Effective Date: May 20th, 2019

SQUANCH GAMES PRIVACY POLICY

Squanch Games, Inc., a Delaware corporation (“Squanch Games”, “we”, “us” and their derivatives), makes this policy available to users of our websites, including squanchgames.com and its subdomains (collectively, the “Websites”), the video games we publish and distribute, including Trover Saves the Universe™ and Doctor Splorchy Presents: Space Heroes™ (collectively, the “Games”, and, each, a “Game”), and other online services we may provide (collectively, with the Websites and the Games, the “Services”).

This policy describes how we collect, use, transfer, disclose, retain and dispose of users’ personal data. Note that certain key lowercase terms that are used but not defined in this policy (e.g., “personal data”, “controller”, “process”, “data subject”, etc.) have the meanings assigned in Article 4 of the European Union General Data Protection Regulation. To be clear, however, this policy applies to all users of the Services, no matter where they live.

This policy applies only to personal data we collect through the Services. It does not apply to any information that we collect offline or you provide to or is collected by any third party.

Please read this policy carefully, so you can understand our policies and practices regarding your personal data. If you don’t agree with our policies and practices, don’t use our Services. By using our Services—including the Websites—you consent to our practices with respect to personal data as described in this policy.

Children

We do not knowingly collect personal data from anyone under 16 years of age. Our Services are directed to people who are at least 16 years old. If you are under 16, don’t submit any information about yourself to us. If you become aware that a child under the age of 16 has provided us with personal information, please contact us at hi@squanchgames.com, so we may remove the information.

Personal Data We Collect and How We Collect It

Personal Data You Provide. We collect most Personal Data when you provide it to us directly. By way of example, when you sign up for a mailing list, enter a contest, complete a survey, or create an account, you may be required to choose a password and user identifier and provide your name, telephone number(s), email and/or street address, age, gender, an avatar, and preferences. In addition, we may acquire personal data from you when you contact us directly (e.g., via telephone, postal mail, social media interaction, email, SMS, MMS, or similar technologies). If you correspond with us electronically (e.g., via email or using a fillable form), we will retain records of our correspondence, including the contents of whatever was said, your email address, your name and any other information that you provide to us in connection with such correspondence.

Information from Third-Party Game Platforms. We may automatically receive your personal data from the third-party platforms (e.g., Steam, the PlayStation Store, the Epic Games Store, etc.) (each a “Third-Party Platform,” collectively “Third-Party Platforms”) through which you download and play the Games. The personal data we collect from a Third-Party Platform may include, by way of example, your name, the name of your account associated with the Third-Party Platform, and/or a list of your saved contacts with the Third-Party Platform (e.g., your “Steam Friends List”). Personal data collected by a Third-Party Platform is subject to each specific Third-Party Platform’s privacy policy (e.g., the Steam Privacy Policy Agreement, the Playstation.com Privacy Policy, and the Epic Games Global Privacy Policy). Information collected from Third-Party Platforms is used by us in accordance with the “How We Use Personal Data” section below.

Additionally, in connection with certain Games, Google Analytics provides us with aggregated anonymous analytics regarding the frequency and types of actions taken in the applicable Game. To be clear, Google Analytics does not provide us with information that could be used, including when aggregated with other information, to identify an individual user. In short, our use of Google Analytics in connection with certain Games does not provide us with any personal data that we could share with third parties. For additional information about Google Analytics, please the Google privacy policy that specifically concerns use of Google Analytics by third-party applications.

Analytics. If you browse our Websites, we may collect certain information about your use of our Websites. This information may include, without limitation, the number of page visits and duration, type of browser, etc. Some of this information, such as your IP address, may constitute personal data.

Personal data we collect about your use of the Websites may be collected through “cookies” and “web beacons”. Cookies are small files placed on the hard drive of your computer through your web browser that enable us to recognize your browser and capture and remember certain information. Web beacons (also referred to as “clear gifs”, “pixel tags”, and “single-pixel gifs”) are small electronic files that enable us, for example, to count users who have visited our pages and for other related website statistics. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Additionally, other online resources, such as Privacy Badger from the Electronic Frontier Foundation, are available that can help block certain automatic data collection technologies. Please note that, if you disable or refuse cookies or other automatic data collection technologies such as web beacons, some aspects of the Services may be inaccessible or not function properly.

Do Not Track Notice. Do Not Track (“DNT”) is a setting in a web browser that directs websites not to track your behavior. You can activate the DNT settings through most browsers. We do not track users across third-party websites, so we don’t respond to DNT signals.

Where Personal Data is Processed; Transfer of Personal Data

We’re based in the State of North Carolina in the United States of America. We may process and transfer your personal data in and to the United States of America and other countries, regardless of where you are. Note that the laws regulating the collection, use, and disposal of personal data vary from country to country, so applicable law in the country where your personal data may be processed may not be as comprehensive or strict as the laws of the country where you’re located.

How We Use Personal Data and Our Legal Bases for Processing It

We use personal data that we collect about you or that you provide to us:

  • To present the Services to you (e.g., when you play the Games, we may use personal data collected from the applicable Third-Party Platform in order to present the Games and their various features and functions to you);

  • To respond to direct inquiries from you;

  • To provide you with information, products or services that you request from us, including information and updates pertaining to goods or services that you order from us;

  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);

  • To improve the Services (e.g., by conducting demographic or aggregate studies for marketing, sales, planning, and business and product development);

  • To process transactions;

  • To respond to employment inquiries;

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

  • In furtherance of the purpose for which the personal data was collected (e.g., where applicable, to help us troubleshoot an issue you’re having with the Services or to add you to a mailing list);

  • For any other purpose with your consent; and

  • Where you have given us permission to do so, to send you news and marketing materials about our products or services, including special offers and promotions. 

Additionally, we reserve the right to merge or co-mingle anonymous, non-personally identifiable information about you, your offline and online behavior, and/or your device(s) (i.e., information that is not personal data), with your personal data for any lawful business purpose.

We rely on the following legal bases to process your personal data:

  • Your consent;

  • Compliance with applicable law;

  • Exercise of our legitimate interests in:

    • Providing the Games and enabling our users to play the Games, including with one another;

    • Providing customer service;

    • Improving our Services and business;

    • Reviewing job applications; and

    • Addressing legal issues.

  • Fulfillment of our obligations to users of our Services; and

  • Endeavoring to protect users of our Services.


Access to Personal Data by Contractors and Disclosure of Personal Data to Other Third Parties

We may give certain independent contractors access to information we collect, including personal data. These independent contractors may assist us with tracking use of our Services and the provision and improvement of the Services. Independent contractors that work for us and access and/or process personal data on our behalf are obligated to keep personal data confidential and use it only in accordance with our express instructions. We are not responsible for the conduct of any of our independent contractors.

Google Analytics

One of our independent contractors is Google Analytics. Google Analytics tracks and reports website traffic and monitors use of our Websites. Data collected may be shared with other Google services and used to target the ads of its own advertising network. It is our understanding that you can opt-out of Google Analytics tracking on our Websites by installing the Google Analytics opt-out browser add-on that prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.

Mailchimp

Another one of our independent contractors is Mailchimp. Mailchimp helps us manage our mailing lists and sends bulk e-mails for us. For information on Mailchimp’s use of personal data, please see Mailchimp’s Privacy Policy.

Squarespace

Squarespace hosts our Websites. All data that is collected through our Websites is collected by Squarespace’s systems. For information on Squarespace’s privacy practices, please visit Squarespace’s Privacy Policy.

We also may disclose personal data:

  • to our subsidiaries and affiliates;

  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Squanch Games’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Squanch Games pertaining to the users of our Services is among the assets transferred;

  • To comply with any court order, law, or legal process, such as responding to a government or regulatory request;

  • To enforce any contract we may have in effect with you such as our Terms of Service (available at http://www.squanchgames.com/terms); or

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

Your Data Subject Rights

We will promptly act on the request of any user of the Services that we:

  • Confirm that we have their personal data;

  • Provide them with access to their personal data, including in portable format, that we may possess;

  • Correct, update or amend their personal data;

  • Delete and “forget” their personal data; or

  • Limit our processing of their personal data.

You may always withdraw any consent to process your personal data you have provided us and object to our use or disclosure of your personal data. Exercise of any of the rights set forth in this section may not apply retroactively from the date a given request is made and doesn’t affect our ability to continue processing personal data in accordance with this policy and applicable law. The rights described in this section are subject to certain limitations and exceptions under applicable law.

If you’d like to exercise any of your data subject rights concerning your personal data that we may possess, please reach out to us by email at hi@squanchgames.com. When you reach out, please put “Data Subject Access Request” in the subject line of the e-mail, and briefly describe the right or rights you intend to exercise. We may use your personal data to confirm your identity before acting on your request.

You will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. We ask that you contact us first, so we can try to address any concerns that you have about our privacy practices directly.

Data Security and Retention

We retain personal data for only as long as necessary to fulfill the purposes for which it was collected or provided, subject to certain exceptions as authorized by and where required under applicable law. We may pseudonymize, delete or take other measures to dispose of personal data. We may retain copies of personal data for additional time for business continuity purposes and for the purposes of creating backups.

We implement a variety of security measures to maintain the safety of your personal data when you use the Services. We offer the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted. Such information is only accessible by those authorized with special access rights to such systems and that are required to keep the information confidential, subject to any additional requirements imposed by our contract with them and applicable law.

Also, please keep in mind that the transmission of information via the internet is not completely secure. Although we have designed our Services with the protection of your personal data in mind, we cannot guarantee the security of your personal data transmitted through the Services. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes to this Policy

If we make any changes to this policy, we will post the revised policy on this page and, if the change is material, put a notice of the revision on the squanchgames.com homepage. You are responsible for periodically visiting this page to check for any changes. The date the privacy policy was last revised is listed at the top of the policy.

Contacting Us
If you have any questions regarding this policy or our privacy practices, you may contact us at hi@squanchgames.com.