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November 14, 2025 by Veranika Liatkouskaya

Last updated: 06.11.2025

We care about your privacy and handle your personal data with transparency and care.

We created this Privacy Policy (the “Policy”) to help you understand what personal data we collect, why we collect it, and how we use and protect it whenever you interact with us.

We, XTEN Limited (“XTEN”, “we” or “us”), are the controller of your personal data, and if you have any questions, you can always reach out to us as described below.

1. WHO ARE WE, HOW TO CONTACT US AND WHAT DOES THIS PRIVACY POLICY COVER?</>

Throughout this Policy, XTEN means the company headquartered in Cyprus that provides the UFL Services.

In this Policy, “UFL Services” means:

(i) our console game UFL available on video game consoles and our PC game UFL available on game platforms and as a standalone version through the Websites, both of which link to this Policy (“Game”);

(ii) our mobile application UFL (“App”);

(iii) our websites, including uflgame.com, support.uflgame.com, and other XTEN-controlled websites (“Websites”); and

(iv) our Strikerz ID account system used to access certain UFL Services (“Strikerz account”);

(v) related products, services, and other online activities.

OUR CONTACT DETAILS:

Controller: XTEN Limited

Address: Office 701, 169 Archiepiskopou Makariou III, CEDARS OASIS TOWER, 3027, Limassol, Cyprus.

Email address: <a href="mailto:privacy@strikerz.inc">privacy@strikerz.inc</>

For questions about this Policy or your personal data, please contact us first.

You also have the option to contact our Data Protection Officer at <a href="mailto:dpo@strikerz.inc">dpo@strikerz.inc</>

2. HOW DO WE COLLECT PERSONAL DATA?

HIGHLIGHT: We may collect your personal data in three ways: (i) directly from you, (ii) from partners and service providers who help us run the UFL Services, and (iii) automatically when you use the UFL Services.

2.1. Personal Data You Provide.

We collect personal data that you directly provide to us when you enter it on the Website or include it in emails or other messages you send to us. This typically happens during business support processes, such as technical support. We may ask for information like your name, email address, date of birth or age group, and country if you participate in promotions, events, market research surveys, beta tests, or if you agree to receive marketing communications from us.

We may also ask you to verify your identity when you make a privacy request to exercise your rights, to comply with legal requirements and protect your personal data.

If you choose to complete surveys or participate in tests and contests, we will receive the information you voluntarily provide so we can contact you, enable your participation, and provide feedback or rewards.

2.2. Personal Data from Our Partners (Service Providers and Partners).

We may receive your personal data from our partners and service providers when you use the UFL Services.

Our game console partners share information with us to enable you to access and play the Game. This includes your user account and profile information, such as your username, account and online ID, chosen language, age or age group, and any parental control restrictions.

Our advertising and analytics service providers may share your advertising IDs and information about your device type, hardware model and settings, and unique device IDs. We receive this data only if you have previously agreed to share it with these providers for advertising and analytics purposes.

Social network platforms and streaming services may also share your account ID with us so we can grant rewards to winners or participants in our activities.

2.3. Personal Data Collected Automatically.

We also automatically collect certain data when you access and use the UFL Services.

This includes your approximate location based on your IP address and your device’s region or country, as well as your device type, hardware model and settings, device memory, unique device IDs, and system activity.

We may use cookies and similar technologies to collect some of this data. You can learn more about our use of cookies in our Cookie Policy, which is available in the footer of each of our websites.

3. HOW DO WE USE YOUR PERSONAL DATA?</>

HIGHLIGHT: We use your personal data only for specific purposes and only when we have a legal basis to do so: (i) Contractual Obligation, (ii) Legitimate Interest, (iii) Consent, or (iv) Legal Obligation.

We process personal data in compliance with the General Data Protection Regulation 2016/679 (GDPR), the Law 125(I)/2018 of the Republic of Cyprus, and other applicable data protection laws and regulations. We are transparent about our privacy practices and follow the principles of data minimization, purpose limitation, accuracy, and accountability.

For your convenience, we have grouped the personal data we collect into categories to make it easier for you to understand how and why it is used:

(i) General Identification Information: your game account ID, game console online ID or game platform online ID, Strikerz ID, username, your date of birth or age group (or age), any game console (or platform) account parental control restrictions, your in-Game clubs names, your advertising IDs, your external service account ID (e.g., Twitch or similar platforms).

(ii) General Location Information: location information derived from your Internet protocol address, approximate geolocation (region or country).

(iii) Contact Information: email address (including email of a parent or legal guardian, if applicable), postal address (for prize delivery), phone number (if needed for activities such as closed UFL testing or prize shipment), links or usernames to messaging apps or social media accounts provided for communication purposes (e.g. Discord, Twitch).

(iv) In-Game Statistics Information: your in-Game entitlements, achievements and scores, friends, events, session details, presence and player reviews, time spent in the Game, in-Game purchases and rankings.

(v) Device Information: your game console or platform type, hardware model and settings, device memory information, unique device IDs, system activity.

(vi) Game Performance Information: matchmaking, connection, error or crash reports.

(vii) Website and Advertising Interaction Information: data collected through cookies, pixels, and similar technologies on the UFL Websites, including cookie identifiers, advertising IDs, IP address, browser type, operating system, referring URLs, on-site interactions (such as page views, clicks, and session duration), engagement with advertisements, and other data related to users’ activity on the UFL Websites.

The table below provides a detailed breakdown of the categories of personal data we process, the purposes for such processing, and the corresponding legal bases, in accordance with applicable data protection laws:

Purpose of Processing: Execute an agreement between us; create and verify your Game account, Strikerz account, UFL Help Centre account, and clubs

Legal Basis: Contractual Obligation

Personal Information: General Identification Information, Contact Information, General Location Information and Device Information

Purpose of Processing: Execute an agreement between us and a minor under the age of digital consent or legal capacity; collect age information and obtain parental or guardian consent via verification tools (e.g., Kids Web Services or platform-based methods); create and verify the minor’s Game account, UFL Help Centre account, and clubs in compliance with applicable laws

Legal Basis: Contractual Obligation, Legal Obligation

Personal Information: General Identification Information, Contact Information, General Location Information and Device Information

Purpose of Processing: Provide the UFL Services to you, most importantly, allow you to play the Game, as well as access and use the App, Websites

Legal Basis: Contractual Obligation

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Allow you to create and access your Strikerz ID by using authentication features provided by third-party platforms

Legal Basis: Contractual Obligation, Consent

Personal Information: General Identification Information, Contact Information, General Location Information

Purpose of Processing: Display UFL leaderboards on the Website and in the Game based on various gameplay metrics

Legal Basis: Contractual Obligation, Legitimate interest to support fair competition and community engagement

Personal Information: General Identification Information and In-Game Statistics Information

Purpose of Processing: Ensure fair gameplay and protect the integrity of the UFL Services by detecting violations of our EULA, including implementing anti-cheat and monitoring measures through technologies developed by us (e.g., watermarking) or third parties (e.g., Easy Anti-Cheat)

Legal Basis: Contractual Obligation

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Process your customer support and privacy-related requests, and provide notifications about updates to UFL Services, features, or policies

Legal Basis: Contractual Obligation, Legal Obligation

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Provide customer support, including the delivery of product updates, patches, fixes, and other relevant notifications related to the UFL Services

Legal Basis: Contractual Obligation, Legal Obligation

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Enable multiplayer gameplay, team-based interactions, and fair matchmaking across various game modes in the Game

Legal Basis: Contractual Obligation

Personal Information: General Identification Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Hold and manage playtests, beta, or early access testing programs; collect your feedback; and provide rewards or recognition to participants or winners of these testing or promotional events

Legal Basis: Legitimate Interest to improve the UFL Services or Consent

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Continuously develop and improve the UFL Services by analyzing how you interact with them, identifying which features need improvement, and reviewing your feedback

Legal Basis: Legitimate Interest to improve the UFL Services or Consent

Personal Information: General Identification Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Comply with applicable legal obligations and regulatory requirements, and perform or enforce our contractual agreements

Legal Basis: Contractual Obligation, Legal Obligation

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Send you marketing communications, share updates about the UFL Services, and provide you with rewards, in-game content, or prizes as part of promotional campaigns or community events

Legal Basis: Consent

Personal Information: General Identification Information, Contact Information, General Location Information, In-Game Statistics Information, Device Information and Game Performance Information

Purpose of Processing: Manage and deliver advertisements within the Game or on third-party platforms, either directly or via external advertising partners

Legal Basis: Consent

Personal Information: General Identification Information, General Location Information, Device Information and In-Game Statistics Information

Purpose of Processing: Conduct retargeting activities to display personalised advertisements for the UFL Services on third-party platforms based on users’ interactions with the UFL Websites

Legal Basis: Consent

Personal Information: General Identification Information, Contact Information, General Location Information, Device Information, Website and Advertising Interaction Information

Purpose of Processing: Analyze and measure the performance and effectiveness of our marketing campaigns to help promote the Game and UFL Services more efficiently

Legal Basis: Consent

Personal Information: General Identification Information, General Location Information, Device Information and In-Game Statistics Information, Website and Advertising Interaction Information

4. HOW LONG DO WE STORE AND USE YOUR INFORMATION?</>

HIGHLIGHT: We keep your personal data only as long as needed for the purposes described above, unless the law requires or allows us to keep it longer.

The period we process your personal data depends on the type of data and how you interact with the UFL Services. We follow the principle of data minimization and keep your personal data only as long as reasonably needed, unless the law requires or allows us to keep it longer. We store your data only for the purposes described in this Policy, such as providing the UFL Services, fulfilling our contracts, protecting our legitimate interests, conducting audits, meeting legal obligations, resolving disputes, and enforcing our agreements.

When setting retention periods, we consider the minimum requirements under applicable laws, our contractual and legal obligations, and the possibility of litigation or similar proceedings. If you request the deletion of your personal data, we will verify and process your request within the timeframe required by law unless we have a legal right or obligation to retain the data for longer. This may happen if we need to defend against a legal claim or if a government authority requests the data, including for reasons of national security or public interest.

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?</>

HIGHLIGHT: We may share some of your personal data with partners who help us run the UFL Services. We cannot provide these services without them, but we ensure your personal data stays protected.

Here are the types of third parties that we may share your personal data with:

(i) Game consoles and PC platforms

Microsoft Corporation (USA) and Microsoft Ireland Operations Limited (Ireland).

Type: Game Console Platform.

Role: Controllers.

Data Collected and Purpose: game console account credentials for authorisation with the help of the platform.

Sony Interactive Entertainment Group of companies: Sony Interactive Entertainment, Inc. (Japan), Sony Interactive Entertainment LLC (USA), and Sony Interactive Entertainment Europe Limited (UK).

Type: Game Console Platform.

Role: Joint Controllers.

Data Collected and Purpose: game console account credentials for authorisation with the help of the platform.

Valve Corporation (USA).

Type: PC Platform.

Role: Controllers.

Data Collected and Purpose: PC platforms account credentials for authorisation with the help of the platform.

(ii) Service providers (data processors) that help us run and provide the UFL Services, help us analyze how the Services perform and help us spread the word about the Game, such as cloud storage providers, tracking and security service providers, business analytics, marketing and advertising partners.

Google LLC (USA)

Type: IT Infrastructure.

Role: Processor.

Data Collected and Purpose: all data for hosting the website on the Google Cloud Platform.

Google LLC (USA)

Type: Email communications tool.

Role: Processor.

Data Collected and Purpose: all data containing in the email communications.

Google LLC (USA)

Type: Analytical Tool.

Role: Processor.

Data Collected and Purpose: data concerning user interactions with the UFL Websites for website maintenance and development, retargeting activities, and measuring the effectiveness of advertising campaigns through Google Ads and related services.

Google LLC (USA)

Type: Authentication Service.

Role: Processor.

Data Collected and Purpose: identifiers and basic profile information (such as name and email address) used to enable account creation and access through third-party authentication (Sign-in with Google).

Squarespace Ireland Limited (Ireland)

Type: IT Infrastructure.

Role: Processor.

Data Collected and Purpose: all data for building and maintaining the website on the “zero coding” construction platform.

Usercentrics A.S (Denmark)

Type: IT Infrastructure.

Role: Processor.

Data Collected and Purpose: cookie files choices and settings for the CookieBot management tool.

Zendesk, Inc (USA)

Type: Communications and Customer Support.

Role: Processor.

Data Collected and Purpose: game console account credentials for authorisation, information provided in the customer’s request.

The Rocket Science Group LLC d/b/a Mailchimp (USA)

Type: Email communications tool.

Role: Processor.

Data Collected and Purpose: all data containing in the email communications.

SFDC Ireland Limited (Ireland)

Type: Analytical Tool.

Role: Processor.

Data Collected and Purpose: visualization of the data concerning interaction with the website of its visitors.

SurveyMonkey Europe UC (Ireland)

Type: Analytical Tool.

Role: Processor.

Data Collected and Purpose: information in the surveys for the Game and Services improvement.

Epic Games, Inc. (USA)

Type: Anti-Cheat tool “Easy Easy Anti-Cheat”.

Role: Controller/ processor.

Data Collected and Purpose: detection and prevention of cheating, fraud, or unauthorised behaviour within the game environment.

Kids Web Services Ltd (UK)

Type: age verification and parent consent management platform.

Role: Controller/ processor.

Data Collected and Purpose: verifying the identity of the parent or legal guardian of a child using the UFL Services.

Gamesight (USA)

Type: Analytics and Marketing.

Role: Processor.

Data Collected and Purpose: analytical and attribution data related to user interactions with the UFL Services for the purpose of measuring marketing performance and optimizing advertising campaigns.

Meta Platforms Ireland Limited

Type: Authentication Service.

Role: Processor.

Valve Corporation (USA)

Type: Authentication Service.

Role: Processor.

Data Collected and Purpose: identifiers and basic profile information (such as Steam ID, nickname, and email address, if available) used to enable account creation and access through third-party authentication (Sign-in with Steam).

Meta Platforms Ireland Limited

Type: Marketing and Analytics Tool.

Role: Processor.

Data Collected and Purpose: data related to user interactions on the UFL Websites for retargeting activities and measuring the effectiveness of advertising campaigns across Meta services and partner platforms.

Xsolla (USA), Inc.

Type: Payment Provider.

Role: Processor.

Data Collected and Purpose: payment provider for our UFL PC standalone version.

Guijin Distribution Kft.

Type: Technical Partner.

Role: Processor.

Data Collected and Purpose: technical partner for the standalone version available through the Websites, supporting application delivery, performance optimization, and service reliability.

(iii) Governmental or public authorities for the purposes of law enforcement, national security and other issues of public interest importance.

6. HOW DO WE TREAT CHILDREN’S PRIVACY?</>

HIGHLIGHT: The information below is for parents or legal guardians of children under the age of 13 or the age of digital consent in the child’s place of residence, whichever is higher.

We also recommend that anyone under 18, no matter where they live or what the local digital consent age is, first ask their parents or legal guardians to help them understand this Policy.

We build UFL Services with privacy by design and by default, aiming to keep them safe for users of all ages. We pay special attention to protecting children’s rights.

If we or our service providers identify that a user is a child, we will seek your permission to collect and process their personal data and to accept the terms and conditions of our agreements on the child’s behalf. We also encourage you to review and adjust parental control settings on your platform to help protect your child’s experience.

7. HOW CAN YOU CONTROL YOUR PERSONAL DATA?</>

<a></>HIGHLIGHT: We want you to stay in control of your personal data and can help you exercise your privacy rights.

You have privacy rights related to your personal data when using UFL Services. To exercise these rights, please submit your request through <a href="https://support.uflgame.com/hc/en-gb">the UFL Help Centre</> for the fastest processing.

You may also contact us at <a href="mailto:privacy@strikerz.inc">privacy@strikerz.inc</>. Please note that we may need to verify your identity before fulfilling requests submitted by email.

Here are the privacy rights you have regarding your personal data:

(i) Right of access and portability. You have the right to be informed which personal data about you we process, including the categories of personal data we have, where we receive it from, how and for which purposes we use it, who may have access to this information. You can also request a copy of the personal data we have about you, and we will provide it in a commonly used and machine-readable format.

(ii) Right of rectification. You have the right to have any inaccurate or outdated personal data about you corrected or updated. Some of the personal data may be additionally corrected or updated by you in your Game and club settings.

(iii) Right of erasure. You have the right to delete the personal data about you in the Game and the UFL Services. Please note that in case you send such a request, you will no longer have access to your Game account and clubs.

(iv) Right to restriction of processing. You have the right to restrict our use of your personal data in case you claim that we use inaccurate data or that we use your personal data unlawfully.

(v) Right to object to processing. You have the right to object to our use of your personal data when we process it on the basis of Consent, Contractual Obligation, or Legitimate Interest. Please note that in case such personal data is necessary to defend a legal claim, or under any other legally permitted exception, we will be able to continue to use it.

(vi) Right to withdraw your consent. You can withdraw your previously provided consent for our use of your personal data for the particular purposes. However, our processing of your personal data preceding such withdrawal will remain lawful.

(vii) Right to object to automated decision making. You have the right to know, whether we use any automated technologies, including profiling that can have significant impact on you, to object to such use of your personal data and to request a revision by a human. Currently we do not use such technologies.

(viii) Right to lodge a complaint. You can make a complaint against our processing of your personal data by contacting your local supervisory authority for data protection (if there is any in your place of residence). The residents of EEA, UK and Switzerland may find more details about their local supervisory authorities as follows:

<a href="https://edpb.europa.eu/about-edpb/board/members_en">EEA list of local authorities</>

<a href="https://ico.org.uk/global/contact-us/">UK: Information Commissioner's Office</>

<a href="https://www.edoeb.admin.ch/de/kontakt">Swiss Federal Data Protection and Information Commissioner</>

However, we encourage you to contact us directly using the details in the “Our Contact Details” section above so we can address your concerns first.

8. WHAT ARE THE INTERNATIONAL OPERATIONS YOU SHOULD KNOW ABOUT?

HIGHLIGHT: We use providers that operate globally to run UFL Services, which means your personal data may be processed abroad from your place of residence.

XTEN Limited is based in Cyprus, and we work with trusted providers worldwide to deliver and improve the UFL Services. This means your personal data may be processed in countries outside your place of residence, including the EEA, UK, Switzerland, the United States, or elsewhere. When we transfer your personal data internationally, we apply safeguards like the EU Standard Contractual Clauses, the EU-U.S. Data Privacy Framework, the UK International Data Transfer Agreement, the Swiss-U.S. Data Privacy Framework, and other approved mechanisms to ensure your personal data remains protected.

9. WHAT ARE OUR DATA PRACTICES FOR NON-EUROPEAN USERS?

HIGHLIGHT: We want all users to know their privacy rights wherever they live. Below is important information for users around the world as the UFL Services and community expand.

9.1. PRIVACY INFORMATION FOR U.S. USERS</>

This U.S. Privacy Information is part of our main Policy and applies to users in U.S. states that provide additional privacy rights under their laws. These states currently include California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia.

9.1.1. Notice at Collection

For a detailed overview of the types of personal data we collect and the purposes for which we use it, please see the section “HOW DO WE USE YOUR PERSONAL DATA?” in this Policy.

9.1.2. Sources of Personal Data

For the categories of sources from which personal data is collected, see the section “HOW DO WE COLLECT PERSONAL DATA?” in this Policy.

9.1.3. Disclosure of Personal Data

For the categories of third parties to whom personal data is disclosed, see the section “WHO DO WE SHARE YOUR PERSONAL DATA WITH?” in this Policy.

9.1.4. Privacy Rights

Users residing in certain U.S. states (as listed above) have specific rights over how their personal data is collected, used, shared, and processed. These rights are subject to applicable laws and may differ depending on the state:

(i) Right to Know/Access. You have the right to know what personal data we collect about you. This includes the categories of sources from which we collect your personal data, the purposes for which we collect, “sell,” “share,” or process it for targeted advertising, the categories of third parties with whom we share personal data, the types of personal data disclosed, and the specific pieces of personal data we hold about you in a usable format.

(ii) Right to Data Portability. You have the right to access your personal data in a portable format.

(iii) Right to Delete. You have the right to request that we delete the personal data we have collected from or about you.

(iv) Right to Correct. You have the right to request that we correct inaccurate personal data that we maintain about you.

(v) Right to Opt Out of Targeted Advertising, Sale, or Sharing of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” or “sharing” of your personal data.

(vi) Right to Request Categories of Third Parties. You have the right to request a list of the categories of third parties to which we have disclosed your personal data.

(vii) Right to Appeal. You have the right to challenge our decision if we decline to act on your privacy rights request. To do so, please contact us and let us know that you wish to file an appeal. We will review your appeal and provide a written response within 60 days, explaining our decision and any actions we have taken. If we deny your appeal, you can file a complaint with the relevant data protection authority or consumer protection agency in your state.

(viii) Right to Non-Discrimination. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise your rights. However, the exercising of the rights described below may result in a different price, rate, or quality/level of product or service where that difference is reasonably related to the impact the right has on our relationship with you or is otherwise permitted by law.

(ix) Right to Request Specific List of Third Parties (residents of Minnesota and Oregon only). You have the right to request a list of the specific third parties to which we have disclosed personal data.

(x) Right to Request Removal of Content (resident of California only). If you are a California resident under the age of 18 with a registered account, you have the right to request the removal of content you have publicly posted through the UFL Services.

(xi) Shine the Light Requests (resident of California only). Under California’s Shine the Light law, California residents may, once per year, request: (i) a list of the categories of personal data we disclosed to third parties in the preceding calendar year for their direct marketing purposes, and (ii) a list of the categories of third parties to whom such data was disclosed.

10. HOW DO WE SECURE YOUR PERSONAL DATA?

HIGHLIGHT: We work hard to keep your personal data safe and will let you know if something goes wrong.

We take the security of your personal data seriously. To protect it, we use trusted service providers, secure technologies, and strong internal practices, including regular staff training and device security. While no system is perfect, we work hard to prevent unauthorized access, loss, or misuse of your personal data. If we ever discover a breach that could affect you, we will notify you as required by law and take steps to keep your personal data safe.

11. HOW DO WE UPDATE THIS POLICY?

HIGHLIGHT: We update this Policy as needed and will let you know if changes could affect you.

We may update this Policy from time to time to keep it clear, accurate, and in line with changing laws or UFL Services. When we do, we will change the “Last Updated” date at the top. If any update could significantly affect you, we will let you know in advance, as required by law, and notify you by email or through UFL Services.