Privacy Policy

Who we are

Supernova iQ is a free gaming analytics and AI coaching service operated by Rectech Gaming Pty Ltd (ABN 75 667 230 766), 29 Izett Street, Prahran, Victoria 3181, Australia — a subsidiary of 9RE Ltd (trading as 9 Realms Entertainment) (headquartered in Cyprus).

Rectech Gaming Pty Ltd is the data controller for the purposes of this Privacy Policy — which means we decide how and why your personal data is used.

If you have any questions about this policy or how we handle your data, contact us at: privacy@supernovaiq.com

1. What this policy covers

This Privacy Policy explains what personal data we collect when you use Supernova iQ, why we collect it, who we share it with, how long we keep it, and what rights you have.

It applies to everyone who uses Supernova iQ — wherever in the world you are based. Supernova iQ is currently provided entirely free of charge.

It sits alongside our Terms of Use, which govern your use of the service generally. Where those Terms reference this Privacy Policy, this document provides the detail.

We keep this policy updated. If we make material changes, we'll let you know — see Section 12 for details.

2. What data we collect and why

We only collect data we actually need. Here's a plain breakdown of what we collect, why, and what legal basis we rely on to process it.

Account data

When you create an account, we collect your name, email address, and password (stored in encrypted form). If you sign up via a third-party login (such as Google), we receive basic profile information from that service.

Why: To create and manage your account. Legal basis: Contract — we need this to provide the service you've signed up for.

Gameplay data from connected game accounts

When you connect a game account, you authorise us to retrieve your gameplay data — including match history, performance statistics, rankings, and related account data — through that platform's official API. The platforms currently supported are listed at supernovaiq.com/platforms.

Once retrieved and stored, we treat this data as your personal data held in custody on your behalf. You own it. We use it to provide the analytics and coaching features you've signed up for.

Why: To provide you with gameplay analytics and AI coaching insights. Legal basis: Contract — this is the core purpose of the service.

Important: we access game data through official developer APIs. We remain independently bound by those platforms' developer terms, which means there are things we cannot do with that data even if you ask us to. We'll always tell you if a request falls outside what we're permitted to do.

Usage data

We collect information about how you use Supernova iQ — which features you use, how often, what you click on, and how long you spend on different parts of the platform.

Why: To improve the service and fix problems. Legal basis: Legitimate interests — understanding how people use the platform helps us make it better, and this doesn't override your privacy rights.

Technical and device data

We automatically collect certain technical information when you use the service — your IP address, browser type, device type, operating system, and general location (country/region level, not precise location).

Why: For security, fraud prevention, and to ensure the service works properly on your device. Legal basis: Legitimate interests.

Communications

If you contact us by email or through the platform, we keep a record of that communication and your contact details.

Why: To respond to you and maintain a record of support interactions. Legal basis: Legitimate interests.

Loyalty and Wallet data

We record your Loyalty Coin balance (currently branded as Founder Runes — ᚨ Ansuz), transaction history, and how coins are earned or used within the platform.

Why: To operate the Wallet and loyalty program. Legal basis: Contract.

Cookies and tracking technologies

We use cookies and similar technologies on our platform. These are small files stored on your device that help us recognise you, remember your preferences, and understand how the platform is being used.

We use:

• Essential cookies — necessary for the platform to function (e.g. keeping you logged in). These cannot be switched off.
• Analytics cookies — to understand usage patterns and improve the service. You can opt out of these.
• Preference cookies — to remember your settings and customisations.

You can manage cookie preferences through your browser settings or our cookie preference centre at supernovaiq.com/policies/cookie-policy. Blocking essential cookies may affect your ability to use the service.

3. Who we share your data with

We do not sell your personal data. We only share it where necessary to provide the service, where you've specifically asked us to, or where we're legally required to.

Affiliated Brands

Supernova iQ is part of the 9 Realms group. If you choose to create an account with, or connect your Supernova iQ account to, an affiliated brand or service within the 9 Realms group, we may transfer your User Data to that brand — but only with your explicit consent.

How this works in practice: when you sign up with an affiliated brand, you'll be shown a clear notice telling you exactly which brand you're connecting with, what data will be shared, and what it will be used for. You'll need to actively consent before any transfer takes place. The affiliated brand's own Privacy Policy then governs how it uses your data once received.

You can revoke this consent and disconnect any affiliated brand at any time through your account settings or by contacting privacy@supernovaiq.com.

Service providers and sub-processors

We use trusted third-party providers to help us operate the service. These providers only process your data on our behalf and under our instructions. Our key sub-processors include:

• Microsoft Azure (Microsoft Ireland Operations Ltd, EU data centre) Cloud hosting and infrastructure — primary platform for storing and processing service data
• Payment processors (e.g. Stripe) Processing subscription payments
• Analytics tools Understanding platform usage patterns
• Email delivery services Sending account and service communications
• Customer support tools Managing support requests

A full list of our sub-processors is available on request at privacy@supernovaiq.com. We will notify you of any material changes to our sub-processor list.

Third-party game platforms

When you connect a game account, your authorisation is processed directly with that platform through their official API. Our currently supported platforms are listed at supernovaiq.com/platforms. We retrieve gameplay data on your behalf — we do not share your Supernova iQ profile data back to those platforms.

Legal requirements

We may disclose your data if required to do so by law, regulation, or a valid legal process (such as a court order). Where permitted, we'll notify you before complying with such a request.

Business transfers

If Rectech Gaming Pty Ltd or 9RE Ltd (trading as 9 Realms Entertainment) is acquired, merged, or its assets are transferred, your data may be transferred as part of that transaction. We will notify you in advance and ensure your rights are protected.

4. International data transfers

Supernova iQ is operated from Australia, but we serve users globally and use cloud infrastructure hosted in the European Union (Microsoft Azure). Your data may be stored or processed in countries other than your own, including Australia and EU jurisdictions.

If you are based in the European Economic Area (EEA) or United Kingdom, we ensure that any transfer of your data outside those regions is protected by appropriate safeguards. These include:

• Standard Contractual Clauses (SCCs) approved by the European Commission for transfers to non-adequate third countries;
• The UK International Data Transfer Agreement (IDTA) or UK Addendum to SCCs for transfers from the UK; or
• Transfers to countries that have received an adequacy decision from the European Commission or UK authorities.

For transfers to Australia specifically: the European Commission has not issued an adequacy decision for Australia. We rely on Standard Contractual Clauses for EEA-to-Australia transfers.

You can request a copy of the relevant transfer safeguards by contacting privacy@supernovaiq.com.

5. How long we keep your data

We keep your data for as long as your account is active or as needed to provide the service. When your account is closed, we delete or anonymise your data within [30] days, except where we need to keep it longer for a specific reason.

• Account data Duration of account + [90] days after closure
• Gameplay data from connected accounts Duration of account + [30] days after closure, or until you disconnect the game account
• Usage and technical data [13] months on a rolling basis
• Support communications [3] years from last interaction
• Loyalty Coin / Wallet records (Founder Runes) Duration of account + [7] years (financial records)

Where retention is required by law (e.g. financial records), we keep only the minimum necessary and restrict access to it.

6. Keeping your data secure

We take security seriously. The measures we have in place include:

• Encryption of data in transit (TLS) and at rest
• Access controls limiting who within our team can access personal data
• Regular security reviews and monitoring
• Secure, access-controlled infrastructure through Microsoft Azure (EU data centres)

No system is completely secure. In the event of a data breach that is likely to affect your rights or freedoms, we will notify you and the relevant regulatory authorities within the timeframes required by law — within 72 hours of becoming aware for GDPR and UK GDPR purposes.

If you believe your account has been compromised, contact us immediately at privacy@supernovaiq.com.

7. Your rights — all users

Regardless of where you are based, you have the following rights in relation to your personal data:

• Access your data You can ask us for a copy of the personal data we hold about you.
• Correct your data If any of your data is inaccurate or incomplete, you can ask us to fix it.
• Delete your data You can ask us to delete your data. We'll do this unless we have a legal obligation to keep it.
• Export your data You can ask for your data in a portable, machine-readable format to take elsewhere.
• Withdraw consent Where we rely on consent, you can withdraw it at any time. This won't affect anything we did before you withdrew.
• Opt out of marketing You can unsubscribe from marketing emails at any time using the link in any email, or by contacting us.

To exercise any of these rights, contact us at privacy@supernovaiq.com. We'll respond within 30 days. We won't charge you for reasonable requests.

8. Additional rights — EU and UK users (GDPR / UK GDPR)

If you are based in the European Economic Area or United Kingdom, the GDPR and UK GDPR give you additional rights and protections.

Additional rights

• Object to processing You can object to us processing your data based on legitimate interests. We must stop unless we have compelling legitimate grounds that override your interests.
• Restrict processing You can ask us to restrict how we use your data in certain circumstances (e.g. while a dispute is resolved).
• Object to automated decisions If we make a significant decision about you based solely on automated processing, you have the right to request human review.

Lawful basis summary

• Providing the service (account, gameplay data, wallet, loyalty) Contract — necessary to perform our agreement with you
• Sharing data with affiliated brands Consent — you actively opt in when connecting with each brand
• Improving the service and security Legitimate interests — balanced against your rights
• Complying with legal obligations Legal obligation

Article 27 GDPR — EU Representative

As Rectech Gaming Pty Ltd is established in Australia and not within the EU or EEA, we have appointed an EU representative in accordance with Article 27 of the GDPR. Our EU representative is authorised to be contacted by EU data subjects and supervisory authorities on our behalf in relation to matters arising under the GDPR.

EU Representative (Article 27 GDPR)

Katsis LLC

K Business Centre, 48 Spyrou Kyprianou Avenue

4154 Limassol, Cyprus

Email: demos@katsislaw.com

You may contact our EU representative directly for any matter relating to this Privacy Policy or your rights under the GDPR. The appointment of an EU representative does not affect your right to take action directly against Rectech Gaming Pty Ltd.

How to complain

If you're not happy with how we've handled your data, you have the right to complain to your national data protection authority:

• United Kingdom: Information Commissioner's Office (ICO) — ico.org.uk
• European Union: Your national data protection authority — a full list is available at edpb.europa.eu

We'd always prefer you contact us first at privacy@supernovaiq.com so we can try to resolve the issue directly.

9. Additional rights — California and US state users (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) give you specific rights over your personal information.

• Know The right to know what personal information we collect, use, disclose, and share.
• Delete The right to request deletion of your personal information, subject to certain exceptions.
• Correct The right to correct inaccurate personal information we hold about you.
• Opt out of sale or sharing The right to opt out of the sale or sharing of your personal information.
• Limit sensitive data use The right to limit our use of sensitive personal information to what is necessary to provide the service.
• Non-discrimination We will not discriminate against you for exercising any of your privacy rights.

Does our affiliated brand model constitute a 'sale' under CCPA?

Potentially yes, depending on the commercial arrangement. CCPA defines 'sale' and 'sharing' broadly to include transfers for commercial benefit, even without direct payment. Where our data sharing with affiliated brands meets that definition, California residents have the right to opt out.

To opt out: contact us at privacy@supernovaiq.com.

If you are resident in Virginia, Colorado, Connecticut, or another US state with applicable privacy legislation, you have similar rights under your state's laws. Contact us at privacy@supernovaiq.com to exercise them.

To submit a verifiable consumer request, contact privacy@supernovaiq.com. We will verify your identity before processing the request and respond within 45 days (with the option to extend by a further 45 days where reasonably necessary).

10. Australian Privacy Act

Rectech Gaming Pty Ltd handles personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Your rights under Australian law

• You have the right to access the personal information we hold about you (APP 12).
• You have the right to request correction of inaccurate, incomplete, or out-of-date information (APP 13).
• Before disclosing your personal information to overseas recipients (including affiliated brands or service providers located outside Australia), we take reasonable steps to ensure those recipients handle your information consistently with the APPs (APP 8).

Complaints

If you believe we have breached the Australian Privacy Principles, you can make a complaint to us at privacy@supernovaiq.com. We will acknowledge your complaint within [5] business days and aim to resolve it within [30] days.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

11. Children's privacy

Supernova iQ is not intended for anyone under 18 years of age (or the age of legal majority in your jurisdiction). We do not knowingly collect personal data from minors.

Users under 16 (or 13 in the United Kingdom) must not use the service without verifiable parental or guardian consent. If we become aware that we have collected data from a minor without appropriate consent, we will delete it promptly.

If you believe a minor has created an account, please contact us at privacy@supernovaiq.com.

12. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes — for example, changes to how we use your data or who we share it with — we will notify you by email and/or by a prominent notice within the platform at least [14] days before the changes take effect.

Non-material changes (such as clarifications or formatting updates) may be made without advance notice. The version date at the top of this document will always reflect when it was last updated.

Continued use of the service after the effective date of any updated policy constitutes your acceptance of the changes.