Reversibility and Exports of the Club’s Data

1. Purpose

The Club may retrieve its data, switch to another provider, transfer it to its own system or request its erasure under the conditions of this annex. This annex supplements Articles 7, 11 and 17 of the Professional Agreement and implements the rules applicable to switching between providers of data processing services.

These guarantees are granted contractually to the Clubs using the service. They do not mean that the European Data Act applies without distinction to all customers worldwide or that Palarena opens its service in all countries.

A mere request for a copy does not terminate the subscription. A request to switch providers or for erasure with end of service is handled as such. The export intended for the Club does not replace players’ individual rights over their personal data.

2. Making a request

The authorized representative writes to contact@palarena.com, subject “Export” or “Switching providers”, indicating the Club, the step requested, the categories concerned, the recipient if any and the desired date. No commercial reason is required. Palarena verifies the authorization and organizes a secure transfer; it does not systematically ask for an identity document where the account’s means allow sufficient verification.

The Parties agree on a schedule, a recipient and a delivery channel. Palarena indicates the known dependencies and risks for the bookings, payments, passes and services still active. It cooperates with the Club and the destination provider to ensure the transfer and continuity within its scope of responsibility.

3. Time limits and continuity

The notice period before the start of a switch does not exceed two months from the request. An earlier date may be agreed. The transition is then carried out without undue delay, within a maximum period of thirty calendar days, with reasonable assistance, continuity of the contractual features and maintenance of security.

If this transition period is technically impossible to meet, Palarena informs the Club within fourteen working days of its request, explains the impossibility precisely and proposes an alternative period that does not exceed seven months. Continuity remains ensured during this period. The Club may extend the transition period once for a duration it considers suited to its needs.

A retrieval period of at least thirty calendar days follows the end of the agreed transition. The Club may then retrieve the data delivered without subscribing to the software again. This retrieval period does not reactivate the sale of new slots or a new commercial subscription. These time limits follow the framework of Article 25 of the Data Act.

4. Exportable categories

The export covers the input and output data, metadata and digital assets generated by the Club’s use of the service or directly related to it, to the extent that they exist and that the Club is authorized to receive them. An empty category is flagged as such. A restriction applies to the field concerned and does not make it possible to refuse the whole file.

The technical register describes the structures, fields, relationships, formats, units, date rules, versions and limits: https://palarena.com/en/legal/export-register/2026-09-13/. It is maintained online and accessible to the Club before subscription; its version is indicated in each delivery. It cannot reduce the legally exportable categories on the sole ground that a screen does not already expose them.

5. Formats, interfaces and delivery

Structured data is delivered in commonly used machine-readable formats, with the information necessary for its reuse. The original files are accompanied by an inventory; supporting documents for reading may also be provided in PDF. A PDF alone does not replace the structured data necessary for the migration.

Palarena makes available to the Club and the destination provider, free of charge, the open interfaces and their documentation necessary for porting and interoperability, under the arrangements described in the technical register. Access is limited to the Club and may be temporary, authenticated and revoked after transfer. An open interface does not imply public access to personal data or to the entire database.

The register indicates the applicable specifications or standards and the adaptations made within the legal time limits. The usual formats remain available where no relevant harmonized specification covers the service. Preparation and guidance may be provided manually without requiring the Club to purchase an export tool. This arrangement does not exempt Palarena from the technical obligations applicable to it. See Articles 26 and 30 of the Data Act.

6. Limits and dependencies

The following are not transferred:

• Palarena’s source code, its internal tools, proprietary algorithms and trade secrets, where they do not constitute exportable assets of the Club;
• the data of other Clubs, a player’s relationships with other Clubs and information whose transfer would unlawfully infringe the rights of third parties;
• keys, passwords, access tokens, full card data, reusable tokenized payment methods or security secrets;
• Palarena’s own internal security, infrastructure and fraud detection data, to the extent that their exclusion is justified; the facts necessary for the Club’s operations and rights are delivered in an appropriate form;
• data irreversibly deleted or anonymized before the request in accordance with the applicable rules.

These exclusions are interpreted strictly and must neither prevent nor delay the switch. A general reference to intellectual property or security does not make it possible to withhold the Club’s commercial data. Any concrete restriction is explained and a partial or redacted delivery is sought where this makes it possible to protect the rights concerned.

The Club’s Stripe account remains distinct from the Palarena service. The export of payment or pass references does not automatically transfer the Stripe agreements, bank mandates, payment methods or subscriptions to another solution. Taking them over requires the coordination of the actors concerned, the authorizations and the technical means required. Earlier refunds and disputes continue to be handled; no data or banking transaction is presented as migrated on the sole basis of an exported file.

Palarena does not guarantee that another software product will reproduce all of its functionality, its interface or its algorithms. It provides the elements and the assistance that fall to it, without requiring the disclosure of legitimate secrets or allowing this limit to deprive the right of exit of its substance.

7. Fees and end of the Agreement

Palarena charges no fee for the export, the reasonable switching assistance or the transfer of data provided for by this annex. The request adds no processing fee. The rights to exemption from charges arising from the regulation remain applicable.

The normal price of the service provided during preparation and transition is governed by the Professional Agreement; no renewal can extend the relationship beyond the end date resulting from the switch. Article 7 provides for a statement at the effective end date: pro rata of the days provided for the monthly plan; for the annual plan, valuation of the days provided at the reference monthly rate accepted at the time of the annual subscription, capped at the annual price paid, then refund of the balance. The limited recovery of the annual discount is the only particular economic consequence; no flat exit fee and no penalty surcharge is added. The trial remains free. Cases of non-performance attributable to Palarena and mandatory restitutions remain reserved. The details are provided and the balance due is returned within thirty days; a dispute over the statement does not block the switch or the retrieval.

For a migration, the service concerned ends when the switch has been successfully completed and this end is notified to the Club. If the Club requests erasure with end of service without transfer, the Agreement ends at the close of the agreed notice period, which does not exceed two months. These particular switching rules prevail over the end-of-period date applicable to an ordinary termination from the portal. The retrieval rights and the obligations relating to earlier operations survive for as long as they are relevant.

8. Deletion and residual retention

After a successful migration and the expiry of the retrieval period, Palarena erases the Club’s exportable data and digital assets, unless a later time limit is agreed or there is a legal obligation to keep only the documents concerned. Palarena communicates the categories kept, their legal basis, their period and the persons who can access them. They are archived outside routine use and are not used to recreate an active account or to continue marketing.

Backups follow their documented cycle; the applicable expiry date is communicated to the Club at the time of deletion. They are not reused as the live database after deletion; if a restoration is necessary, the erasures and restrictions already decided are reapplied before the service is brought back into operation. The deletion confirmation indicates any residual copies and their expiry date. No deletion necessary for an exit is announced as finished until it is.

9. Transparency and complaint

The information available on the infrastructure used and the general measures against incompatible international access to data is described at https://palarena.com/en/legal/service-providers/2026-09-13/ and in the technical register. Palarena communicates to the Club the locations and safeguards applicable to its data before subscription and keeps them up to date; the use of a European hosting provider does not amount to a guarantee that all third-party services process exclusively within the Union.

A difficulty with delivery, format, schedule or deletion is addressed to contact@palarena.com. Palarena explains the precise obstacles and seeks to resolve them; the Club retains the legal remedies before the competent authorities and courts.