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PRIVACY POLICY FOR PROJECT WINTER
Other Ocean Group Inc. (“we”, “us” or “our”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Policy is to inform you about our privacy practices, including how we collect, use and disclose your personal information.
This Privacy Policy relates exclusively to the Project Winter video game (the “Game”), unless we have provided you with a separate privacy policy for a particular product, service or activity within the Game. “Personal information” means information about an identifiable individual, subject to more particular definitions under applicable law.
Please review carefully this Privacy Policy. By submitting your personal information to us (including via the Game), or by registering for, using or playing our Game, you consent to our collecting, using and disclosing your personal information as set out in this Privacy Policy, as revised from time to time.
This Policy is incorporated into, and is subject to, our other applicable terms & conditions of the Game. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in these documents.
WHAT’S IN THIS PRIVACY POLICY?
Personal Information We Collect
When you download and play our Game, we collect your third party platform user name, gameplay data and in game metrics, as well as information when the Game crashes. We collect this information as follows:
If you subscribe to our email list, or complete any other forms or subscriptions, you may be required to provide personal information, such as your first name, last name, email addresses, language, country location or discord user name.
We will not request any sensitive personal information such as your health information, race, religion, or sexual orientation. Please do not send us such sensitive personal information whether via our Game or by any other means.
How We Use Your Personal Information
We may use your personal information and other information for the following purposes. In addition in accordance with the General Data Protection Regulation (“GDPR”) we identify the relevant grounds that we rely on to use your personal information:
We may use your personal information for other purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.
How We May Share Your Personal Information
We design our games to collect only the information that we need from you to offer you an awesome game experience; we strive for data minimization as a practice!
We may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate to meet our obligations to you as a service provider: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our Game; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
We also rely on third party service providers to perform a variety of services on our behalf. Please find below a list of our third-party service providers which may process your personal information (with links to their data/privacy policies):
If we provide your information to third party service providers, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate security measures. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.
If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent if needed.
Your Consent to Data Collection, Use and Disclosure
We collect, use and disclose your personal information with your consent or as permitted or required by law. For example, where we are not relying on your consent, under the GDPR, the legal basis for our processing of personal information is explained above.
How we obtain your consent (i.e. the form we use) will depend on the circumstances and types of data we collect, as well as the sensitivity of the information collected. Subject to the applicable laws that apply in different countries, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we understand that you consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy and so that we can deliver the best payer experience to you.
We will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.
How To Withdraw Consent
You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require appropriate proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide the Game.
If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.
If consent is withdrawn, you may lose access to the Game.
Retention of Personal Information
We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. If you would like further information regarding the periods for which your personal information will be retained, please contact us as set forth in the “Contact Us” section below.
Information Security
We have implemented appropriate physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below. If we learn of a security breach involving your personal information, we will inform you and the relevant authorities of the occurrence of the breach as required under applicable law.
Opting Out of Communications
If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.
We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our Game or products, or other matters.
Rights Regarding Your Personal Information
Under certain circumstances and in accordance with the GDPR or other applicable data protection laws, an individual has the following rights:
You also have a right to make a complaint with a data protection supervisory authority, in particular in the country/province/state where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.
To exercise any of these rights, please contact us as set forth in the “Contact Us” section below. Please note that we may require that you provide appropriate identification to fulfill your request. Any such identifying information will be used only for this purpose.
International Transfer and Storage of Information
Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to a third country.
Third Party Websites and Services
This Privacy Policy applies only to our Game. This Privacy Policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third party websites or products or services.
Children’s Information
We do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you should not provide us with your personal information. If you are a parent or guardian and discover that your child under the age of 16 has provided personal information, then you may alert us as set forth in the “Contact Us” section below and request that we delete that child’s personal information from our systems. We ask that all parents take the necessary precautions to ensure that their children are instructed to never give out personal information when online.
Privacy Policy Updates
This Privacy Policy is current as of the “updated” date which appears at the top of this page. We may modify this Privacy Policy from time to time. When changes are made to this Privacy Policy they will become immediately effective when published in a revised Privacy Policy unless otherwise noted. We may communicate the changes through our Game or by other means. By submitting your personal information to us, by registering for, using or playing our Game, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this Privacy Policy, you consent to our collecting, using and disclosing your personal information as set out in the revised Privacy Policy.
Contact Us
All comments, questions, concerns, requests or complaints regarding your personal information or our privacy practices (including with respect to any service providers outside of your country of residence) should be sent to our Privacy Officer by e-mail to [email protected].
Other Ocean Group Inc. (“we”, “us” or “our”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Policy is to inform you about our privacy practices, including how we collect, use and disclose your personal information.
This Privacy Policy relates exclusively to the Project Winter video game (the “Game”), unless we have provided you with a separate privacy policy for a particular product, service or activity within the Game. “Personal information” means information about an identifiable individual, subject to more particular definitions under applicable law.
Please review carefully this Privacy Policy. By submitting your personal information to us (including via the Game), or by registering for, using or playing our Game, you consent to our collecting, using and disclosing your personal information as set out in this Privacy Policy, as revised from time to time.
This Policy is incorporated into, and is subject to, our other applicable terms & conditions of the Game. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in these documents.
WHAT’S IN THIS PRIVACY POLICY?
- Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- Your Consent to Data Collection, Use and Disclosure
- How To Withdraw Consent
- Retention of Personal Information
- Information Security
- Opting Out of Communications
- Rights Regarding Your Personal Information
- International Transfer and Storage of Information
- Third Party Websites and Services
- Children’s Information
- Privacy Policy Updates
- Contact Us
Personal Information We Collect
When you download and play our Game, we collect your third party platform user name, gameplay data and in game metrics, as well as information when the Game crashes. We collect this information as follows:
- Information From Third Party Game Platforms. We receive your personal information from the platform through which you downloaded and play the Game, such as your user name with that third party platform (for example your user names and IDs from Steam). Personal Information collected by the third-party platform that you use to access the Game is subject to the applicable third-party terms of use and/or privacy policy (for more information, please see the “How We Share Your Personal Information” section below). Our use of your personal information collected through the Game is limited to the applicable third-party terms of use and/or privacy policy and the purposes described in the “How We Use Your Information” section below.
- Gameplay. When you play our Game, we automatically collect your IP address and we may process aggregated personal information from you through our third party service providers during gameplay. We can not link you to your username or other identifiable information with your gameplay. We collect this information to improve your gameplay experience and improve our Game.
- When You Use The In-Game Chat. You may choose to reveal personal information in the Game through multiplayer chat or other public functions, including through your username defined on a third-party game platform, to the extent it contains personal information we cannot control how other users will use personal information that you reveal using multiplayer chat or other public functions, so, if you reveal personal information through multiplayer chat or other public functions, you are doing so at your own risk. Further, disclosure of phone numbers, addresses, age or other personally identifying information that may violate someone else's privacy is prohibited. Encouraging or asking users to disclose publicly their personally identifying information is also prohibited.
- When The Game Crashes. If the Game crashes during play, we automatically collect information such as your operating system and your hardware devices, when the game crashed and the cause for the crash to solve the crash issue, give you support, and improve and optimize your game play experience.
If you subscribe to our email list, or complete any other forms or subscriptions, you may be required to provide personal information, such as your first name, last name, email addresses, language, country location or discord user name.
We will not request any sensitive personal information such as your health information, race, religion, or sexual orientation. Please do not send us such sensitive personal information whether via our Game or by any other means.
How We Use Your Personal Information
We may use your personal information and other information for the following purposes. In addition in accordance with the General Data Protection Regulation (“GDPR”) we identify the relevant grounds that we rely on to use your personal information:
- to provide you with the Game and to support your use of the Game, which allows us to meet our contract requirements with you when you purchase the game. Applicable legal ground per GDPR: contract performance;
- to improve and optimize our Game and your experiences in our Game, and to develop new products and services. Applicable legal ground per GDPR: legitimate interests;
- to personalize your in game experience. Applicable legal ground per GDPR: legitimate interests;
- to provide customer support which is a service we provide to you when you purchase the game; Applicable legal ground per GDPR: contract performance;
- to contact you relating to the Game. Applicable legal ground GDPR: consent;
- to conduct research and analysis related to our business and the Game. Applicable legal ground per GDPR: legitimate interests;
- to collect player feedback, opinions and comments in regard to the Game which we have a legitimate interest in so that we can improve our player experience. Applicable legal ground per GDPR: legitimate interests;
- to communicate with you, including for in-game updates and notifications, new services, and promotional offers that we think might be of interest to you when you agree and consent to receiving this information from us. Applicable legal ground per GDPR: consent; and
- to investigate legal claims or comply with our legal obligations. Applicable legal ground per GDPR: legal obligations.
We may use your personal information for other purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.
How We May Share Your Personal Information
We design our games to collect only the information that we need from you to offer you an awesome game experience; we strive for data minimization as a practice!
We may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate to meet our obligations to you as a service provider: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our Game; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
We also rely on third party service providers to perform a variety of services on our behalf. Please find below a list of our third-party service providers which may process your personal information (with links to their data/privacy policies):
- Unity. We use Unity Analytics and Performance Tracking for anonymous demographics, error reports, error dumps, and other information that may be provided by Unity services. See more about Unity’s data/privacy policies: https://unity3d.com/legal/privacy-policy
- Steam. We use Steam as convenient way to sign in, among other features. We also use Steam for friend discovery, parties with friends, and other features included within Steamworks. We also use Steam for both game purchases and in-game purchases. See more about Valve’s data/privacy policies: https://store.steampowered.com/privacy_agreement/english/
- Playfab. We use Playfab to monitor game performance and ensure the best possible performance in gameplay and user inventory management (e.g. hosts player authentication, game scripts, user data such as in game currency and player reports). See more about Playfab’s data/privacy policies: https://playfab.com/terms/
- Vivox. We use Vivox for voice communications for games, more specifically for host users voice over IP and chat relays to communicate in game. See more about Vivox’s data/privacy policies: https://www.vivox.com/policies/gdpr.html
- Photon Relay. We use Photon Relay to sync in-game actions across multiple players and hosts them in a multiplayer game so they can interact with each other. See more about Exit Games’ data/privacy policies: https://dashboard.photonengine.com/en/Account/PrivacyAndCookiePolicy
- Mailchimp. If you sign up for our email list we use Mailchimp to store your email and deliver you news. You are free to unsubscribe from it at any time. Data is kept until you unsubscribe. See more about Mailchimp’s data/privacy policies: https://mailchimp.com/legal/privacy/
- Gamesight. We use Gamesight to obtain a digital fingerprint of our players in order to better understand how our marketing efforts are impacting our game sales, and to improve making the game visible to the people who are interested. This digital fingerprint includes the player's IP address. To see Gamesight’s privacy policy which contains more information and the ability to opt-out, please follow this link: https://console.gamesight.io/privacy-policy
- Modulate: Toxmod. We use Toxmod to enhance the user experience by providing better moderation during gameplay. See more details about Modulate’s data/privacy policies here: https://www.modulate.ai/privacy-policy
If we provide your information to third party service providers, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate security measures. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.
If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent if needed.
Your Consent to Data Collection, Use and Disclosure
We collect, use and disclose your personal information with your consent or as permitted or required by law. For example, where we are not relying on your consent, under the GDPR, the legal basis for our processing of personal information is explained above.
How we obtain your consent (i.e. the form we use) will depend on the circumstances and types of data we collect, as well as the sensitivity of the information collected. Subject to the applicable laws that apply in different countries, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we understand that you consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy and so that we can deliver the best payer experience to you.
We will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.
How To Withdraw Consent
You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require appropriate proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide the Game.
If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.
If consent is withdrawn, you may lose access to the Game.
Retention of Personal Information
We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. If you would like further information regarding the periods for which your personal information will be retained, please contact us as set forth in the “Contact Us” section below.
Information Security
We have implemented appropriate physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below. If we learn of a security breach involving your personal information, we will inform you and the relevant authorities of the occurrence of the breach as required under applicable law.
Opting Out of Communications
If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.
We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our Game or products, or other matters.
Rights Regarding Your Personal Information
Under certain circumstances and in accordance with the GDPR or other applicable data protection laws, an individual has the following rights:
- Access: entitled to ask if we are processing information and, if we are, request access to personal information. This enables the individual to receive a copy of the personal information we hold and certain other information about him or her;
- Correction: entitled to request that any incomplete or inaccurate personal information we hold be corrected;
- Erasure: entitled to ask us to delete or remove personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims;
- Restriction: entitled to ask us to suspend the processing of certain personal information, for example to establish its accuracy or the reason for processing it;
- Transfer: request the transfer of certain personal information to another party;
- Objection: one may challenge when we are processing personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information;
- Automated decisions: contest any automated decision made where this has a legal or similar significant effect and ask for it to be reconsidered.
- Consent: where we are processing personal information with consent, withdrawal of consent.
You also have a right to make a complaint with a data protection supervisory authority, in particular in the country/province/state where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.
To exercise any of these rights, please contact us as set forth in the “Contact Us” section below. Please note that we may require that you provide appropriate identification to fulfill your request. Any such identifying information will be used only for this purpose.
International Transfer and Storage of Information
Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to a third country.
Third Party Websites and Services
This Privacy Policy applies only to our Game. This Privacy Policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third party websites or products or services.
Children’s Information
We do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you should not provide us with your personal information. If you are a parent or guardian and discover that your child under the age of 16 has provided personal information, then you may alert us as set forth in the “Contact Us” section below and request that we delete that child’s personal information from our systems. We ask that all parents take the necessary precautions to ensure that their children are instructed to never give out personal information when online.
Privacy Policy Updates
This Privacy Policy is current as of the “updated” date which appears at the top of this page. We may modify this Privacy Policy from time to time. When changes are made to this Privacy Policy they will become immediately effective when published in a revised Privacy Policy unless otherwise noted. We may communicate the changes through our Game or by other means. By submitting your personal information to us, by registering for, using or playing our Game, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this Privacy Policy, you consent to our collecting, using and disclosing your personal information as set out in the revised Privacy Policy.
Contact Us
All comments, questions, concerns, requests or complaints regarding your personal information or our privacy practices (including with respect to any service providers outside of your country of residence) should be sent to our Privacy Officer by e-mail to [email protected].