Privacy Policy

ZA/UM STUDIO PRIVACY NOTICE

Last Updated: 31 July 2025

1. ABOUT US

1. 1 Welcome to the privacy notice for Zaum Studio Limited (a company registered in England and Wales under company number 12394671 with its registered office at Brickworks (Office 305) 37 Cremer Street, London, England, E2 8HD) (referred to in this privacy notice as “us”, “we”, or “our”). We are the controller and are responsible for your personal data.

1.2 We respect your privacy and are committed to protecting your personal data. This privacy notice will explain how your personal data will be looked after or used by us when you:

download, access or use our software products (including playing our games and apps);
access any of our websites, including https://discoelysium.com/ and https://zaumstudio.com/ (“Websites”); or
contact us or otherwise interact with us.

1. 3 Please take the time to read and understand this privacy notice in full before you use any of our websites or products.

2. PURPOSE OF THIS PRIVACY POLICY

2.1 This privacy notice aims to give you information on how we collect and process your personal data through your use of our games, our launcher application and our websites.

2.2 Our products and our website are not intended for, and should not be used by, anyone under the age of 18. We do not knowingly collect personal data from children.

2.3 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

3. THIRD-PARTY LINKS

3.1 Our games and websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Additionally, you may have purchased one of our products from a third-party platform.

3.2 We do not control this third-party content and are not responsible for their privacy statements. When you leave a platform operated by us, we encourage you to read the privacy notice of every third-party platform you visit.

4. DATA WE COLLECT ABOUT YOU

4.1 Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

4.2 We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data, such as your first name and last name;
Contact Data, such as your email address;
Profile Data, such as your unique installation-specific ID, user ID, and authentication ID;
Usage Data, meaning information about your interactions with and within a game, app or Websites, such as the date and time you accessed the game, the time you spend in-game, the time you spend on an element within a game, your interactions with other users in-game and analytics about your interactions and activity;
Technical Data, including your approximate geographical location, IP address, login data, information about the device you use to access our game, app or our Websites (such as your hardware model, operating system, mobile network information), unique device identifiers, IDFV, performance of our game, app and Websites including crash logs and diagnostics, other technology on the devices you use to access our game, apps or our Websites; and
Transaction Data, including details about payments to and from you, and other details of products and services you have purchased from us and your purchase history.

4.3 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users who use a specific game feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

4.4 We do not collect any special categories of personal data about you (which means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

5. IF YOU FAIL TO PROVIDE PERSONAL DATA

5.1 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our games, apps and our Websites, any updates or any additional content or services you have requested). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

6. HOW DO WE COLLECT PERSONAL DATA?

6.1 We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Profile and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. download a game;
2. make any purchases in-game;
3. give feedback or contact us directly, including through our official social media channels and support email addresses;
4. subscribe to our publications or marketing via our mailing list;
5. enter a competition, promotion or survey.
Automated technologies or interactions. As you interact with our games and our websites, we will automatically collect Usage Data and Technical Data about your equipment, actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
1. our platform partners such as the App Store and Google Play Store;
2. our payment providers; and
3. other third-party service providers we engage, such as for analytics services.

7.1 HOW DO WE USE YOUR PERSONAL DATA?

We will only use your personal data when relevant law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you, or to take steps at your request before entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party).
‘Legitimate interest’ means our interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we need to comply with a legal obligation to which we are subject.

7.2 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us without affecting the lawfulness of the consent provided prior to its withdrawal.

8. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

8.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

8.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To authenticate your access to a game and allow you access to a game and its features	Profile Data, Transaction Data	Performance of a contract with you
To process and deliver purchases in a game	Contact Data, Profile Data, Transaction Data	Performance of a contract with you Necessary for our legitimate interests (to enable and deliver content purchases)
To manage our relationship with you, including notifying you of updates or changes to our terms, asking for your feedback and directly responding to you when you contact us	Contact Data, Profile Data	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to provide support to you when requested to do so)
To prevent cheating, fraud, security breaches and other unauthorised activity in-game.	Profile Data, Technical Data, Usage Data	Necessary for our legitimate interests (for provision of the game, to run our business, for network security, to prevent cheating, fraud and other harmful behaviours in-game)
To administer and protect our business, websites and games (including troubleshooting, investigating complaints, ensuring compliance with our Terms of Use, data analysis, testing, system maintenance, support, reporting and hosting of data)	Contact Data, Profile Data, Technical Data, Usage Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) Necessary to comply with a legal obligation
To use analytics to improve our websites, our games, our marketing, our customer relationships and our experiences	Technical Data, Usage Data, Profile Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our games and websites updated and relevant, to develop our business and to inform our marketing strategy)
To deliver relevant content to you and measure or understand the effectiveness of the content we serve to you	Contact Data, Profile Data, Technical Data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

9. COOKIES

9.1 We use cookies and/or similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse and also allows us to improve your experience. Please see our Cookie Policy for more information on cookies and similar technologies and how we use these.

10. CHANGE OF PURPOSE

10.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

10.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

10.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. TRANSFERS OF YOUR PERSONAL DATA

11.1 We do not sell your personal information. However, we may disclose it to certain third parties for the purposes set out in the table in Section 8 in order to allow us to conduct our business activities and provide our games, our websites and other services to you, enforce our rights or to comply with legal or regulatory obligations. Such third parties include:

our group of companies (i.e. our subsidiaries, our ultimate holding company and its subsidiaries) who work with us in the development, sale and provision of the game based on our legitimate business interests;
suppliers and service providers who we engage to process data on our behalf, including Unity Technologies and the platforms we host our games and apps on such as Google Play;
in the context of a transaction: we may share your personal data with potential partners and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. This is on the basis of our legitimate interests for our business operations and the legitimate interests of third parties such as those in connection with the transaction.
regulators, government bodies, law enforcement agencies, and our legal and other professional advisors. This is on the basis of our legitimate interests for the establishment, exercise or defence of legal claims to protect our business.
In compliance with applicable legal and regulatory obligations: we may share your personal data with law enforcement agencies, courts, government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of a third party as legitimate interests.

11.2 We require all third parties we engage to respect the security of your personal data and to treat it in accordance with the law.

11.3 We are based in the United Kingdom and some of our external third parties are based overseas. Whenever we transfer your personal data out of the country where we collected it, we ensure an appropriate degree of protection is afforded to it by ensuring the safeguards required by data protection laws which apply to us are implemented. In these cases, we rely on approved data transfer mechanisms, including legal exceptions, adequacy decisions, recognised frameworks (e.g. the EU-US Data Privacy Framework), and standard contractual clauses. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards.

11.4 Please contact us if you want further information on the specific mechanisms used by us when we transfer your personal data.

12. SECURITY

12.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those 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.

12.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. RETENTION

13.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

13.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

13.3 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

14. YOUR LEGAL RIGHTS

14.1 In some situations, you can ask for access to your personal data, correct your data, delete your data, or object to our use of your data. If you wish to exercise any of those rights, please contact us using the contact details set out in Section 16 (Controller).

14.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

14.3 Subject to certain legal conditions, you may have a number of rights in respect of the personal information we hold about you. These include:

access: you have the right to request, free of charge, access to a copy of the personal information that we hold about you;
correction: you can ask us to change, correct, or complete any inaccurate, incomplete, or out-of-date personal information that we hold about you;
erasure: you can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
objection: you can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You can also object to our use of your personal information for direct marketing purposes;
restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it; and
transfer: In certain circumstances, you can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form; and
withdraw consent: If you have given us your consent to use your personal information (for example, for marketing purposes), you can withdraw your consent at any time without affecting the lawfulness of the consent provided before its withdrawal.

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

14.5 Please also be aware that not all of those rights are absolute and there may be circumstances in which we will not fully comply with your request because of a specified legal ground or exemption.

14.6 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15. COMPLAINTS

15.1 We encourage you to raise your concerns directly with us so that we can address them through our internal complaints escalation procedure. To do so, please contact us at privacy@zaumstudio.com, providing full details of your complaint. If you remain dissatisfied after this process, you may escalate the matter to our legal team, at legal@zaumstudio.com. We are committed to resolving any concerns promptly and transparently.

15.2 You have the right to lodge a complaint with the relevant data protection authority in your country of work or residence if you are not satisfied with the way your request was handled or are concerned about our privacy practices. The UK data protection regulator is the Information Commission, see www.ico.org.uk.

16. CONTROLLER

16.1 If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Zaum Studio Limited

Email address: privacy@zaumstudio.com

Postal address: Brickworks (Office 305) 37 Cremer Street, London, England, E2 8HD

16.2 Please contact us in the first instance if you have any issues regarding data protection or your personal data.

17. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

17.1 We keep our privacy notice under regular review and we may update this notice to reflect changes in our practices. Older versions of our privacy notice are available on request.

17.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by contacting us.