BONFIRE STUDIOS PRIVACY POLICY

 Last Updated: September 17, 2025

Bonfire Studios, Inc. (“Bonfire”) respects the privacy of its players and users of its games, websites, and services, including communication services, (collectively, the “Services”).

We recognize the importance of protecting information we collect and have crafted this Privacy Policy to inform you about how we gather, use, process, store and disclose your personal information, in conjunction with your access to and use of our Services. It also describes your privacy rights, including the right to object to some of the processing which Bonfire carries out. More information about your rights, and how to exercise them, is set out in Sections 5 to 7 below.

• WHAT INFORMATION WE COLLECT

• HOW WE COLLECT YOUR INFORMATION

• USE OF YOUR INFORMATION BY BONFIRE

• SHARING YOUR INFORMATION

• YOUR CONTROLS, RIGHTS AND CHOICES

• YOUR PRIVACY RIGHTS (STATE-SPECIFIC AND INTERNATIONAL)

• CHILDREN’S PRIVACY

• DATA TRANSFERS, SECURITY, AND LAWFUL BASIS FOR PROCESSING

• CHANGES TO THIS PRIVACY POLICY; COMMENTS AND QUESTIONS

1.   WHAT INFORMATION WE COLLECT

We may collect the following categories of information (“Personal Information”):

●      Registration information you provide when you create an account whether on our site or through our third party service providers (e.g., Steam), which may include personal data such as: your first name and surname, country and/or state of residence, date of birth, email address, phone number, username and password.

●      Account information including:

○      Information sent either one-to-one or within a limited group using our chat, post or similar functionality, where we are permitted by law to collect this information.

○      Content, communications and other information you provide to us, view or engage with when you use our games and sites, play our games through third-party sites or platforms (such as digital distribution services or social networking sites) or link your profile from a third-party site or platform (e.g. Steam) to your registered account. We collect information about how you use our Services, including: the types of content you view or engage with, the features you use, the actions you take, the people or accounts you interact with, and the time, frequency and duration of your activities.

○      Location information, when you visit our sites or use our Services, including location information either provided by a mobile device interacting with one of our games or sites, or associated with your internet protocol (IP) address, where we are permitted by law to process this information.

○      Usage, viewing and technical data, about your computer, device, hardware or software you use to access our Services, including device identifiers (including make and model, operating systems and browsers, or other device or system-related specifications), IP address, proxy server, plugins, internet service provider or your mobile carrier, and third-party handles associated with your account when you visit our sites, use our games on third-party sites or platforms (e.g., Steam), or open emails that we send. We use log-ins, cookies, device information and IP addresses to identify you and log your use, including web pages you visited prior to coming to or upon exiting our sites, the game you played or application you used, how long you played or used it, gameplay attempts, progression and results, saved preferences, and crash reports.

○      Communications that you send to us, such as inquiries related to your account.

●      Your marketing preferences, including any consents you have given us.

●      Information you share with us in connection with playtests, surveys, contests, or promotions, including your first name and surname, residence, date of birth, email address and phone number.

Additionally, there are a few special circumstances to note:

●      Intellectual Property Claim Notices: If you notify us of an intellectual property claim, the information in your claim notice may be shared with other parties to the disagreement or third parties in our discretion and as required by law;

●      Alpha/Beta Service Player: If you volunteer to serve as a participant for our pre-commercial content, we may track bug reports and individual system performance in an effort to test our technology rigorously before it is deployed;

●      Former Player: If you discontinue your use of our Service, we may keep your registration file in our database for use in the event that you elect to renew your use of our Service, as well as for anti-fraud and other such protective measures. When the Chinese Personal Information Protection Law (“PIPL”) applies, we will not keep your registration file if you discontinue your use of our Service; unless (i) the retention period prescribed by laws or administrative regulations has not expired, or (ii) it is technically difficult to delete your information. In such cases, we will cease the processing except for the storage and any necessary measure taken for security protection.

2.   HOW WE COLLECT YOUR INFORMATION

We collect information you provide directly to us when you access our games, services or request information from us, register with us, participate in public forums or other activities on our sites and in-game, respond to inquiries or surveys, or otherwise interact with us. We also record some of this information automatically when you use our Services.  We also may receive some of this information from service providers and third parties.

●      We collect the types of information outlined in Section 1 and when you play our games or visit our sites, when you register and manage your account, when you use our Services, when you purchase a product or services from us, when you post to forums or chats, if you send us support inquiries, intellectual property claims or other claims, complaints or inquiries, when you participate in playtests, contests or promotions, or when we ask you for information for contractual or legal reasons.

●      We collect some information automatically through technology, such as cookies and other mechanisms (such as web beacons and pixel tags), including when you visit our sites or play our games on third-party sites or platforms. A cookie is a small string of data which often includes an anonymous unique identifier sent to your Internet browser from a website’s computers, which is stored on your computer’s hard drive and is used to customize your use of a product or online site, keep records of your access to an online site or product, or store information needed by you on a regular basis (e.g. password retention functionality). Bonfire uses cookies for a number of purposes relating to our websites, games and services, including to access your account information where you “login” to our websites, forums or other areas and to keep track of your website session data. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so consult the “Help” menu of your browser to learn how you change your cookie preferences. Please note that if you reject all cookies, you may not be able to use certain of our (or other companies’) web pages.

●      We acquire information when you buy, download, or access our games on or through services operated by third parties. If you do, they may provide us with information to facilitate your access to and use of our Services. This typically includes information like your display name, user ID, and device and region information. For example, you can choose to download and play our games on platforms (such as Steam or Epic Games) or consoles (such as PlayStation® or Microsoft Xbox) through your related account. When you do, the company operating that platform or service may share some information with us, which helps us do things like facilitate your gameplay, and track your progression and entitlements.

●      We acquire information from other trusted sources to update or supplement the information you provided, or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, by accessing our game through Steam or linking a social media account), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this Privacy Policy and the information that the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our games.

3.   USE OF YOUR INFORMATION BY BONFIRE

Bonfire will be the data controller for your information. We may use your information for the following purposes and legal bases set out below:

● Contractual Necessity: we process Personal Information to perform the Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process Personal Information to set up and maintain your account, process your purchases, authenticate players, provide player-experience features (including saving your preferences), monitor and analyze the Services, detect and prevent fraud, cheating or other similar misuse, and contact you about your account, transactions, or other updates. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.

● Legitimate Interests: we process Personal Information as needed for our business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you would reasonably expect, including to communicate with you, respond to your requests, or provide you with updates and information; better understand our players and their preferences; personalize your experience, save your preferences, authenticate our players, and provide similar user experience features; develop, deliver, and improve the Services and other offerings (including those which may be offered in connection with other parties); manage and customize promotional offers and (in-game) purchases; secure and protect the Services; support auditing, data analysis, and other legitimate business operations; and prevent or moderate fraudulent, toxic, harmful, or illegal content or conduct that breaches our terms.

● Legal Obligations: we process Personal Information when necessary to comply with legal obligations, including responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes; and to identify or moderate illegal content or conduct on the Services.

● Consent: we process Personal Information when you provide us with your consent to do so (including for playtests, surveys, contests or promotions; to personalize content and experiences on our sites and in our games; and to optimize or improve our products, services, and operations). You are not required to provide consent if you do not want your Personal Information to be processed for the requested purposes, and you may withdraw your consent at any time.

Bonfire also uses cookies to perform authentication of your account, show you accurate information, personalize your experience (including communication preferences, features and customized content), enable and support our security features, help us detect fraudulent or malicious activity, conduct marketing campaigns and track their performance, and improve our services. For further information on these, including how to manage your consent preferences, please visit the cookie banner on our website.

4. SHARING YOUR PERSONAL INFORMATION

Except under certain limited circumstances as set forth herein, Bonfire does not disclose to third parties the Personal Information or other account-related information that you provide to us without your permission. You understand, however, that we may disclose your Personal Information or other account-related information under the following circumstances:

● With platform and console partners (for example, to facilitate gameplay when you access our games or Services through a third-party provider such as Steam or PlayStation®);

● With other players (if you use our social features, such as chat);

● Publicly (for example, your display name, content you create or share, basic game statistics, and such similar information as may be generally accessible to others);

● With service providers that operate on our behalf to help support our Services in accordance with our instructions (for example, anti-fraud functions, cloud storage providers, email delivery, marketing and advertising partners, payment processors, player support, or Bonfire’s operations to fulfill your service requests, offer content, or help us improve our products and/or services);

● When we believe we must in order to comply with the law or to protect you, Bonfire, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of our terms and policies, or if necessary to protect others from death or serious harm to body or property);

● With our licensees (including our publishing partner in Korea and Japan, Drimage);

● In connection with certain types of corporate transactions, including the prospective purchaser’s adviser and new owners if the disclosure is done as part of a purchase, transfer, or sale of services or assets (for example, in the event that substantially all of our assets are acquired by another party, player information may be one of the transferred assets), should we plan to merge with or be acquired by that business entity;

● With your permission (for example, if you use or link third-party external accounts to use our games and Services or participate in cross-promotional events); and

● We may also share information that does not identify you with third parties, including aggregated or de-identified information.  

To the extent that we share your Personal Information with third parties, we endeavor to ensure these third parties provide the same or substantially similar protections as those that we have described in this privacy policy.

5.   YOUR CONTROLS, RIGHTS AND CHOICES

5.1 Data Retention

 We retain your Registration Information and Account Information while each of your accounts is inactive, and for 6 years (or for Germany 3 years) afterwards.

Where we process your Personal Information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period of 14 days after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process your Personal Information in connection with playtests, surveys, contests, promotions, or performing a contract, we keep the data for 6 years (and for Germany 2 years) from your last interaction with us.  

We also retain your Personal Information for as long as reasonably necessary to comply with our legal obligations. If required by law or if the information is subject of a legal request or governmental investigation, we retain certain financial transaction information and Personal Information for as long as we are required to comply with applicable laws, regulations or such legal process or investigation. We also retain Personal Information in order to protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

5.2 Right to Access and Control your Personal Information

 You may exercise your controls, rights and choices, or request access to your Personal Information, by following the unsubscribe instructions provided in communications that we send to you, or sending correspondence regarding your request(s) or the communications or services you no longer wish to receive from us to privacy@bonfirestudios.com.

6.   YOUR PRIVACY RIGHTS

Under certain circumstances, you have rights under data protection laws to access, modify or delete the Personal Information we hold about you.

6.1       YOUR STATE-SPECIFIC PRIVACY RIGHTS

Some U.S. states (such as California) provide additional rights by law. Based on your jurisdiction, you may have some or all of the rights listed below:

● Access: The right to know what Personal Information we collect about you, including the categories of Personal Information collected and sources, the business or commercial purposes for collection, the categories of third parties with whom we disclose Personal Information, and the specific pieces of Personal Information collected;

● Correction: The right to rectify any inaccurate Personal Information;

● Deletion: The right to delete Personal Information that we have collected from you unless retention is necessary for operational or legal reasons (including to provide you with the Services you requested, complete transactions, perform our contract with you, ensure the security or integrity of the Services, debug the Services, exercise legal rights on behalf of ourselves or others, enable internal uses aligned with user expectations, or comply with a legal obligation);

● Restriction: The right to restrict the processing of your Personal Information in certain instances;

● Data Portability: The right, in certain cases, to receive your Personal Information in a structured, commonly used and machine readable format and/or transmit that Personal Information to another data controller;

● Objection: In some cases required by law, the right to ask us to stop processing your Personal Information. Your right to object includes where we process your Personal Information for performing a task in the public interest or pursuing our legitimate interests or those of a third party;

● Withdraw Consent: Where your consent is required, you may withdraw such consent at any time (though this will not affect the lawfulness of our processing of your Personal Information prior to that).

We do not “sell,” “share,” or use Personal Information of consumers for “targeted advertising” purposes in those U.S. states that require these defined activities to be subject to an opt-out. We are therefore not required to provide an opt-out.

6.2       INTERNATIONAL RIGHTS

If you are based in the European Economic Area, the United Kingdom or Japan, under certain circumstances you have the following rights:

● Request access to your Personal Information (Art. 15 (UK) GDPR). You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making. This also covers the right to obtain a copy of your personal data undergoing processing.

● Request correction of your Personal Information (Art. 16 (UK) GDPR). You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you. 

● Request erasure of your Personal Information (Art. 17 (UK) GDPR. You may have the right to request that personal information held about you be deleted.

● Request restriction of processing your Personal Information (Art. 18 (UK) GDPR). You may have the right to prevent or restrict processing (including disclosing to third parties) of your personal information.

● Request objection (Art. 21 (UK) GDPR) to processing your Personal Information on the basis of our legitimate interest (or those of a third party). This includes processing for direct marketing purposes or profiling for purposes of direct marketing, or where we are performing a task in the public interest - your objection will be upheld, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defence of legal claims that may be brought by or against us.

● Request transfer of your Personal Information (Art. 20 (UK) GDPR). You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.

In the following jurisdictions, you may also have the following additional or different rights:

● Brazil: You have the right to request confirmation that we process your Personal Information; you have the right to request that we block, anonymise or exclude your Personal Information where the data is unnecessary, excessive or processed in violation to local laws; you have the right to request erasure of your Personal Information processed based on your consent; you have the right to request information on with whom we shared your Personal Information; you have the right to receive information on the possibility of not granting consent and the adverse consequences of that choice; you have the right to oppose to the processing where it is carried out based on a legal basis other than consent, where the processing is in violation to local laws; you have the right to request the review of a decision taken based solely on the automated processing of your Personal Information. 

● China: You may have the right (i) to know about and decide on the processing of your Personal Information, (ii) to object to the processing of your Personal Information, (iii) to copy your Personal Information; (iv) to an explanation of the rules for processing Personal Information; (v) of individuals who cancel their accounts or withdraw their consent to prompt handling and access to convenient methods/channels supporting the exercise of their rights.

 ● France: You may have the right to instruct us on the processing (retention, erasure and disclosure) of your Personal Information after your death; you may change or revoke such instructions at any time. This also includes the right for you to choose, if you wish, a third party to whom we will disclose your Personal Information after your death. For detailed information regarding retention periods, please see Section 5.1 above.

● Italy: You have the right, limited to the direct offer of information society services, to prohibit the exercise of the rights referred to in the GDPR after your death, by instructing Bonfire through a written declaration. You may change or revoke such instructions at any time. In any case, such prohibition cannot adversely affect the exercise, by third parties, of property rights arising from your death, nor the right to defend their own interests in court.

● United Kingdom: Make a complaint against Bonfire in connection with the processing of your Personal Information. You have the right to make a complaint against us using the contact details set out below if you believe that we have not complied with our obligations under UK data protection law.

6.3       EXERCISING YOUR PRIVACY RIGHTS

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

Where we collect your Personal Information to perform a contract with you, or where we have to collect your Personal Information by law, the provision of information is mandatory. If the relevant data is not provided, then we will not be able to provide the Services to you. The provision of all other information is optional, but not providing information may affect your ability to use the Services or use particular aspects of the Services if information is needed for those purposes.    

Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may however have other legal grounds for processing your data for other purposes, such as those set out above.

In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.

You have the right not to be discriminated against for exercising any of these rights.

If you would like to exercise the rights available to you, please contact us at privacy@bonfirestudios.com. We will confirm receipt of and respond to your request consistent with applicable law.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.

You may also make a rights request using an authorized agent. Authorized agents must include (a) the name and email address of both you and the agent, and (b) the written permission, signed by you, granting authority to the agency, such as power of attorney. If we receive a rights request from an authorized agent who does not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may require you to verify your own identity directly with us, confirm with us that you provided the authorized agent permission to submit the request, or deny the request.

We may limit how we respond to your requests, and may retain certain Personal Information when necessary to handle legal claims, comply with applicable laws or legal obligations, or cooperate with law enforcement.

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

Where you believe that we have not complied with our obligations under this policy or applicable data protection law, you have the right to make a complaint to your local data protection supervisory authority. If you are based in the EU, details of EU data protection authorities are available here. In the UK, this is the Information Commissioner’s Office and their website is here. In Brazil, this is the Autoridade Nacional de Proteção de Dados and their website is here.

7.  CHILDREN’S PRIVACY 

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from thirteen (13) years of age. If Bonfire learns that personal information of persons under thirteen (13) has been collected on or through our Services, Bonfire will take appropriate steps to delete this information.

If you are the parent or legal guardian of a child under thirteen (13) who has provided personal information to Bonfire without your knowledge, please contact us at privacy@bonfirestudios.com to have that child’s account terminated and/or personal information deleted.

For residents of the European Economic Area or UK, where processing of personal data is based on consent, Bonfire will not knowingly engage in that processing for individuals under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such individuals, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records. 

8.   DATA TRANSFERS AND SECURITY

8.1 Cross Border Data Transfers

We operate globally and may transfer your information or Personal Information to third parties in locations around the world for the purposes described in this Privacy Policy. If you are located in the European Union, the United Kingdom, Brazil, or other regions with laws governing data collection and use that may differ from U.S. law, please note that your information may be transferred to a country or jurisdiction that differs from those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. Whenever your Personal Information is transferred, stored, or processed by us, we will take reasonable steps, including ensuring that third parties will implement required measures, to safeguard the privacy of your Personal Information in accordance with applicable law. If permissible under local law, you are authorizing Bonfire to process your information in any of the locations where we operate (including the United States) by using our Services. To learn more, see our “Comments and Questions” section below.

8.2 Security

We implement technical, physical and organizational security safeguards designed to protect your data from loss, misuse and unauthorized access and disclosure. The details of these safeguards can be obtained on request by using the contact details below. We regularly monitor our systems for possible vulnerabilities and attacks. However, given the nature of electronic communications and information processing technologies, we cannot guarantee the security or safety of any information that is sent to us, transmitted through the Internet or stored on our systems. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach by others of any of our physical, technical, or organizational safeguards. In the event that Personal Information is compromised due to a breach of security, Bonfire will promptly notify our players and relevant authorities in compliance with applicable law.

9.   CHANGES TO THIS PRIVACY POLICY; COMMENTS OR QUESTIONS

From time to time, we may change this Privacy Policy to reflect changes in our technologies or practices, regulatory requirements or for other purposes. We will provide notice to you through our Services if these changes are material and, where required by applicable law, we will obtain your consent. If you object to any changes, you may discontinue using our Services and close your account. You acknowledge that your continued use of our Service or product(s) after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

If you have a comment or question about this Privacy Policy or our privacy practices, please send an email to privacy@bonfirestudios.com.