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Blind Squirrel Games

Privacy Policy

(Last updated September 13, 2023)

Navigation

  • Introduction
    • Disclosure to California Residents
    • Information We Collect
    • Registration Information
    • Payment Information
    • Information Collected by Customer Support
    • Technical and Usage Information
    • Location Information
  • How We Collect Your Information
    • Communications Features
    • Cookies and Automated Information Collection
    • Other Sources
  • How We Use Information We Collect
    • To provide services pursuant to our contract with you
    • To pursue legitimate interests that are not outweighed by your privacy rights
    • To comply with statutory or legal obligations
  • Sharing your Information
    • Third Party Service Providers and Third Party Products and Services
    • Friends and Other Players
    • Safety, Security, and Compliance with Law
    • Sale or Merger
  • Our Policies Concerning Children
  • How to Control Your Information
  • Opt Out Options
    • Opting Out of Promotional Communications
    • Opting Out of Other Communications
  • Security of Your Information
  • Changes to Our Privacy Policy
  • Sharing your Information For Direct Marketing Purposes
  • Links to Other Sites
  • Responding to Do Not Track Signals
  • International Transfer
  • Contact Us

1. Introduction If you are here, you have reached us by visiting blindsquirrelentertainment.com, driftersthegame.com, or one of the other websites owned and operated by Blind Squirrel Entertainment (the “Site”), or by registering or installing any of Blind Squirrel Entertainment’s game offerings (the “Game” or “Games”), our content, events, applications, services, patches, updates, or tools, or by using any of our other online or offline services (collectively, the “Services”). Blind Squirrel Entertainment, Inc. (“Blind Squirrel”) is committed to protecting your privacy. This privacy policy explains our collection, use, disclosure, retention, and protection of your personal information, as well as your rights to your data under US and International Law, including but not limited to EU Directive 2002/58/EC and the EU General Data Protection Regulation (“GDPR”), Brazil’s Lei Geral de Proteção de Dados (commonly referred to as the “LGPD”), the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 (“CAN-SPAM”), the US Children’s Online Privacy Protection Act (“COPPA”), and the California Consumer Privacy Act (“CCPA”), and the choices you have associated with that data. We may refer to Blind Squirrel Entertainment, Inc. herein as “Blind Squirrel”, “we” or “us”. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service. Where we are required to identify a data controller pursuant to regulation, Blind Squirrel is the designated controller of the data we collect.

This Privacy Policy applies to the Site, our Games (including without limitation enhancements thereto or future DLC), and our Services where this privacy policy is referenced, regardless of how they are accessed. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

For our policies in connection with the personal information of job applicants and employees of Blind Squirrel, please refer to our Applicant & HR Privacy Notice here: https://blindsquirrelentertainment.com/terms

This Privacy Policy describes:

  • the information we collect, how we collect such information and the purposes of our collection;
  • how we use and with whom we share such information;
  • how you can access and update your information; and
  • how we protect the information we store about you.

Disclosure to California Residents: In our efforts to comply with applicable regulation, we ask and advise that California residents review the “CCPA Disclosure” at the end of this document. Although we do not sell user data, we will provide notice if at any time those circumstances change.

Disclosure to Residents of Brazil: The LGPD grants residents of Brazil certain rights about the processing of their personal information and we ask and advise that residents of Brazil review the relevant section under the “Your Rights” heading of this Privacy Policy.

2. Information We Collect When you interact with our Services, we may collect and store information from you directly as described below:

2.1 Registration Information You will need to create a user account through our system before you can play or access Drifters Loot the Galaxy or any other Blind Squirrel product or service (your “Account”). Your Account is used to enjoy the multiplayer and player versus player modes available in our Game and may be used to publicly identify you as part of the social features of the Services, which may include user-to-user interaction, chat or messaging functionality, competitive gameplay and matchmaking, and other similar features.

We may also offer you the option to complete a user profile or provide information in a player dashboard that is accessible and editable only by you, and that may be viewable to other Blind Squirrel users. Your user profile may include a profile photo, a Blind Squirrel username, biographic details that you provide, details about the Games you play, and a Blind Squirrel user ID number that is created by Blind Squirrel and used to identify your profile.

Your Blind Squirrel username will be public and will be shown to other users, but will only permit access to information that is considered public or that you have designated as public in your user profile settings. The information you include in your profile is optional, and we advise you to limit the information you share through this feature if you have concerns about your privacy.

Your Account will be used to identify your transactions and payment history, player sessions and player ratings or rankings, individual user settings and customized characters, in-game currency, and other in-game features that we may make available from time to time. We discourage you from sharing your Account information or password with anyone, and we will never request such information in order to provide Services to you.

2.2 Payment Information When you order any good or service through the Game, including any virtual currency or virtual good, the purchase will be made directly through our payment, currency, and account solutions providers, which may collect relevant information in connection with such purchase. Please review the terms and conditions and privacy policies of the third party marketplace through which you accessed the Game for more information. In addition, each time you make a purchase, we will collect information relating to that in-app purchase, including but not limited to player ID, device ID, session ID, your current available currency, the USD value of the currency, an other information related to the transaction. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Game without having to re-enter it each time. Please note that purchases from third parties may also be subject to additional policies.

2.3 Information Collected by Customer Support When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your gameplay or activity on the Games, and your user name or ID number. We will also store the correspondence and any information contained within.

2.4 Technical and Usage Information When you access our Services, we may collect (i) certain technical information about your gaming device, mobile device, or computer system, including IP Address, device ID (IDFA, Google Advertising ID or other identifiers), anonymized Player and Account ID, session ID, marketplace purchases, transaction history and currency information, gameplay and player information, and the current version of your operating system; and (ii) usage statistics about your interactions with the Games. In certain Games we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Games. This information is typically collected through the use of third-party software development kits.

2.5 Location Information We or our third party providers may collect information for payment processing, region-locking, and other such purposes, which may include information about the territory or region from which you access the Game by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you.

3. How We Collect Your Information We may collect information about you in any one or more of the following ways:

3.1 Communications Features You may be able to take part in certain activities through our Services that give you the opportunity to communicate or share information not just with Blind Squirrel, but also with other users of our Services. These include:

  • participating in player forums and message boards;
  • posting public comments to other users’ profiles or gameboards;
  • sending private messages or invitations to other users, either directly through the Games or to their e-mail accounts;
  • sharing user generated content or photos, if such feature is made available; and
  • chatting with other users

We may use, record and store archives of these communications on Blind Squirrel’s servers to protect the safety and well being of our users and Blind Squirrel’s rights and property in connection with the Services.

3.2 Cookies and Automated Information Collection When you access our Services, we collect certain technical information in order to (i) analyze the usage of our Services; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf may use Log Files and tracking technologies to collect and analyze certain types of technical information, including Cookies, Flash Cookies, and Web Beacons.

“Log Files” means certain information about how a person uses our Services, including both registered and unregistered users (either, a “User”). Log Files may include information such as a User’s Internet Protocol (IP) addresses, device name, user language, time played, platform type, number of page clicks, player levels, player history, the amount of time spent on particular levels, campaign progression, pvp sessions and rankings, Game state and the date and time of activity on our Site or the Games, webpage interactions and pages viewed, and other similar information. In some cases, we will associate this information with your Account ID number for our internal use.

“Cookies” are small text files that are placed on your device by a web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

”Web Beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to know if a certain page was visited or whether an e-mail was opened, to advertise more efficiently by excluding our current users from certain promotional messages, to identifying the source of a new installation, to delivering ads to you on other websites. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

“Flash Cookies” are local shared objects, which help us to prevent fraud, remember your in- Game preferences and speed up load times.

Please note that companies delivering advertisements in the Games or on our Site may also use cookies or other technologies, and those practices are subject to their own policies.

3.3 Other Sources We may collect or receive information from other sources including (i) other Blind Squirrel users who choose to upload their email contacts, and (ii) third party information providers. We do not condition participation in our Services on you providing more personal information than is reasonably necessary for that activity.

4. How We Use the Information We Collect In general, we collect, store and use your information to provide you with a customized experience. For example, we may use information collected from you in any one or more of the following ways:

We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:

  • to create Accounts and allow play of the Games;
  • to facilitate in-app purchases;
  • to enable user-to-user communications;
  • to provide technical support and respond to user inquiries;
  • to prevent, detect, mitigate, and investigate fraud or potentially illegal activities, and enforce our Terms of Service;
  • To provide other services requested by you as described when we collect your information;
  • to notify users of in-Game updates, or updates to our Terms of Service or this Privacy Policy; and
  • to provide in-Game leader boards and matchmaking, and to promote in-Game player achievements.

We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes:

  • to track user retention and aggregated gameplay information to improve the overall user experience for Blind Squirrel’s products and services;
  • to solicit input and feedback to improve Blind Squirrel’s products and services and customize your user experience;
  • to use general location information to provide you with location based services (such as matchmaking, search results, and other personalized content); and
  • to contact you with information that we reasonably believe may be relevant to you

With your consent, we may use your personal information:

  • to inform users about new products or promotional offers.

If you have provided your e-mail address to us, we may use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-game activity, including comments from friends and notifications about in-game status. With your consent, we may also send promotional e-mail messages (“Promotional Communications”) directly or in partnership with parties other than Blind Squirrel. Each Promotional Communication will generally offer recipients choices about withdrawing consent so you no longer receive additional messages.

5. Sharing of Your Information We may share your information (in some cases personal information) with third parties in the following circumstances:

5.1 Third Party Service Providers and Third Party Products and Services We will provide your information to third party companies to perform certain services, including but not limited to payment processing, data analysis, e-mail delivery, hosting services, customer service and to assist us in our marketing efforts. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on Blind Squirrel’s behalf.

We do not routinely share personal information with third parties except as may be necessary to provide Services to you. We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; (iii) certain technical information (including IP Addresses and device or player IDs) to develop and deliver Services to you, including payment solutions; (iv) personally identifiable information, including payment information, address, phone number, identify verification, credit card number, and other personal information as may be necessary to provide such Services.

We may also allow third parties to collect these types of information within the Games and they may share it with us. Advertisers may collect this information through the use of tracking technologies like browser cookies and web beacons.

We may disclose aggregated and anonymous information to describe the Services to prospective partners, advertisers, and other third parties, and for other lawful purposes. We may use aggregate, non-personally identifiable information for our own internal promotion or marketing purposes and we may share such aggregate non-personally identifiable information with others for marketing purposes.

In certain instances, you may need to opt in or opt out of advertising directly through our partners.

You may view a complete list of our third party service providers with links to their respective privacy policies as follows:

5.2 Friends and Other Players In many Games, friends and other players will be able to see your Game profile, which may include your name or a “game name” and your profile photo, which in certain cases can reveal your Blind Squirrel ID. Access to a Blind Squirrel ID may allow others to view the public information associated with your related Blind Squirrel account. This information may also be shared with friends you invite to play when you participate in our Referral Program.

5.3 Safety, Security and Compliance with Law Your information may be disclosed: (i) when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations; (iii) where we believe that the Games are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect the rights or property of Blind Squirrel, including to enforce our Terms of Service.

5.4 Sale or Merger In the event that Blind Squirrel undergoes a business transition, such as a merger, acquisition by another company, change of control, or sale of all or a portion of its assets, we may transfer all of your information, including personal information, to the successor organization in such transition.

6. Our Policies Concerning Children Our Services are intended for a general audience and are not intended for children under the age of 13. We do not knowingly collect personal information from users deemed to be children under their respective national laws. If we learn that we have collected personally identifiable information (“PII”) of any child we will take steps to delete such information from our files as soon as possible. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission. We recognize a special obligation to protect personal information obtained from young children.

Should you wish to have your child’s personal information deleted from our records, please contact us at privacy@blindsquirrelgames.com. We will be happy to remove your child’s information as appropriate.

7. How to Control Your Information Under the EU General Data Protection Regulation, individuals residing in the EU and other territories that have adopted GDPR compliance or comparable regulation have a right to:

  • Access your user data
  • Correct the data you have provided to us
  • Have information provided to you in a portable format
  • Request the deletion of the data we have collected
  • Restrict processing
  • Object to processing or the legal basis on which we rely to process your data

You may send an e-mail to privacy@blindsquirrelgames.com with your request to exercise any of the rights identified above. Place the reason for your request (e.g. “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and e-mail address in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content through the Services, we may not be able to delete it. Accounts created with Blind Squirrel are considered active until we receive a user request to delete them or deactivate them. Any request to deactivate or delete an account will not automatically result in information deletion unless so requested by the End User, and only to the extent we are not required to retain such data to satisfy our legal obligations.

Please note that requests to restrict processing or delete your data may require the termination of your user account if we require the information subject to the deletion request to maintain your user account or otherwise provide gameplay services to you.

We are unable to delete data controlled solely by third parties; for example, if you purchase our Game through Steam, we won’t be able to delete your Game from your Steam library, nor the data collected by Valve in connected with your purchase or your Valve account. Similarly, if you access any our of Services through third party social media or service platforms, such as Discord, or if you are routed to a third party service provider’s web page through our Services, you will need to make any deletion requests to those respective third parties separately.

Individuals Located in Brazil: The LGPD grants you certain rights about the processing of your personal information. In addition to any applicable rights mentioned above, eligible residents of Brazil also have the right: (i) to the anonymization, blocking, or elimination of your personal information, if you believe we are processing your personal information in an unnecessary, exceeding or non-compliant manner with the LGPD; (ii) to request the portability of your personal information; (iii) to request information about the entities with which we have shared your personal information; and (iv) to request information about the possibility and consequences of denying consent. While our processing of personal information generally does not include automated decision-making, you are also entitled to a review of our decisions that are made solely based on automated processing of personal information that affect your interests. Notwithstanding any other references to the contrary within this Privacy Policy, in accordance with the LGPD, we will respond to your request within fifteen (15) days after receipt and we will provide any requested information free of charge to you. You may also file a complaint with the National Data Protection Authority in Brazil, the Autoridade Nacional de Proteção de Dados (“ANPD”) for alleged violations of the LGPD, in addition to or alternatively to seeking judicial redress.

8. Opt Out Options

8.1 Opting out of Promotional Communications You can choose to opt out of receiving promotional e-mails and product updates from Blind Squirrel by clicking on the “unsubscribe” link in any such e-mail, or by opting out of such communications in your Game or Account preferences. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, usually within 10 business days.

8.2 Opt Out Limitations Please note that if you opt-out of our Promotional Communications or other forms of communication, we may still e-mail or communicate with you from time to time if we need to: provide you with information and updates concerning this Privacy Policy or our Terms of Service, respond to a customer support or technical support inquiry, notify you of changes to your account (including suspension or deactivation), respond to any customer service or technical support inquiry, request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons.

9. Security of Your Information Accessing your account or any personally identifiable information stored through your account is password protected and requires two-step authentication using OTP when first accessing our Services through any new computer or device, or when cookies are disabled. It is important that you protect and maintain the security of your Account and that you immediately notify us of any unauthorized use of your Account. We encrypt the transmission of all information using secure socket layer technology (“SSL”).

We further encrypt all data we store or share, and each transfer of data is tokenized and signed with a secret. However, while we take reasonable precautions against possible security breaches of our Services, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted through our Services; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access.

10. Changes to Our Privacy Policy Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. If we decide to make material changes to our Privacy Policy, we will notify you and other users by placing a notice on blindsquirrelentertainment.com or by sending you a notice to the e-mail address we have on file for you, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective. We may supplement this process by placing notices in the Games and on the Site. You should periodically check blindsquirrelentertainment.com and this privacy page for updates.

11. Sharing Your Information for Direct Marketing Purposes We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in” to receive information from a third party that is participating in a sweepstakes or other promotion through our Services. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt in to such use when you provide personal information through our Services.

12. Social Media Communications You may be able to take part in certain activities through our Services that give you the opportunity to communicate or share information not just with Blind Squirrel, but also with other Users of our Services, generally by engaging with official Blind Squirrel social media accounts. We are not responsible for your use of those services. If you communicate to us or other Users publicly via our social media accounts, you are strongly encouraged to review the privacy policies of those services if you have questions about the use of your data. We only access the information you make available to the public on our social media pages and do not receive any information concerning your social media account from any social media platform.

13. Links to Other Sites Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

14. California Residents: Responding to Do Not Track Signals In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the web sites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning out collection and use of personally identifiable information will continue to operate as described in this policy.

15. International Transfer Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States andchoose to provide your personal information to us, we may transfer your personal information to the United States and process it there.

16. Contact Us If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to privacy@blindsquirrelgames.com.

Blind Squirrel Entertainment, Inc. 320 Commerce, Suite 250 Irvine, CA 92602 (714) 460-0860

Facebook: https://www.facebook.com/blindsquirrelgames/ Twitter: https://twitter.com/Blind_Squirrel_ Instagram: https://www.instagram.com/blindsquirrelgames/

California Consumer Data Rights

Blind Squirrel Entertainment complies with the California Consumer Privacy Act of 2018 (CCPA), effective January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.

Categories of Data we Collect and their Uses

In addition to the details provided in Section 2 of our Privacy Policy, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected Reason for Collection (specifically identify business purpose if for business purpose) Is Information “Sold” to 3rd Pty?
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Yes Account name, e-mail address: account creation ID: For attribution (if install came from Facebook or Twitter) and IP is for Location No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. No N/A N/A
Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). No N/A N/A
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No N/A N/A
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Yes Keystrokes and interactions with game products for analytics purposes and to improve gameplay No
Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Yes Cookies may be used on our Site and we may save your user settings in our products No
Geolocation data. Physical location or movements. Yes Whatever is identified by the Public IP Address provided by the ISP for purposes of geolocation, localization, and region-locking. No
Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No N/A N/A
Professional or employment-related information. Current or past job history or performance evaluations. No N/A N/A
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No N/A N/A
Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes Analytics and gameplay metrics and behaviors tracked for play testing and to provide quality assurance No

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our end users. For example, from customers who engage us for customer support or to provide customer feedback.
  • Indirectly from our end users. For example, through information we collect from our end users in the course of providing customer support to them.
  • Directly and indirectly from activity on our Site or in our Games. For example, from APIs and cookies (described above) embedded in our Site or Games to measure game metrics and progress, play time per level, and other information related to improving our products.
  • From third-parties that interact with us in connection with the services we perform. For example, from third party analytics or anti-cheat providers, or to ad mediators for the purpose of providing personalized advertising and marketing customized to you.

All such Personal Information is used as otherwise described in Section 4 of our Privacy Policy.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers, Commercial information, Internet or other similar network activity, and Geolocation data. We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
  • Our vendors.

Your Rights and Choices

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

We generally do not sell our player data. However, if we do sell your personal information for a business purpose, we will also disclose to you:

  • The personal information that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete any transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products, including our Site and Games, to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at (714) 460-0860 Emailing us at legal@blindsquirrelgames.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the

CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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