PRIVACY POLICY

Introduction

Welcome to Swordeye. This Privacy Policy explains how ALX Theory L.L.C ("ALX Theory,” "we," "us," or "our") collects, uses, discloses, and otherwise processes personal information in connection with Swordeye (the "Game"), which is made available exclusively through Steam.

By downloading, installing, accessing, or using the Game, you acknowledge that your personal information may be processed as described in this Privacy Policy. If you do not agree with this Privacy Policy, do not use the Game.

Scope

This Privacy Policy applies to personal information we collect or process in connection with the Game and related support communications. Because the Game is distributed only through Steam, certain information may also be collected and processed by Valve Corporation and its affiliates ("Valve") pursuant to Steam’s own privacy disclosures and terms. This Privacy Policy does not apply to information processed by Valve except to the extent we receive that information from Valve.

For individuals located in the European Economic Area, the United Kingdom, and Switzerland, this Privacy Policy is intended to provide the information required under applicable data protection laws, including the General Data Protection Regulation ("GDPR"), as applicable.

Controller Information

For purposes of applicable data protection law, the controller of your personal information in connection with the Game is: ALX THEORY L.L.C.

If required by applicable law, you may contact our data protection officer or privacy lead at swordeye@alxtheory.com.

Information We Collect

We may collect the following categories of information in connection with the Game:

Information Received from Steam

If you access the Game through Steam, we may receive certain information from Steam or through Steamworks integrations, such as:

• your Steam ID or other platform-specific user identifier;
• your Steam display name;
• information relating to ownership or license status for the Game;
• gameplay-related platform data, including achievements, play session information, friends or social features data if enabled by platform functionality, cloud save information, and other information made available through Steamworks or similar tools; and
• country or region information associated with your Steam account, if provided to us through Steam.

The specific information we receive depends on the Steam features we use and the permissions, APIs, and settings made available by Valve.

Information Collected Automatically

When you install, launch, or use the Game, we may automatically collect certain device, technical, and gameplay information, including:

• IP address;
• device identifiers;
• operating system and version;
• hardware information;
• language and region settings;
• crash reports, error logs, bug reports, and performance diagnostics;
• gameplay statistics, progression, save data, preferences, settings, and interaction data; and
• anti-fraud, anti-cheat, and security-related telemetry.

Information You Provide Directly

We may collect information you provide directly to us, such as when you:

• contact us for customer support;
• report a bug or technical issue;
• submit feedback or other communications; or
• participate in surveys, promotions, or community features that we make available.

This information may include your name, email address, account identifier, the contents of your message, attachments you send us, and any other information you choose to provide.

How We Use Information and Our Legal Bases

We process personal information only where we have a valid legal basis to do so. Where we rely on legitimate interests, those interests generally include operating the Game efficiently, maintaining security, improving gameplay and performance, responding to users, preventing misuse, and protecting our business, users, and platform environment. You may have the right to object to processing based on legitimate interests in certain circumstances. Where we rely on consent, you may withdraw that consent at any time, although this will not affect the lawfulness of processing carried out before withdrawal.

How We Disclose Information

We may disclose personal information to the following categories of recipients:

• Service providers and vendors that help us operate the Game, including hosting providers, analytics providers, cloud storage providers, support tools, security providers, and other technical service providers;
• Valve and platform partners, where necessary to provide or support Game functionality, verify entitlements, or interact with Steam services;
• Professional advisors such as lawyers, accountants, auditors, and insurers; and
• Authorities, regulators, and law enforcement where required by law or where necessary to protect rights, property, safety, or the integrity of the Game.

Where required by applicable law, we put in place appropriate contractual, technical, and organizational measures with processors and service providers that process personal information on our behalf.

We do not sell personal information for money. We also do not share personal information for cross-context behavioral advertising through the Game unless expressly disclosed in a supplemental notice.

Data Retention

We retain personal information for no longer than is necessary for the purposes for which it was collected, including to provide the Game, maintain account-related records, resolve disputes, enforce agreements, comply with legal obligations, and protect our legitimate interests.

Retention periods vary depending on the type of information and the purpose for which it is used. For example:

• account, entitlement, and save-related data may be retained for as long as needed to provide the Game and related features;
• support communications may be retained for as long as necessary to address the issue, maintain support history, and protect against legal claims;
• logs, diagnostics, crash data, and security records may be retained for troubleshooting, fraud prevention, security monitoring, and system integrity purposes; and
• some information may be retained longer where required by law, regulation, litigation hold, or legitimate dispute-resolution needs.

When personal information is no longer reasonably necessary, we will delete it, anonymize it, or securely store it and isolate it from further use, unless retention is required or permitted by law.

Cookies and Similar Technologies

Because Swordeye is available exclusively through Steam, many platform-level cookies and tracking technologies may be controlled by Valve or other third parties rather than by us. To the extent we use cookies, SDKs, pixels, local storage, analytics tools, or similar technologies in connection with the Game or any related website, launcher, or support portal, we will do so in accordance with applicable law.

Where required by law, we will request consent before using non-essential cookies or similar technologies. You may also be able to manage certain preferences through your browser, device, Steam settings, or other platform tools, depending on the relevant technology.

California Privacy Notice

If you are a California resident, this section supplements the rest of this Privacy Policy.

Categories of Personal Information Collected

In the preceding 12 months, we may have collected the following categories of personal information, as defined under California law:

• identifiers;
• customer records information;
• internet or other electronic network activity information;
• geolocation data in the form of approximate location inferred from IP address or region settings;
• audio, electronic, visual, or similar information, if included in support communications or user-submitted reports;
• inferences drawn from certain information described above; and
• sensitive personal information in limited circumstances only if voluntarily provided or otherwise permitted by law.

Business and Commercial Purposes

We collect and use these categories of information for the purposes described in Section 5 above.

Disclosure of Personal Information

We may disclose the categories of personal information listed above to the categories of recipients described in Section 6 for business purposes.

Sales and Sharing

We do not sell personal information and do not share personal information for cross-context behavioral advertising as those terms are defined under California law.

Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes that would require a right to limit under California law, except as permitted by law.

Children’s Privacy

The Game is not directed to children under 13, and we do not knowingly collect personal information from children under 13 without appropriate consent where required by law. If you believe a child has provided personal information to us in violation of applicable law, contact us at swordeye@alxtheory.com, and we will take appropriate steps to investigate and address the issue.

If the Game is offered in jurisdictions that impose different age thresholds for children’s data, including within the European Economic Area or the United Kingdom, we will comply with applicable requirements concerning children’s consent and parental authorization where those requirements apply.

Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. These measures are designed to reflect the nature of the personal information we process and the risks associated with that processing.

However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

Third-Party Services and Links

The Game may interact with Steam and may contain links to third-party websites, communities, or services that are not operated by us. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of Valve and any other third-party services you use.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated version and revise the Effective Date above. Where required by law, we will provide additional notice or obtain consent.

Contact Us

If you have questions or requests regarding this Privacy Policy or our privacy practices, please contact us at: swordeye@alxtheory.com