Privacy Policy

Privacy Statement

Critical Path Games Ltd. and its affiliates (collectively, "Critical Path", "we", "our" or "us") recognize the importance of privacy. The purpose of this Privacy Statement is to inform you about our privacy practices, including how we collect, use, and disclose your personal information.

What This Privacy Statement Covers

This Privacy Statement covers the following topics:

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Consent to the Collection, Use and Disclosure of Your Personal Information
• Our Use of Cookies
• Opting Out of Marketing Communications
• Retention, Storage, and International Transfer of Personal Information
• Information Security
• Your Rights Regarding Your Personal Information
• Third-Party Websites and Services
• Children’s Personal Information
• Changes to this Privacy Statement
• How to Contact Us

Personal Information We Collect

“Personal information” means information about an identifiable individual. This information may include, but is not limited to, your name, mailing address, e-mail address, telephone number and country of residence.

Personal information does not include information where there is no serious possibility that it can be used to identify an individual, whether on its own or in combination with other information, or personal information that has been anonymized or aggregated such as to be considered anonymized information or no longer personal information under applicable laws.

How We Collect Personal Information

We collect personal information from you in the following ways:

• Through your use of our games and other products, whether directly uploaded and created by you, or automatically collected by us as you use the games.
• Through your engagement with our Website, including information submitted by you within a website form or obtained from us through cookies or similar technologies.
• From other users within our games that you may interact with
• From other third party sources, such as our partners and service providers.

Types of Personal Information We Collect

We may collect, use, and disclose different types of personal information, depending on our relationship with you. Generally, we collect the following types of personal information (not all of which may apply to you):

• Contact information, such as your name, address, e-mail address and telephone numbers;
• Information input by you and generated by your use of our games, including game progress, in game activities and communications;
• Technical and usage information when you use our website and our games, such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and games;
• Event participation information, such as your enrollment and attendance at our events; and
• Marketing and communications information, such as your preferences for receiving our communications.
• We also collect, use, and share aggregated and anonymized data for any purpose. Aggregated and anonymized data is not considered personal information because it cannot be used to identify you.

How We Use Your Personal Information

We generally use your personal information for the following purposes:

• To determine your eligibility for our games in accordance with applicable laws and our policies;
• To administer our games and other products;
• To respond to your inquiries, complaints or requests, and to provide support;
• To communicate with you or to facilitate communication and interaction with other users within our games;
• To manage our business and our arrangements with our users, including to detect and prevent errors and fraud;
• To improve the effectiveness and efficiency of our operations, products, games, and products and to test our games;
• To investigate legal claims and protect our rights, operations or property;
• To provide you with information that we think may interest you, including marketing communications;
• For such other purposes as you may consent to from time to time; and
• As otherwise required or permitted by law.

How We Share Your Personal Information

We generally identify to whom, and for what purposes, we will disclose your personal information (and we obtain your consent to such disclosure) at the time we collect your personal information.

We share your personal information with third party service providers who perform some functionality within our games or otherwise on our behalf, such as customer service, game testing services, technical support, payment processing, and research and analytics. If you would like more information about our service providers, please contact us using the contact information on our website.

Additionally, we may disclose your information when we believe such disclosure is permitted, necessary or appropriate: (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 products and games; (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.

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.

Your Consent to the Collection, Use and Disclosure of Your Personal Information

We collect, use, and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question. Generally, we will seek your consent at the time we collect your personal information, either orally, electronically, or in writing.

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 such information from you, and to use and disclose his or her information as described in this privacy statement.

If you wish to withdraw your consent to our collection, use or disclosure of your personal information, please contact us using the contact information in the “How to Contact Us” section below. We will accommodate your request to withdraw consent, subject to legal or contractual restrictions. Withdrawal of your consent may mean that we will no longer be able to provide you with certain products or access to certain games.

Our Use of Cookies

A “cookie” is a small text file that contains information and is stored on your computer. We use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our website and your interaction with our emails. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage.

We use this information to facilitate the use of our website, for our business or analytical purposes (including to assess website traffic and track search criteria), and to personalize web pages according to your choices and interests.

We may also use this information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our website, and across third-party websites or service offerings when you leave our website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests.

If you do not wish to accept cookies, you can adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. Some areas or features of our website rely on cookies and may not work if you delete or decline cookies. For more information about cookies generally please visit www.allaboutcookies.org.

Opt Out of Marketing Communications

If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information in the “How to Contact Us” section below.

Please note that if you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our games and products, or other matters.

Retention, Storage, and International Transfer of Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and as permitted or required by law.

Our practices regarding your personal information will at all times continue to be governed by this privacy policy and we will continue to comply with all applicable legal requirements. For more information about our policies and practices regarding transfers to other countries, contact us using the contact information in the “How to Contact Us” section below.

Information Security

We have implemented commercially reasonable physical, organizational, contractual and technological security measures with a view to protecting your personal information from accidental or unlawful destruction, loss or theft, unauthorized access, disclosure, copying, use or modification.

Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. In the case of a breach of security safeguards, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

You are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of our website and/or our games. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through our website or our games. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through our website or our games. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party.

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 on our website.

Your Rights Regarding Your Personal Information

Individuals have a number of rights concerning their personal information under global privacy laws. You may make a written request to access, correct or delete any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

Where applicable, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

When you exercise your right to deletion of your personal information, we will delete your personal information, subject to some instances where your personal information will be maintained for us to fulfill our obligations under contract.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.

Third-Party Websites and Services

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy statements and policies of the respective third party. This Privacy Statement does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.

Children's Personal Information

Our games and products are not intended for children under the age of 14 and we do not knowingly collect personal information from children under the age of 14. Children under the age of 14 should not use our games or products and should not provide us with their personal information.

Changes to this Privacy Statement

The Privacy Statement was last revised as of the date that appears at the top of this page. From time to time, we may make changes to this Privacy Statement. When changes are made, they will become immediately effective when published in a revised Privacy Statement posted on our website, unless otherwise noted. We may also communicate the changes to this Privacy Statement by other means.

How to Contact Us

All comments, questions, concerns, or requests regarding your personal information or our privacy practices should be forwarded to our Privacy Officer as follows:

Jesse Houston

[email protected]

20th Floor, 250 Howe Street Vancouver, BC, V6C 3R8