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Game Privacy Policy

Starship Troopers: Extermination Privacy Policy

Last Updated: October 6, 2023

This Privacy Policy relates to [Starship Troopers: Extermination] (the “Game”). The Game is developed by Offworld Industries Ltd. (“Offworld”, “we”, “us”, “our”), and is hosted and operated by us and/or our third party game server hosting provider(s). We address this Privacy Policy to every individual who plays our Game (“Player”, “you”, or “your”) to convey how we collect, use, store, transfer, disclose, or otherwise process personal information we have collected from you when you access or play our Game. For visitors to our website, https://www.offworldindustries.com/ (“Website”), we have a separate privacy policy that is intended to inform you how we collect, use, store, transfer, disclose, or otherwise process personal information through our Website or in your correspondence with us through our Website. We invite and strongly encourage you to carefully read this Privacy Policy and the privacy policy on our Website. If you reside in California, please also see our California Consumer Privacy Act (CCPA) Notice at Collection further below for additional information we are required to provide to you under California law. If you reside in Virginia, please also see our Virginia Addendum further below for additional information we are required to provide to you under Virginia law. If you are in the European Union (“EU”), European Economic Area (“EEA”) or the United Kingdom (“UK”), please also see our EU/EEA Addendum further below for additional information regarding the processing of your personal information.

IMPORTANT NOTICE

We do not knowingly collect or process any personal information from individuals under the age of majority or anyone who does not understand or agree to this Privacy Policy. This Game is not directed to any person under the age of majority. If you are under the age of majority in the province, state or country from which you wish to access and play this Game, or do not understand or agree to this Privacy Policy, we kindly ask you not to use our Game, and to not disclose or communicate any of your personal information to us (any information that would allow you to be personally identified). If we are made aware that we have unknowingly collected any personal information from a minor, and are asked to erase such information from our database, we will do so without undue delay. By accessing or playing our Game, and by sharing any of your personal information through our Game, you agree to this Privacy Policy and represent and warrant to Offworld that you have reached the age of majority in the province, state or country from which you are accessing and playing this Game. If you do not understand or agree to this Privacy Policy or are a minor, please do not access or play our Game.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended from time to time. The most current version of our Privacy Policy will be marked with the “Last Updated” date listed at the top of this Privacy Policy.

WHAT PERSONAL INFORMATION WE COLLECT FROM YOU

From time to time, we may collect personal information from you when you play our Game, whether your personal information is volunteered to us in the context of our Game or we need to collect your personal information for the purpose of operating the Game. We may collect the following personal information from you:

PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL INFORMATION

We may collect, use, store, transfer, disclose or process your personal information for the following purposes:

The purposes listed above are a reasonably necessary part of your relationship with us.

TRANSFERS AND DISCLOSURES OF PERSONAL INFORMATION

Your personal information may be stored, used, or processed by us, our affiliates or our service providers (e.g. Google Analytics and Microsoft Playfab), in support of the Game, using resources and servers located outside of the country in which you access the Game, or in jurisdictions outside Canada. This means that personal information we collect from you in one country could be transferred, used, stored, communicated or otherwise processed outside of that country to allow third parties to perform functions on our behalf, for the purposes described within this Privacy Policy. As a result, such jurisdiction’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws, which may differ from terms in this Privacy Policy. Whenever we hire other organizations to provide support services, they will be required to conform to our privacy standards. Service providers we use may be located in Canada, the United States, the United Kingdom, the European Union and/or other jurisdictions, and may have servers located in multiple jurisdictions.

SECURITY AND RETENTION

We take steps intended to protect the security and confidentiality of your personal information. We protect the personal information within our custody or control with appropriate organizational, technological and physical safeguards. Our security measures include restricted access to records and data processing equipment, password protocols, and encryption and security software. We only retain personal information for as long as is necessary for the purpose for which it was collected. When we are no longer required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold.

RIGHTS TO YOUR PERSONAL INFORMATION

In some jurisdictions, you may have the right to access personal information that we currently hold about you, request to rectify or correct your personal information, and withdraw your consent to our collection and use of your personal information. For more information about how you can exercise any of these rights, please do not hesitate to contact us using the contact information provided below.

ANTI-SPAM

Where applicable and required by applicable laws, we will seek your express consent to send you communications in electronic form, including by way of commercial electronic messages. Please contact us at privacy@offworldindustries.com if you have any questions. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message. Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes as permitted by applicable laws. For example, we may contact you to provide communications you have consented to receive about products or services we provide to you, or communications that form part of our existing business relationship with you. We may also contact you in response to any inquiries or requests you submit to us using contact details herein. By accessing or playing our Game, you acknowledge and agree that you will not use the Game, or any functionalities contained therein to transmit unsolicited marketing communications, harassing or hateful content, or for any illegal activities in Canada, its provinces, or anywhere else in the world.

CONTACT US

If you have any comments, questions, or concerns related to the contents of this Privacy Policy or our information practices on our Website, please do not hesitate to contact our Privacy Officer using the contact information provided immediately below:

Privacy Officer,
Offworld Industries Ltd
privacy@offworldindustries.com

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE AT COLLECTION – STARSHIP TROOPERS: EXTERMINATION

These additional disclosures supplement the Privacy Policy above and apply to you only if you reside in California. These disclosures do not reflect our practices where an exception applies under the California Consumer Privacy Act of 2018 or its regulations (“CCPA”).

Please see “WHAT PERSONAL INFORMATION WE COLLECT FROM YOU” above for information about the categories of personal information that we collect from you when you play our Game. These categories correspond with the following categories listed in the CCPA’s definition of personal information:

We only collect sensitive personal information, as the CCPA defines this term, if you voluntarily disclose it to us. Please see “PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL INFORMATION” above for information about the purposes for which we use your personal information. We do not “sell” or “share” (as the CCPA defines these terms) personal information about you. We retain each of the categories of personal information collected under this Notice at Collection as long as necessary to fulfil the purposes for which it was collected and comply with applicable legal requirements, in accordance with this Privacy Policy, per “SECURITY AND RETENTION” above.

Please find our CCPA Privacy Policy, which includes additional information about how we process California residents’ personal information and California residents’ privacy rights, here: [http://www.offworldindustries.com/ccpaprivacypolicy].

VIRGINIA ADDENDUM

These additional disclosures supplement the Privacy Policy above and apply to you only if you reside in Virginia. These disclosures do not reflect our practices where an exception applies under the Virginia Consumer Data Protection Act (“VCDPA”).

Please see “WHAT PERSONAL INFORMATION WE COLLECT FROM YOU” above for information about the categories of personal data that we collect, use, disclose and otherwise process when you play our Game. Please see “PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL INFORMATION” above for information about the purposes for which we process your personal data and the categories of third parties to whom we may disclose personal information. We do not sell personal data to third parties or process personal data for targeted advertising.

Under the VCDPA, Virginia residents have the following rights subject to applicable limitations:

If you are a resident of Virginia, you may exercise these rights by contacting us at the details under “CONTACT US” above. We may request information from you to verify your identity. If we decline to take an action regarding your request, we will inform you of this, including the justification for declining to take action and instructions on how to appeal the decision. We will inform you of any action or inaction taken in response to such appeal. If the appeal is denied, you may contact the Virginia Attorney General to submit a complaint.

EU/EEA AND UK ADDENDUM

In addition to the information provided in this Privacy Policy above, the information in this EU/EEA and UK Addendum below applies to users that are in the EU, EEA and UK. For the purposes of EU/EEA and UK data protection laws, Offworld Industries Ltd, privacy@offworldindustries.com, is the controller of the personal information that we collect from you or that you provide to us.

HOW WE USE YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR PROCESSING

We process your personal information for the following purposes and rely on the legal bases set out in the table below under EU/EEA and UK data protection laws to process your personal information; and the legal basis for processing your personal information:

The provision of your personal information may be necessary for the purposes of entering into a contract with us or to receive the products and/or services you request, or may otherwise be voluntary. However, if you do not wish to provide your personal information to us, we may not be able to: (a) provide the products or services you request, or (b) tell you about other products and services that we offer.

TRANSFERS OF YOUR PERSONAL INFORMATION

If you are located in the EU/EEA or UK, your personal information may be transferred outside of the jurisdiction in which you are located. We may transfer your personal information to jurisdictions that are deemed as adequate for the purposes of EU/EEA and UK data protection laws, and where that is not the case we will ensure appropriate safeguards are in place in accordance with EU/EEA and UK data protection laws. For more information, please contact us at the details above (please see “Contact Us” above).

RETENTION OF YOUR PERSONAL INFORMATION

We only retain personal information for as long as is necessary for the purpose for which it was collected. When we are no longer required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold. To determine the period for which it is necessary to process and retain your personal information, we take into account the type of personal information collected, the purpose(s) for which the personal information was collected, the duration for which it is necessary to process that personal information for those purposes, and any legal, regulatory or other obligations that we may be subject to or applicable limitation periods for bringing or defending potential legal claims under applicable laws.

YOUR RIGHTS

Under EU/EEA and UK data protection laws, you have certain rights which we have summarised below:

You also have a right to lodge a complaint with a data protection authority in your jurisdiction: