Privacy Policy

Introduction

4AI Limited ("4AI Limited", "we", "our", or "us") is committed to protecting your privacy and to complying with applicable data protection laws. This Privacy Policy explains how we collect, use, and safeguard your information in two distinct contexts:

(1) when you visit or interact with our Universe3D website and any other online properties that link to this Privacy Policy (together, the "Website"), and

(2) when you use applications powered by Universe3D technology that we develop and publish (the "Universe3D-powered Apps" or "Apps").

Universe3D is a common brand and technology used across multiple Apps. Currently, this includes Album3D and "PlanetMars3D: Spirit Mission" (including demo versions of those Apps where offered). This list may not be exhaustive and we may release additional Universe3D-powered Apps in the future.

For the avoidance of doubt, where a section below is labeled "Website" it applies only to use of our Website. Where a section is labeled "Universe3D-powered Apps" it applies only to use of our Apps. General sections (for example "Data Security" and "Your Rights") apply to both, unless stated otherwise.

Website - Information We Collect

When you use our Website, we may collect the following categories of information that you provide directly to us or that are collected automatically:

• Email address (for example, when you subscribe to our newsletter or contact us).
• Name and message content (when you contact us through our contact form).
• Technical and usage data related to your visit (such as IP address, browser type, pages viewed, and interactions with the Website), collected via cookies and similar technologies.

Website - How We Use This Information

We use Website-related information for the following purposes:

• To operate, maintain, and improve the Website.
• To respond to your inquiries and provide customer support.
• To send you updates about our services and platform availability (where permitted by law and your preferences), including optional newsletters where offered.
• To monitor aggregate usage, analyze performance, and optimize user experience.

Website - Cookies and Tracking

We use cookies and similar tracking technologies on the Website to operate the site, improve your browsing experience, and understand how the Website is used. You can control cookie preferences through your browser settings and, where offered, through any cookie preference tools on the Website.

Third-Party Services

In connection with the Website, we may use third-party service providers (for example, analytics providers, email delivery services, or hosting providers). These third parties may process personal data on our behalf and only in accordance with our instructions and applicable data protection law. They are not permitted to use your information for their own independent purposes.

If you have questions about our use of third-party providers in relation to the Website, you can contact us using our contact form.

Universe3D-powered Apps – Information We Process

Universe3D-powered Apps may be distributed via third-party platforms (for example Steam) and are designed with privacy by default. In connection with your use of our Apps, we process the following categories of information, to the extent they are actually made available to us through the relevant platform (where applicable) or your use of the App:

• Local content. Content you load, create, or manage within an App (for example, files stored on your device) is generally processed locally on your device to provide the App's functionality. We do not upload or store your personal files on our own servers unless the App explicitly provides an online feature that requires doing so.
• Configuration and save data. App preferences, progress, and similar configuration or save data are stored locally and may optionally be synchronized via platform cloud services (for example Steam Cloud), depending on the App and your platform settings.
• Platform account identifiers and entitlements. Where an App integrates with a distribution platform's developer APIs (for example the Steamworks API), we may receive limited information associated with your platform account that is necessary to operate the App, such as a platform user identifier, confirmation that you own the App, in-App entitlements (for example credits balance or purchased add-ons), achievements, and other App statistics needed to provide core functionality and customer support.
• In-app purchase and transaction information (where applicable). If an App offers in-App purchases via a third-party platform, the financial transaction is processed by that platform. We do not receive your full payment card details. We may receive non-financial transaction information, such as the type of product purchased, time of purchase, relevant transaction or order identifiers, and updated entitlement information, in order to deliver your purchase, maintain your in-App balance, prevent fraud, and comply with accounting or legal obligations.

Universe3D-powered Apps typically do not require you to create a separate in-App account. Where an App is accessed via a third-party platform, you use your existing platform account via that platform's authentication services. Registration and login credentials you provide to the platform are submitted directly to and controlled by that platform; we do not receive or store your platform password and only receive limited account information as described above.

If you choose to contact us through an App (for example through optional feedback, support, or bug-reporting features), we will process the information you provide only for the purpose of responding to your request and improving the App, in line with this Privacy Policy.

Universe3D-powered Apps – Relationship with Steam / Valve

Some Universe3D-powered Apps may be made available through the Steam platform. Valve Corporation ("Valve") is an independent controller for the personal data you provide to Steam and processes that data in accordance with its own terms and privacy documentation, including the Steam Privacy Policy available at https://store.steampowered.com/privacy_agreement/.

According to Valve's published information, Steam may make certain information relating to your Steam User Account available to developers through the Steamworks API. We refer you to Steam's own documentation and privacy policy for a complete description of what data Steam collects and how it is used. For Universe3D-powered Apps, we only use the subset of Steamworks data that is necessary to:

• verify that you own the relevant App and are entitled to access it;
• deliver, restore, and support in-App purchases of credits and add-ons (where applicable);
• synchronize your App-related progress, settings, and entitlements (for example via Steam Cloud, achievements, or leaderboards, where implemented);
• detect and prevent fraud or abuse and ensure the integrity of the App.

Steam's Web API Terms require developers who access non-public Steam data to maintain and comply with a privacy policy describing how such data is used. This Privacy Policy is intended to meet that requirement for our Universe3D-powered Apps that access non-public Steam data. We do not use Steam-provided data for unrelated marketing and we do not sell your personal data.

Data Security

We implement appropriate technical and organizational measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. While no security measures can guarantee absolute protection, we aim to ensure a level of security appropriate to the risk.

Legal Bases for Processing (Additional Information for EEA/UK Users)

Depending on where you are located, different data protection laws may apply to our use of your personal information. In particular, where the General Data Protection Regulation ("GDPR") or equivalent data protection laws in the United Kingdom or European Economic Area apply, we process personal information on one or more of the following legal bases. We describe these legal bases here in particular for users in those jurisdictions, but we apply the same underlying principles to our processing of personal information for all users worldwide, subject to applicable local law.

• Performance of a contract. To provide and support the Website and our Universe3D-powered Apps, including processing information that is necessary to operate those services, respond to your requests, verify entitlements via distribution platforms (where applicable), and deliver in-App purchases.
• Legitimate interests. To operate, secure, and improve our services; to prevent fraud, cheating, or misuse; to understand how our Website and Apps are used; and to respond to your inquiries in a way we believe does not override your rights and freedoms.
• Compliance with legal obligations. To comply with record-keeping, tax, accounting, and other legal or regulatory obligations that may apply to us.
• Consent. Where required by law, for example for certain marketing communications or non-essential cookies on the Website. Where we rely on your consent, you may withdraw it at any time as described below.

Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. The appropriate retention period depends on the nature of the data, the services involved, and the applicable laws.

For example, contact information and correspondence you send via the Website may be retained for as long as needed to respond to your request and maintain an accurate record of our communications. Non-financial transaction records and in-App entitlement data (where applicable) may be retained for as long as you have access to the relevant content and for a subsequent period where we are required to keep records for tax, accounting, or dispute resolution purposes. Basic technical logs may be retained for a limited period for security, troubleshooting, and analytics purposes.

International Data Transfers

Depending on your location, your personal information may be processed in countries other than the country in which you are resident. This includes processing by our hosting and service providers and other third parties who support the Website and our Universe3D-powered Apps (including, in some cases, distribution platforms such as Valve/Steam).

Where required by applicable law, we will ensure that any international transfers of personal information are subject to appropriate safeguards, such as adequacy decisions of the European Commission or the use of standard contractual clauses or equivalent mechanisms, so that your information remains protected in accordance with applicable data protection laws.

Children's Privacy

The Website and our Universe3D-powered Apps are not directed to children under the age of 13 (or any higher age required by law in your jurisdiction for digital consent), and we do not knowingly collect personal information from such children. Where an App is distributed via a third-party platform, that platform may impose its own age-related requirements on account holders, and we may rely on those measures for access to the App.

If you are a parent or guardian and believe that your child has provided us with personal information in relation to the Website, please contact us using the details below so that we can take appropriate steps to review and, where appropriate, delete that information.

Your Rights

Depending on your location and applicable law, you may have some or all of the following rights in relation to your personal information:

• To request access to the personal information we hold about you.
• To request correction of inaccurate or incomplete information.
• To request deletion of your personal information, subject to legal or contractual obligations that require us to retain certain data.
• To object to or request restriction of certain processing activities, including direct marketing, where applicable.
• Where provided by law, to request that we provide certain personal information to you or a third party in a structured, commonly used, and machine-readable format (data portability).
• To withdraw consent where we rely on your consent (for example for certain communications), without affecting the lawfulness of processing based on consent before its withdrawal.
• To lodge a complaint with a supervisory authority or other regulator where you believe we have infringed applicable data protection laws.

To exercise your rights in relation to personal data we control, please contact us using our contact form or by using the contact details provided on this Website.

To exercise rights in relation to data controlled by third-party platforms or service providers (for example, app stores or distribution platforms), please refer to their own support and privacy tools.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or applicable laws and regulations. When we make changes, we will revise the "Last updated" date at the top of this page and, where required by law, provide additional notice or obtain your consent.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information in connection with the Website and our Universe3D-powered Apps.

Contact Us

If you have any questions about this Privacy Policy or how we handle your personal information, or if you would like to exercise any of your rights, you can contact us using our contact form or by writing to:

4AI Limited
128 City Road
London, EC1V 2NX
United Kingdom