Artificial.Agency Privacy Policy

Last Update: February 28, 2025

Artificial.Agency Inc. (“Artificial.Agency”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy (this “Privacy Policy”) to describe the manner in which we collect, use and disclose your personal information when you visit our Website located at https://www.artificial.agency/ (the “Website”), or otherwise interact with us.

Artificial.Agency is an artificial intelligence-powered behaviour engine that partners with game developers and studios, enabling them to embed runtime decision-making to deliver an individualized gaming experience for users (the “Services”).

This Privacy Policy does not apply to entities we do not own or control, including the game developers and studios with whom we have partnered. If you have any questions about such organizations’ use of your personal information in connection with our Services, please review the applicable privacy policy or directly contact them.

TABLE OF CONTENTS

• Collection and Use of Personal Information

• Information We Collect when You Visit Our Website

• Sharing of Personal Information

• Safeguards and Retention

• Your Choices

• Information about our Privacy Governance Policies and Practices

• Updates to this Privacy Policy

• Contact Us

COLLECTION AND USE OF PERSONAL INFORMATION

When providing the Services to our partners, such as game developers and studios (“Customers”), Artificial.Agency generally processes your personal information as a service provider (i.e., processor) on behalf of our Customers under the agreements we have entered into with them. In this situation, our Customers are the accountable entities (i.e., data controllers) and are ultimately responsible for the collection, use and other processing of your personal information. In other words, when we process your personal information through a Customer’s direction, our Customer is directly accountable to you in respect of the processing of your personal information. Should you have any questions about the processing of your personal information by a Customer, we encourage you to review the Customer’s privacy policy explaining how they process your personal information or reach out to them directly. See “Information we process as a service provider on behalf of our Customers”.

In other cases, such as when you visit our Website, apply for a job with Artificial.Agency, or otherwise communicate with us (e.g., when you sign up to receive newsletters from us), we collect, use and process your personal information on our own behalf as an accountable entity. We use the information we collect to improve the Website and Services, including to train and improve the models that are used to generate more personalized and interactive experiences for our Customers’ clients. We remove names, contact information and other direct identifiers from the information we use to train and improve our models. In such circumstances, we are ultimately responsible for the collection, use and other processing of your personal information. See “Information we collect and use on our own behalf as accountable entity (independent of our Customers)”.

Information we process as a service provider on behalf of our Customers:

We process personal information as a service provider on behalf of our Customers when you play a game which incorporates our artificial intelligence powered behaviour engine. We may receive information about your gameplay, including your interactions with virtual characters or the game environment. We process this information to interact with you and further enhance your gaming experience (e.g., to refer to you by your username or nickname in real-time during gameplay, or to provide you with a more personalized quest or virtual item).

Information we process on our own behalf as accountable entity (independent of our Customers):

We process personal information on our own behalf as accountable entity as follows:

• Visit our Website: You do not have to register to visit or use our Website. However, we may collect certain personal information when you visit our Website. Please see “Information we collect when you visit our Website” for detailed information regarding the personal information we collect when you visit and use our Website, and the choices you have with regards to that collection.

• Partnerships: When a potential Customer contacts us for partnership, we collect their name, email, company name, project name, and information about the Customer’s game (e.g., genre, product type, stage of production, etc.). We collect this information to determine suitability for partnership and to provide the Services.

• Customer Employees: When you work for one of our Customers, we collect information from you to administer that Customer’s account, including for billing purposes, such as name, email, phone number, company name, business title, and billing information (e.g., credit card number, expiration date, and security code).

• Book a Demo: If you contact us to request a demo of the Services, we will collect your name, email, phone number, country, company name, business title, organizational information, and any other information you choose to provide to us for the purpose of contacting you to facilitate your request and discuss how the Services can serve your needs.

• Marketing Communications: If you sign up to receive email, SMS and other marketing communications, we will collect your name, email address and phone number in order to send you newsletters, offers, promotions, and other information that may be tailored to your interests and preferences. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information provided under the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.

• If you receive marketing communications from a Customer, such communications are sent by the Customer, and your choice to unsubscribe from marketing communications sent by Artificial.Agency will not impact your communications preferences with that Customer. Should you wish to unsubscribe from communications sent by our Customer, please utilize the unsubscribe mechanisms offered in the communication sent by our Customer or otherwise contact our Customer directly.

• Attend an Event: If you attend one of our events or webinars (or visit a booth at an event), we may collect business contact information, such as your first and last name, company name, work email address and phone number. We collect this information so that we can communicate with you about the event or webinar and contact you about future events or webinars.

• Participate in a Survey or Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other research projects. We will collect certain personal information about you if you choose to participate in a research survey of ours. The information we collect will depend on the particular survey or research project and we will provide you with specific details regarding our information practices for that survey or research project prior to collecting any information from you. The information obtained through our surveys and research is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Website and Services.

• Contests or Promotions: When you enter a contest or participate in a promotion, we may collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you. We use this information to administer your participation in the contest or promotion. As part of a contest or promotion, we may obtain your consent to share or otherwise publish the content you submit.

• Apply for a Job at Artificial.Agency: In connection with an application or related inquiry for a job at Artificial.Agency, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information to process and respond to your application for current and future career opportunities at Artificial.Agency.

• Contact Us: When you contact us with a comment, question or complaint about Artificial.Agency through our web form, email or by phone, you may be asked for information that identifies you, such as your name, email address, and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment, question or complaint. We may retain this information to assist you in the future and to improve our customer service and products.

Separately, see “Receive Support Services” for information about the support services we provide to you on our Customers’ behalf.

INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITE

• Visiting Our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.

• Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.

• Analytics: We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en . You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

  • https://policies.google.com/technologies/partner-sites

  • https://support.google.com/analytics/topic/2919631

Third-Party Links: Our Website may contain links to other websites that Artificial.Agency does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

SHARING OF PERSONAL INFORMATION

Artificial.Agency does not, on its own behalf, sell, disclose or share your personal information with third parties without your consent, except for the following purposes or as required or permitted by law.

• Service Providers: Your personal information will be transferred or otherwise made available to certain third parties that provide services on our behalf (whether we are acting as an accountable entity or a service provider). We use service providers to provide services such as IT support, hosting the Website, storing data, providing customer and technical support, conducting analytics, processing payments, and providing advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We and our service providers may access, store and otherwise process personal information outside of Canada (including for residents of the Province of Quebec, outside of Quebec), including in the United States or other foreign jurisdictions, where we or our service providers are located.

• Legal and Compliance: We and our U.S., Canadian, and other foreign service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

• Sale of Business: We may transfer any personal information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Artificial.Agency or as part of a corporate reorganization or other change in corporate control.

SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We have measures in place that are designed to restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes of providing services to our Customers pursuant to our agreements with them or, with respect to the information we process on our own behalf as accountable entity, for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.

YOUR CHOICES

Marketing Communications

As indicated above, if you receive our email marketing communications from Artificial.Agency, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.

Your choice to unsubscribe from marketing communications sent by Artificial.Agency will not impact your communications preferences with our Customers. Please utilize the unsubscribe mechanisms offered in the communications sent by our Customers or otherwise contact our Customers directly.

Exercising Your Privacy Rights

We will take reasonable steps to ensure that personal information is not used unless it is accurate and up to date. We request that you regularly review the information you have submitted to us using the Website and promptly notify us if any information submitted is no longer accurate or correct.

Subject to exceptions under applicable law and depending on the jurisdiction in which you are based, you have the right to access, update, rectify and correct inaccuracies in your personal information, and to withdraw your consent to the collection, use and disclosure of your personal information in our custody or control.

You can exercise your rights in respect of personal information for which we are accountable (see “Information we collect and use on our own behalf as accountable entity (independent of our Customers)”) by emailing or writing to us using the contact information set out under “Contact Us” below. We may request certain personal information from you for the purpose of verifying your identity when you make such a request.

If we receive a request from you regarding the exercise of your rights in respect of personal information that we process on behalf of a Customer and for which our Customer is accountable (see “Information we process as a service provider on behalf of our Customers”), we will direct you to the relevant Customer and assist our Customer in responding, where possible.

INFORMATION ABOUT OUR PRIVACY GOVERNANCE POLICIES AND PRACTICES

We are committed to protecting personal information and have implemented a comprehensive set of policies and practices that govern our treatment of personal information. These policies and practices include:

• Policies and procedures, including safeguards, designed to protect personal information in our custody and control against loss or theft or from unauthorized access, use or disclosure;

• Processes to respond to data subject requests and complaints concerning the handling of personal information in a timely and effective manner;

• Policies and procedures to respond to privacy and security incidents, including practices pertaining to privacy training and awareness for our employees with access to personal information;

• A framework for the retention and destruction of personal information designed to ensure compliance with legal and contractual obligations, and to securely destroy personal information once no longer required;

• A designated Privacy Officer who is responsible for overseeing Artificial.Agency’s compliance with privacy legislation; and

• A framework that contemplates the roles and responsibilities of our employees with respect to the treatment of personal information in our custody and control.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Privacy Policy when it was most recently updated.

CONTACT US

If you have any questions or comments about this Privacy Policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, please contact us at: Data Team at Artificial.Agency datateam@artificial.agency

If you have any questions regarding the personal information we process on behalf of one of our Customers, we encourage you to first contact the Customer directly or review their applicable privacy policy.