Effective Date: May 20th, 2019
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.
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 firstname.lastname@example.org, 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.
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.
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:
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.
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 email@example.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 you have any questions regarding this policy or our privacy practices, you may contact us at firstname.lastname@example.org.