Privacy Policy

INTRODUCTION

This mobile application and its related online platform components, collectively referred to as “Elysium” (“App”), is created by Mythologi Inc. (“Mythologi,” “we,” “our,” or “us”), and is designed to enable you to build and interact in game worlds blended with information from the real world. To provide the App, we need information about you. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it, and what choices you have when you use our App.

You should also read our Terms of Use, which sets out the agreement between you and Mythologi with respect to the App.

By downloading, accessing, using, and/or interacting with the App, you agree to the collection and use of your information in accordance with this Privacy Policy. If you have any concerns about providing information to us or it being used as described in this Privacy Policy, you should not use the App.

Mythologi reserves the right to change this Privacy Policy at any time by posting a modified version on the App, so please review the Privacy Policy frequently to ensure you are aware of any changes. If we make a material change to this Privacy Policy, we will provide appropriate notice in accordance with legal requirements. At such time, your continued use of the App after notice of posting or notice of such changes constitutes your agreement to this latest version of this Privacy Policy and any future revisions.

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to the mobile application and its related online platform components, collectively referred to as “Elysium”

This Privacy Policy does not apply to other Mythologi websites, online properties, or systems, or to third party websites, online properties, or systems to which the App may link, and you accept that Mythologi is not responsible for the security or privacy practices of any such third party websites, properties, or systems. Sometimes we may direct you to a site operated by a vendor or partner. Even though the page where you provide information may have the look and feel of a Mythologi page, a different privacy policy may govern that information collection by our vendor or partner.

Capitalized terms that are not defined in this Privacy Policy are defined in our Terms of Use.

2. DATA CONTROLLER

Mythologi Inc., a registered company headquartered at 512-5333 avenue Casgrain, Montreal Quebec, Canada H2T 1X3, is the data controller responsible for making decisions about how we use your personal information.

If you have any questions or comments on this Privacy Policy or our Terms of Use, please email us at [email protected] .

3. KEY THINGS TO KNOW

We’ll keep the information we hold about you to a minimum. We’ll only use your information to provide you with services you’ve asked for, reply to your messages, improve our App and comply with the law. We won’t sell your information to anyone else (ever). We won’t share your information with anyone else unless absolutely necessary for the purposes of maintaining existing features of the App You have quite a few rights when it comes to how we use your information If we change how we want to use your personal information, we’ll let you know first

4. THE INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

By law, we can only use your information if we meet one of six rules. These are also called ‘legal grounds’.

The key rules we rely on when using your Personal Data are where:

We need to use your information to do something that we’ve agreed to do, or require you to do something that you’ve agreed to do, under any agreement between us, for example, under the terms that apply when you use our App (contract)

You’ve given us permission to use your information for a specific reason (consent)

We need to use your information to comply with the law (law)

We need to use your information where we’ve a good reason for doing so, if we’re sure that you would expect this, and that your rights won’t be affected (good reason)

We need to collect and use certain Personal Data to provide the App to you, as follows:

When you sign up for an Account on the App, you give us Personal Data voluntarily by providing it to us. We collect and use that information in order to authenticate you when you register an Account to make sure you are eligible to use the App. That information includes the username you choose to use on the App, and internal account IDs that we assign to your account.

You must have an Account with a supported external single sign-on (SSO) service to use the App. As such, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow.

A. EXTERNAL SIGN-ON

You must have an Account with a supported external single sign-on service to use the App. As such, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access the App.

If you choose to register your Account with the App using your Google account, we will collect your Google email address and an authentication token provided by Google.

If you choose to register your Account with the App using your Apple account, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.

Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.

B. IN-GAME ACTIVITIES AND MOBILE DEVICE INFORMATION

We collect and use your in-game actions and achievements, as well as certain information about your mobile device (including device OS, model, configuration, settings and information about third party applications or software installed on your device), to operate the App for you and to personalize your user experience.

C. SUPPORT SERVICES

We further use the information above in order to provide technical and customer support to you.

D. COMMUNICATION WITH US

You also may give us Personal Data when you communicate with us, depending on the method of communication you use and the information you include in your communication. For example, you may email us and include a contact phone number. We use that information to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

Using information regarding the pages of our App which you browsed or the features you used, and the time spent on those pages or features, the links on our App that you click on, as well as actions you take in the App, your in-game user settings and preferences to understand who is using the App and how.

Using your contact information (e.g., your email address or phone number) if you provide it to us when you contact us, in order to communicate with you to provide technical and customer support.

Analyze your in-app activity to enable other features of the App that are tailored to your personal user experience.

E. TO OFFER NEW OR ADDITIONAL FEATURES FOR OUR APP

Using your in-app actions, as well as certain information about your mobile device (including device OS, model, configuration, settings and information about third party applications or software installed on your device), to:

Carry out anti-fraud measures and enforce our Terms of Service Ensure that we provide a fair and equitable experience to all players. Make legal or regulatory disclosures Establish, exercise, or defend legal claims.

5. ACCESSING, CORRECTING OR UPDATING YOUR PERSONAL INFORMATION

Any requests to access, correct, amend or delete any personal information can be made via our contact details below (section-15 of this document).

If you request access to your personal information, we will provide access whenever this is required by law or we otherwise consider it appropriate. However, making a request does not guarantee that we will provide you with access. In particular, we will not provide access to information that is confidential, legally privileged or would otherwise have an unreasonable impact on the privacy of others.

For EU residents, you may also obtain a copy of your personal information on request and transfer this to another person or entity pursuant to your right of data portability, as well as request that your data be erased (right to be forgotten) to the extent that we can by law.

For California residents, you may also obtain a copy of your personal information on request including additional details regarding how your information is used, collected, shared or sold in the preceding 12 months. You may also request that your data be erased, opt out of the sale of your personal data and have the right to not be discriminated against for exercising these rights.

6. WHO WE SHARE INFORMATION WITH

We will not share any personal information that we have collected from or regarding you except as described below:

A. INFORMATION SHARED WITH OUR SERVICE PROVIDERS

We engage external service providers to work with us to administer the App. As part of that, they will process your Personal Data on our behalf. These external service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose and to provide protections for your Personal Data that are at least as protective as this Privacy Policy. The service providers we use help us to run, operate and maintain the App through third party platform and software tools; perform content moderation and crash analytics; administer multi-user functionality; and provide technical and customer support.

B. INFORMATION SHARED WITH THIRD PARTIES

We share Anonymous Data with third parties for industry and market analysis. We do not share Personal Data with any third parties for their direct marketing purposes.

C. INFORMATION DISCLOSED FOR OUR PROTECTION AND PROTECTION OF OTHERS

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

D. INFORMATION DISCLOSED IN CONNECTION WITH BUSINESS TRANSACTIONS

Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

7. HOW YOUR PERSONAL DATA IS TRANSFERRED

Mythologi operates the App across the globe. Your Personal Data will very likely be transferred and stored in a country outside of your home country according to the purposes outlined in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the EEA to other countries, including the United States, we ensure that a similar degree of protection is provided to your Personal Data as within the EEA by ensuring that the country that your Personal Data is transferred to is a country that the European Commission has deemed to provide an adequate level of protection for Personal Data as the EEA.

Entities located overseas will use the data in compliance with the APPs, GDPR and CCPA and Mythologi will take reasonable steps to ensure they comply with the APPs, GDPR and CCPA.

8. HOW WE KEEP YOUR PERSONAL DATA SAFE

We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to address any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Although Mythologi takes a range of security measures designed to protect your Personal Data, complete online and offline security can never be guaranteed, so you should always take care when sharing your information online.

A. SECURITY MEASURES AND RISK AGREEMENT

Your personal data is kept from disclosure in various ways (encryption, passwords). To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with an AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Except if your information is required to be retained by law, we will hold your information for as long as we require it to provide services to you, or until you notify us you no longer wish to hold your account, or for EU or California residents, until you request that we erase your data.

Personal information collected online is stored by Mythologi and/or service providers in databases protected by physical and electronic means of control, technologies of the access control system and other acceptable security measures. Despite this, such security measures cannot prevent all losses, malicious use or modification of personal data, and the Mythologi is not responsible for any damage or loss that result from such incidents.

You acknowledge, confirm and agree that the technical processing and transmission of information of the App may include the transmission of data through various networks, including via unencrypted communication channels of the Internet, which is never completely confidential and safe.

You also understand that any messages and/or information sent via Mythologi’s server may be unauthorizedly read and/or intercepted by third parties.

By using the App, you are aware and agree that the App may be subject to malfunctions and downtime due to which you may incur losses, Mythologi is not liable for any malfunction and subsequent loss of data and other consequences in case of malfunctions and downtime of the App.

By providing the data you agree to the processing, i.e. the implementation of any actions (operations) with the data provided.

You hereby consent to Mythologi’s provision of the transferred information to third parties, including those supporting our services, in the quantity necessary for such support and/or other persons; rights and responsibilities for access to relevant information are established by applicable law.

Your consent to the processing of the data provided is valid for an indefinite period and shall remain in effect until the time of its withdrawal in writing. Mythologi undertakes to terminate the processing of data in a reasonable time after receiving the relevant request.

9. HOW LONG WE WILL KEEP YOUR PERSONAL DATA

We keep your Personal Data for as long as we need to provide the App to you and fulfill the provisions of this Privacy Policy and our Terms of Use, as well as to comply with applicable law. This is also the case for anyone that we share your information with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you.

When removing Personal Data, we will take commercially reasonable and technically feasible measures to make the Personal Data irrecoverable or irreproducible.

10. YOUR RIGHTS AND CHOICES

The law provides you with quite a few rights when it comes to how we use your information. You may not be able to use all these rights, depending on the facts.

Access: You have the right to be told if we’re using your information and the right to request a copy of the information held about you together with certain information about how we use your information

Correction: You have the right to ask us to correct any information we hold about you which isn’t right or isn’t complete

Deletion: You have the right to ask us to delete or remove any information held about you where there’s no good reason for us to continue holding it or where you’ve objected to us using your information

Restriction: You have the right to ask us to limit how we hold your information, for example, to confirm its accuracy or our reasons for holding it

Objection: You have the right to object to us holding any information about you which is based on any of the good reasons we described above. You’ve also the right to object to us holding your information for marketing purposes

Portability: You have the right to receive or request that we transfer a copy of the information we hold about you where you’ve given consent to us using such information or we need to use your information as part of our agreement with you

Complaints: You have the right to complain to the ICO or, where you’re based outside the UK, any other EU authority in relation to how we collect and use your information

We won’t charge you anything to exercise your rights, although we’re allowed to do so in certain cases. Where this is the case, we’ll let you know.

We offer you choices regarding the collection, use, and sharing of your Personal Data, and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request on the App, you may not be able to access all of the features of the App.

11. CHILDREN

Users who are minors can use the App only if their parent or guardian has consented to their use of the App.

If a parent or guardian no longer consents to a minor’s access to or use of the App, the parent or guardian should delete the minor’s App account by contacting [email protected] , providing the email account details to request removal, and should delete the App by following the instructions of the App store from which the App was downloaded.

As contrasted with minors, who are individuals under the age of majority in their jurisdiction, we define “children” as follows:

Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.

Residents of other regions: anyone under 13 years old.

Mythologi does not knowingly collect or store any Personal Data from children under 13 in the United States or under the relevant age threshold in other jurisdictions where the child is located. However, we may collect technical information required for delivering the App and for the support of our internal operations from all users of the App, including collection of persistent identifiers to authenticate users of the App. If parents believe that we have unintentionally collected their children’s Personal Data or otherwise used their children’s Personal Data for another purpose, they may contact us by emailing [email protected] or sending written communication to 512-5333 avenue Casgrain, Montreal QC, Canada H2T 1X3

We recognize a special need to protect the personal information of children. We urge parents to instruct their children to never give out their real names, addresses, phone numbers, or other personal information without parental permission, when online. Mythologi also recommends that parents familiarize themselves with parental controls available on mobile telephones, tablets and other devices they provide to their child and accompany their child when online. Parents should contact Mythologi immediately if they have any concerns.

Parents have the right to review their child’s Personal Data; to have their child’s Personal Data deleted; and to refuse further collection, use, and/or disclosure of their child’s Personal Data by notifying us. If we learn that we have collected Personal Data of a child, and we do not have parental consent, we will take steps to delete such information from our files as soon as possible.

If you have questions about our privacy practices for children, please contact us at [email protected] or 512-5333 avenue Casgrain, Montreal Quebec, Canada H2T 1X3.

12. CHANGES TO THIS PRIVACY POLICY

Mythologi is constantly improving ways of collecting, storing and processing data, including the Privacy Policy. Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.

The continued use of the App after making such changes confirms your agreement with such changes.

13. THIRD PARTIES

In using the App, you may access links to websites and services that are owned or operated by third parties (each, a “Third Party Service”).

Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy, or security practices and policies of any Third Party Service.

To protect your information we recommend that you carefully review the privacy policies of all Third Party Services that you access.

14. DISCLOSURES SPECIFIC TO CALIFORNIA RESIDENTS

California law requires that we make certain disclosures about your data. As a California consumer, you have the right to tell us not to disclose or transfer your personal information to a third party in exchange for something of value. This is referred to as the right to tell us “Do Not Sell” your personal information, or your right to “Opt Out of Sale.”

We do not sell your Personal Data. The information listed in Section 4 falls under the following California Consumer Privacy Act (“CCPA”) categories: identifiers, Internet or other electronic network activity information, and inferences drawn from this information.

15. CONTACT US

If you have questions about our Privacy Policy or would like to otherwise contact us with respect to this Policy, you can email us at [email protected] or send us a written communication at 512-5333 avenue Casgrain, Montreal Quebec, Canada H2T 1X3.