal information transferred to another organisation

• The right to object to certain types of processing of your personal information by us

• The right to complain (please see the final section of this Privacy Policy).
   

You may contact us directly at any time to ask questions about your personal information, or to update your details. Please provide your country of residence in your correspondence.
 

HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?
 

Without prejudice to your right to request erasure of your personal information, we retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including while we operate, support, update, analyse, or assess the relevant title or related titles.
 

The following data retention criteria applies based on how you engage with Playside:
 

• Data privacy requests; 21 days

• Gameplay Analytics; Life of title + 13 months

• Crash logs; Life of title + 90 days

• Marketing engagement; until you opt-out

• Customer service records: until the support request is resolved, or for up to one month after our last interaction with you, unless a longer period is required for legal, security, dispute resolution, or operational reasons.
   

"Life of title" means the period during which PlaySide continues to operate, support, update, analyse, commercially assess, or make the title available. This may include a period after active development has ended where the title remains available through relevant platforms or where data is still required for operational, legal, security, analytics, or business purposes.
 

We may retain some of your information in our files for a reasonable period of time to comply with the requirements of any tax or other governing bodies, resolve disputes, enforce our user agreements, administer our services, comply with technical and legal requirements, and/or any other constraints related to the security, integrity, and operation of our Online Services.
 

DO WE DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?
 

PlaySide is based in Australia and may store, access, process, or transfer your personal information in countries other than the country in which you are located. This may include Australia, countries in the European Economic Area, the United Kingdom, the United States, and other countries where service providers or operational partners are located.
 

Where we transfer personal information outside your country or region, we take steps designed to ensure that your personal information receives an appropriate level of protection. These steps may include:
 

• transferring personal information to countries that have been recognised as providing an adequate level of data protection;

• entering into appropriate contractual safeguards with recipients, including the European Commission’s Standard Contractual Clauses where required for transfers of personal information from the European Economic Area;

• using the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses where required for transfers of personal information from the United Kingdom;

• implementing additional technical, organisational, and contractual safeguards where appropriate, such as access controls, encryption in transit, role-based access, vendor due diligence, and data minimisation.
   

Where required by applicable law, we will assess whether the laws and practices of the recipient country may affect the protection of your personal information and will implement supplementary safeguards where appropriate.
 

You may contact us at support@playsidestudios.com if you would like more information about the safeguards we use when transferring personal information overseas.
 

OUR WEBSITE COOKIES
 

Our website will present you with an option to supply us with data; and preserve your right to choose to opt-out or customize your boundaries with use of cookie data. In some cases, rejecting the use of cookies may impact our website functionality outside of our intention. 
 

UNSOLICITED COMMUNICATION
 

PlaySide will only use your preferred contact methods to communicate with you when you’ve: 
 

• Actively consented to email marketing

• Initiated communication through a customer service or support feature
   

Should you receive an email stating it is from us but the email comes from another email address (not containing “@playsidestudios.com”), or if you suspect a phone call you received may be suspicious, please report this immediately to support@playsidestudios.com. Do not acknowledge or respond to the suspicious communication.
 

RESIDENTS IN THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM
 

This Privacy Policy also applies to residents of the United Kingdom and European Economic Area in compliance with the GDPR and the UK GDPR.

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If you are a resident of the United Kingdom or European Economic Area you are protected by specific regulations set out in the GDPR and the UK GDPR which include the following:
 

• You have the right to access your personal information at any time and enquire as to exactly what information we are holding about you.

• You have the right to rectify or change your personal information at any time.

• You have the right to request deletion of your personal information at any time unless we are required to hold your data for legal or regulatory reasons.

• You also have the right to restrict whatever personal information we hold on you.

• You have the right to request the transfer of your data to a relevant third party.

• You have the right to object to your personal information being used in a way that you do not like and request that we stop doing so. We will fulfil your request unless there is a legal or regulatory reason not to.

• You have the right to make a privacy complaint if you feel we are misusing your data.

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We will respond in the same way as we will for residents of any other country as set out in this Privacy Policy. 

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RESIDENTS IN CALIFORNIA, USA
 

This Privacy Policy also applies to residents of California, USA, in compliance with the CCPA. If you are a resident of California you are protected by specific regulations set out in the CCPA which include the following:
 

• You have the right to access your personal information at any time and enquire as to exactly what information we are holding about you.

• You have the right to rectify or change your personal information at any time.

• You have the right to request deletion of your personal information at any time unless we are required to hold your data for legal or regulatory reasons.

• You have a right to opt out of the sale of your personal information.

• You have a right not to be discriminated against for exercising one of these privacy rights.
   

For California residents, the categories of personal information we may collect include identifiers, online identifiers, internet or electronic network activity information, commercial information, device information, gameplay information, support information, and inferences drawn from gameplay, service, or marketing engagement.
 

The categories of sources, purposes for collection and use, categories of recipients, and retention periods are described in the sections above, including "What Personal Information Do We Collect?", "How We Use Your Personal Information", "How Long Do We Store Your Personal Information?", and "Do We Disclose Your Personal Information Overseas?".
 

Marketing attribution may use limited identifiers, such as IP address and platform identifier, to help us understand how users discover or purchase the Game. Where required by California law, this may be treated as a "sale" or "sharing" of personal information, and California residents may opt out where applicable. Where required, the privacy consent form shown when you launch the Game will ask whether you consent to marketing attribution.
 

We do not knowingly sell or share the personal information of children under 16. Where we disclose personal information to service providers, contractors, or partners, we do so for the purposes described in this Privacy Policy and subject to appropriate contractual restrictions where required by applicable law.
 

We do not knowingly sell or share the personal information of children under 16. Where we disclose personal information to service providers, contractors, or partners, We do so for the purposes described in this Privacy Policy and subject to appropriate contractual restrictions where required by applicable law.

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We will respond in the same way as we will for residents of any other country as set out in this Privacy Policy. 

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COMPLAINTS AND SPEAKING TO A PRIVACY CONTACT OFFICER

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PlaySide Studios Limited is the controller of your personal information for the purposes described in this Privacy Policy.

We have not appointed a Data Protection Officer in the European Union or the United Kingdom. Privacy enquiries will be handled by our internal privacy and data specialists in Australia. You can contact us using the details below:

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PlaySide Studios Limited
75 Crockford Street
Port Melbourne, Victoria 3207, Australia
support@playsidestudios.com

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The designated specialists will then investigate and respond to you. All such enquiries or complaints will be taken seriously and handled with impartiality and discretion. If you wish to submit a complaint, please provide us with all relevant details such as the date and time of the incident or communication, the circumstances surrounding the event and your concerns about what was said or done. In some cases we may ask for further information to support your requests. If you have complained about something that is not covered by the relevant applicable privacy laws, we will explain why we are unable to take further action. Please allow a few days for us to investigate and respond to any privacy complaints.