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Behaviour Digital Inc. – Privacy Policy

Version 1.0

 

BEHAVIOUR DIGITAL INC., its subsidiaries or affiliates (hereafter “BHVR”) respects your privacy and understands the importance of protecting your personal information. We will only collect information we need to fulfill your requests and our legitimate business objectives. We will never send you marketing communications without your consent, and we will never share your personal information with third parties that are not bound by our privacy policy unless you tell us we can.

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE ANY BHVR SERVICE.

If we amend this Policy, we will post the modifications on the Services or other places so that you can be fully informed. We reserve the right to modify this Policy at any time, so please review it frequently. Amendments affecting existing BHVR Services shall be effective thirty (30) days after posting. Your continued use of our Services will signify your acceptance of the changes to this Policy.

 


1. Introduction

BHVR respects the privacy rights of consumers and recognizes the importance of protecting the information collected about them. We have adopted this Privacy Policy to explain how we collect, store, use and share the information you provide us when you access BHVR’s websites, mobile sites and applications, online games, online functions of offline games and any other online functions controlled, accessed by BHVR as described herein (collectively, the “Services”).

 

2. What Is Personal Information And When Does BHVR Collect It?

 

A. Personal Information Collected By BHVR

 

“Personal Information” is information that identifies you and that may be used to contact you on-line or off-line, such your name, date of birth address, phone number, e-mail address or payment/billing information and any other information that is required by applicable law to be treated as Personal Information.

 

BHVR may collect Personal Information when you:

  • create a user account on the Services (an “Account”) or a public profile
  • shop at one of our online stores or purchase virtual items within a game,
  • create user generated content,
  • participate in interactive sections of the Services or watch advertisements within our Services,
  • sign up to receive a newsletter or other promotional content,
  • contact BHVR customer service or request technical support,
  • participate in a contest, sweepstakes, event or promotion,
  • participate in community forums or chat rooms,
  • apply for a beta tester position,
  • register a product online or download patches or demos.

 

Please note that, if BHVR combines non-personal information with Personal Information, BHVR will treat this information as Personal Information pursuant to this Policy

B. Personal Information Provided To BHVR by Third Parties

 

We may also receive Personal Information from third parties in connection with the operation and distribution of our website and online products as well as market and demographic studies that we use to supplement Personal Information provided directly by you. As with all other information, we use this data only for purposes consistent with this Policy.

 

3. What is Non-Personal Information and which Kind does BHVR Collect?

Non-personal information, alone, cannot be used to identify or contact you. BHVR collects non-personal information about your use of our website and online products.

When you use a BHVR Service, we may collect certain non-personal demographic information including gender, zip code, information about your computer, hardware, software, platform, media, mobile device. We also collect other non-personal information such as feature usage, game play statistics and scores, user rankings and click paths as well as other data that you may provide in surveys, via your account preferences and online profiles or through purchases, for instance. We may also receive either non-personal or public information from third parties in connection with market and demographic studies that we use to supplement personal information provided directly by you.

 

4.How Does BHVR Collect Personal and Non-Personal Information?

BHVR collects non-personal information and Personal Information when you actively provide it in the context of various online activities including online polls and marketing surveys, for instance. In addition, we might use IP addresses, cookies and other technologies to passively collect information:

 

a. IP Addresses.

An IP address is a number that may be assigned to your computer by your internet service provider to identify your computer every time you log on to the Internet. In general, we use log files to monitor traffic on our websites and to troubleshoot technical problems. In the event of user abuse of our websites, however, we may block certain IP addresses. If available, IP addresses and console IDs may be used to personally identify you in order to enforce our Terms of Use.

 

b. Cookies.

Cookies are small files applied to your Internet browser to track movements within websites. We may link cookie information to Personal Information. Cookies link to information regarding what items you have viewed. Also, we may use cookies to deliver content specific to your interest and to monitor website or game usage. Most browsers are automatically set to accept cookies whenever you visit a website. You can disable cookies or set your browser to alert you when cookies are being sent.

We may also use flash cookies, also known as “local shared objects,” on our sites that employ Flash technology. Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site. Flash cookies only collect data in the aggregate. Like normal cookies, Flash cookies are represented as small files on your computer.

Please note that this privacy policy covers the use of cookies by BHVR only and does not cover the use of cookies by any advertisers. For more information about cookies, please see http://www.allaboutcookies.org.

 

c. Analytic Metrics Tool And Other Technologies.

BHVR may also use its own proprietary analytic metrics tool and third party analytics technologies to collect non-personal information when you use our products and services, such as, device unique identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, product scores, product metrics and statistics, feature usage, advertising conversion rates, monetization rate, purchase history,  and other similar information.

 

d. Interest Based Ads.

BHVR may also use third party ad serving technologies that may collect information as a result of ad serving in the Services, and that may temporarily display advertisements on the Services and third party sites. The information collected and used for the interest based advertising may contain the following, without limitation: age and gender, number views of an advertisement, device unique identity or other device identifiers and settings, information about your use of the products and Services and other Internet sites (including third party web pages and mobile Internet sites) viewed by you (as well as date and time viewed), advertisement(s) served, the advertisement(s)’ in game location and length, and response to the advertisement(s) (if any).

 

5. What Happens To The Information BHVR Collects?

 

A. How BHVR Uses Your Information

 

BHVR may use your Personal Information and non-personal information to:

  • To provide and operate the Services and to process and complete any transactions in connection therewith;
  • To communicate with you and respond to provide customer service.
  • To monitor and analyze the Services usage and trends and otherwise measure the effectiveness of the Services or request feedback from you about the Services;
  • To send you confirmations, updates, security alerts, and support and administrative messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our administration and operation of, the Services;
  • To conduct surveys contests and sweepstakes;
  • To personalize and improve the Services and users’ experiences, to increase the functionality and user friendliness of the Services, to deliver advertisements, newsletters, coupons, promotions, rewards, awards or other content, or features that match user profiles or interests on the Services, and to provide recommendations as to other advertisements, content or features that may be of interest to users on the Services;
  • To provide you with news and information about our third party events, activities, offers, promotions, products, and services we think will be of interest to you;
  • For any other purpose as described in this Policy or for which we notified you the information will be collected, used and shared and/or received your consent.

In addition, if you choose to receive communications from us about BHVR products and news, the personal information you provide will allow us to send you messages about things including new features, enhancements, contests and events of interest. You may also later opt out of this service from BHVR.

 

B. Will BHVR Share My Information With Third Parties?

 

BHVR will never share your Personal Information with third parties without your consent. We may, however, share non-personal data in the aggregate (in a form that does not personally identify you) with third parties. You may also opt in to allow BHVR to share your Personal Information with companies and organizations that provide products or services that we believe may be of interest to you.

 

From time to time, BHVR may employ third party contractors to collect Personal Information on our behalf to provide email delivery, product, or promotional fulfillment, contest administration, credit card processing, shipping or other services on our Services. When requesting these services, you may be asked to supply your name, mailing address, telephone number, credit card information and email address to our contractors. We ask some third party contractors, such as credit agencies or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and to better meet our visitors’ needs and preferences.

 

When our third party contractors collect and/or have access to the Personal Information you provide to BHVR, BHVR requires that they adhere to our stated privacy policies and procedures and protect the confidentiality of Personal Information they collect or have access to in the course of their engagement by BHVR. These third parties are prohibited from using your Personal Information for any other purpose without your specific consent.

 

We may also disclose Personal Information to law enforcement, or the appropriate civil authorities to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on BHVR. Unless required by law, BHVR will not be required to notify you of any such disclosure.

 

6. Children under 13

BHVR’S SERVICES ARE NOT DIRECTED AT CHILDREN UNDER 13 YEARS OF AGE, NOR DOES BHVR KNOWINGLY REQUEST AND/OR COLLECT INFORMATION FROM CHILDREN UNDER 13. IF YOU ARE UNDER 13, PLEASE DO NOT SUBMIT ANY PERSONAL INFORMATION TO BHVR.

 

7. Where and How Long Is my Information Kept?

BHVR utilizes data storage facilities located in the United States.

Unless a different use/storage period is required by applicable laws and regulations, BHVR will use and store your Personal Information for a length of time necessary for the uses explained in this Policy.

 

8. How Does BHVR Protect Your Personal Information?

The security of your Personal Information is important to us. We follow generally accepted industry standards, including the guidelines developed by the Online Privacy Alliance and the US Federal Trade Commission to protect the Personal Information submitted to us, both during transmission and in storage against loss, misuse and alteration. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security.

ACCORDINGLY, BHVR DISCLAIMS AND DOES NOT REPRESENT AND WARRANT THAT IT WILL BE ABLE TO MAINTAIN YOUR PRIVACY OR THE SECURITY OF ITS DATA IN REGARD TO YOUR PERSONAL INFORMATION. OUR PRIVACY POLICY AND PROCEDURES ARE “AS IS” AND BHVR MAKES NO REPRESENTATIONS AS TO THE FITNESS FOR A PARTICULAR PURPOSE OR MERCHANTABILITY.

Please note, we will notify users of a data breach pursuant to applicable law. If you have any questions about security on our website, please contact us at LHHgame@bhvr.com.

 

9. Review, Correction Of Your Information, Requesting Removal From Mailing Lists And Deactivating Your Account

 

You can correct, update or delete your account information at any time by logging on the relevant Service and navigating to “My Account,” “View My Profile” or other account settings or contacting LHHgame@bhvr.com.

In addition, if for any reason you wish to question, view, correct or delete your Personal Information collected by BHVR please contact us at LHHgame@bhvr.com.

We will review, update or remove your information as appropriate. We may still retain your information in our files however, to resolve disputes, enforce our user agreement, and due to technical and legal requirements and constraints related to the security, integrity and operation of our Services.

Your request will be processed within thirty (30) days of the date of which we receive it.

 

10. Public Information Including User Generated Content, Online Forums, Blogs and Profiles

You may choose to disclose information about yourself in the course of contributing user generated content to BHVR Services, in public online chat rooms, blogs, message boards, user “profiles” for public view or in similar forums in our Services. Information that you disclose in any of these instances is public information, and as such there is no expectation of privacy or confidentiality towards them.

You should be aware that any personally identifiable information you submit in the course of these public activities can be viewed, collected, copied and/or used by other users of these instances without your consent, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these instances.

If you post a video, image or photo on one of our Services for public view you should be aware that these may be viewed, collected, copied and/or used by other users without your consent. We are not responsible for the videos, images or photos that you choose to submit to BHVR’s Services.

 

11. Third Party Sites

BHVR Services may contain advertising or services which link to other websites such as Twitter, Facebook and YouTube. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third party site, including on an advertisement, you will leave the BHVR Services you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as BHVR. If you visit a third party website that is linked to a BHVR site, you should consult that site’s privacy policy before providing any personal information.

 

12. Products Offered In Partnership with Third Party(s)

Certain products and/or services available in our Services may be provided to you in partnership with third party(s) and may require you to disclose personally identifiable information in order to register for and access such products and/or services. Such products and/or services shall identify the third party partners at the point of registration. If you elect to register for such products and/or services your personally identifiable information will be transferred to such third party(s) and will be subject to the privacy policy and practices of such third party(s). We are not responsible for the privacy practices and policies of such third party(s) and, therefore, you should review the privacy practices and policies of such third party(s) prior to providing your personally identifiable information in connection with such products and/or services.

 

13. Your Consent Is Important To Us

It is important to us that where we collect, use or disclose your Personal Information we have your consent to do so. Depending on the sensitivity of the Personal Information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide or offer Services to you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to LHHgame@bhvr.com.

 

14. BHVR’s Terms of Use

The terms of this Policy are incorporated into our Terms of Use which you can review at http://event.lhhgame.com/terms_of_use/. All terms in capital used in this Policy have the meaning as those defined in the Terms of Use located at http://event.lhhgame.com/terms_of_use/.

 

15. Contact Information

If you have questions or concerns regarding this Policy, you should contact BHVR at LHHgame@bhvr.com.

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