PRIVACY POLICY

Effective Date: August 30, 2019

This Privacy Policy applies to Skybox Labs Inc. (“SkyBox”, “we”, “our” or “us”) services, including but not limited to SkyBox applications, our website skyboxlabs.com, and our games currently titled “Stela” and “Idle Harvest” (together, the “Games” and each a “Game”) and any other product or service that we choose to apply this Privacy Policy to (collectively, the “Service”), and details how we collect, use, and disclose data about our users, including you.

 

By clicking “I AGREE” or similar CONFIRMATION or by using the Service you are agreeing to the terms of this Privacy Policy as Applicable in your jurisdiction.

1. HOW WE OBTAIN YOUR DATA

The Service collects and processes personal data, which is information about you or that identifies you, as well as anonymous data, which does not identify you.

We obtain your personal data directly from you or when you use the Service.  In many circumstances you may be required to submit personal data in order to access the Service.  Your provision of personal data to SkyBox is governed by any terms of use, end-user license agreement or similar agreement that we may apply to the Service, which you must agree to in order to use the Service, and this Privacy Policy.  If you have any questions or concerns about the disclosure of your personal data please contact us at your convenience using the contact information found below.

Subject to legal, contractual and technical requirements, you may choose not to provide SkyBox with certain data or request the deletion of certain data, which may impact the Service features available to you or essential operations of the Service.

2. PERSONAL DATA WE COLLECT

  • all user IDs associated with your access to the Service including but not limited to Steam IDs, Android identifiers and iOS identifiers as well as any associated login credentials such as passwords (which in most cases are collected by third-parties to which we do not have access);
  • your email address, only if you choose to provide it when communicating with us;
  • Game data such as your save files, keyboard input mappings, playthrough data, details about the use of certain Game features, the length of time spent on certain Game modes, whether you are currently playing the Game, total number of sessions played, the frequency of use of certain features, level progression, checkpoints reached, completion data and achievements obtained; and
  • information about your gaming platform, computer, platform, phone, web-connected devices or other devices used to connect to the Service including but not limited to, operating system information, operations performed on the device, country of install and unique device identifiers (including IP addresses) that may identify you over time and across different websites or platforms.

We also collect anonymous data that does not identify you, including but not limited to responses to anonymous feedback requests, metrics and other types of statistical data, which could be derived from use of the Service and analytical data concerning the Service.

3. PROCESSING OF YOUR PERSONAL AND ANONYMOUS DATA

We process your personal and anonymous data primarily for our legitimate business purposes, such as providing the Service to you, to understand your needs and the needs of our users and to improve the quality of the Service and analyze the data we collect.  Specifically, these uses include but are not limited to:

  • displaying and delivering the Games and content through the Service;
  • interacting with you through our social media websites or profiles and providing customer support and feedback;
  • authenticating users;
  • maintaining and analyzing functionality of the Games and the Service, backing up data or testing, developing new aspects of the Games, researching new features of the Service, updating the Games and the Service and generating reports and data models that we use to improve the service;
  • supporting the security and integrity of the Service and its users including but not limited to detecting and protecting SkyBox and other third-parties against error, fraud, theft and other illegal activity or for contractual, legal, regulatory or audit obligations;
  • investigating improper or suspicious activity; and
  • contacting you for various reasons including, but not limited to, user feedback requests or marketing purposes, if you previously consented to such contact.

We may disclose your personal and anonymous data to our parent companies, affiliates, subsidiaries, employees and contractors for the same purposes described above.  We may also disclose your personal and anonymous data to third-parties, who may be located in a foreign jurisdiction and subject to foreign laws.  The situations where we disclose your personal and anonymous information to third-parties include, but are not limited to:

  • processing your information as described above as well as providing and enhancing the Service features;
  • providing customer support and feedback, analyzing the Service functionality and technical issues, tracking use of the Service and generating reports and data models that we use to improve the service;
  • providing customized, tailored and personalized advertisements to users of the Service; and
  • responding to a request from law enforcement or a government that has asserted its lawful authority to obtain the data or where SkyBox has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending our rights and the rights of others or providing information to our legal counsel.

4. THIRD-PARTY SERVICES

The Privacy Policy only applies to personal data that SkyBox collects, processes and discloses and does not apply to the collection, processing and disclosure of data by third parties, through third-party services, which may be broader than set forth in this Privacy Policy, and that may be embedded into the Service.  In many cases, third-parties may collect personal information about a user’s online activities over time and across different websites and services.  We strongly recommend that you read each third-party privacy policy carefully before using the Service.  SkyBox may provide data to third-parties, including: Apple Inc., Google Inc, PlayFab, Inc., MailChimp,  and Unity Technologies Inc.  A full list of third-parties that we share your personal data with can be found here https://skyboxlabs.com/privacy-policy/third-parties/. Please contact us directly using the information found below if you would like to learn more about third-party data practices.

5. COOKIES AND DIGITAL TRACKING TECHNOLOGIES

The Service may use tracking technologies, such as Google Analytics, cookies, web beacons, java beacons and clear GIFs, to collect data about you, such as your IP address.  Based on the data collected from the above listed tracking technologies, third-parties may be able to resolve your identity across multiple devices or platforms, for example, by matching your IP address, in order to target you based on your behavior.  A full list of cookies and tracking technologies can be found here: https://skyboxlabs.com/privacy-policy/cookies/. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies.

6. OBTAINING, RECTIFYING AND CONTROLLING YOUR PERSONAL DATA

You may contact SkyBox to obtain a copy of any personal data we collected about you, the production of which may be subject to a fee as permitted by applicable law.  In addition, you may contact SkyBox to correct inaccurate personal data or to complete incomplete personal data.

You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital:

  • for the performance of contractual obligations;
  • to comply with our legal obligations;
  • to protect your interests or those of another person; or
  • for our legitimate interests or the legitimate interests of a third-party,

and may do so by removing personal data, if the Service permits such removal, by ceasing your access to SkyBox and contacting us using the contact information found below.

7. DATA STORAGE, RETENTION AND TRANSFERS

While SkyBox is a Canadian company, the data you provide through the Service may be stored and processed by third parties in countries around the world.  You authorize SkyBox and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal and anonymous data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

SkyBox complies with international personal data transfer laws in applicable jurisdictions.  For residents in the European Economic Area (the “EEA”), SkyBox complies with Articles 44-49 of the European Union’s General Data Protection Regulation (the “GDPR”).  Currently, all transfers of personal data to Canada from residents of the EEA are covered by an adequacy decision as described in Article 45 of the GDPR.

Your personal data is retained until you request its deletion or until SkyBox no longer requires such data for the purpose for which it was collected or until required to be deleted by laws applicable in your jurisdiction.

8. CHILDREN

SkyBox complies with the United States Children’s Online Privacy Protection Act and all other applicable privacy laws and regulations concerning children and the Internet including laws applicable to residents of the EEA.  The Service and the Games are not directed to children under the age of 13 and although it may be possible that children below the age of 13 to access certain features of the Service such as the Games, we do not knowingly collect personal data from children under the age of 13 without first obtaining the appropriate parental consent required by law.  If we learn that we inadvertently collected personal data from a child under the age of 13, in a jurisdiction where consent of a parent or guardian is required to be collected prior to the collection of such personal data, without first obtaining such appropriate parental consent, we will delete that data as quickly as possible.  If you are a parent or guardian of a child under the age of 13 or under the age of consent in your jurisdiction, who you believe provided SkyBox with personal data without your consent, please contact us at info@skyboxlabs.com

9. DO NOT TRACK DISCLOSURE

Do Not Track (“DNT”) is a web or device setting that allows users to request that receivers of personal data stop their tracking activities.  When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter to stop tracking your activity.  Currently, there are no DNT technology standards and it is possible that there may never be any DNT technology standards.  As a result, we do not respond to DNT requests.

10. CALIFORNIA “SHINE THE LIGHT” RIGHT

If you are a California resident, California Civil Code 1798.83 grants you the right to request our disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year.  If you are a California resident and would like to make this request, please contact us using the contact information set forth below.

Please note that you may only make this request once per year.

11. EUROPEAN USERS AND RIGHTS OF EUROPEAN ECONOMIC AREA RESIDENTS

SkyBox has a legitimate interest, as described in Article 6(1)(f) of the GDPR, in collecting your personal data described in this Privacy Policy for the purposes described in this Privacy Policy.  In some cases, the processing of your personal data is necessary for our provision of the Services to you, as described in Article 6(1)(b) of the GDPR.  In other cases, such as when you provide consent to contact you using your email address, SkyBox may collect your personal data pursuant to Article 6(1)(a) of the GDPR.

If you are a resident of the EEA, you have certain rights in regards to your personal data.  These rights include:

  • A Right of Access. You have the right to access your personal data that we hold about you free of charge in most circumstances.
  • A Right to Rectification. If your personal data is inaccurate or incomplete, you can change the information you provided by changing the information yourself or by contacting SkyBox using the email listed below.
  • A Right to Erasure. You have the right to obtain deletion of personal data concerning you in many cases. In many cases, you may simply delete your information by yourself or requesting the deletion by using the contact information found below.  Please be careful as deletion of your data in this manner is permanent and your data cannot be recovered.
  • A Right to Object. If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR or if your personal data was collected based on your consent, you have the right to object to this processing.  If you object we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the personal data is necessary for the establishment, exercise or defense of legal claims or if personal data is required for the provision of the Service and you still wish to use the Service.
  • A Right to file a Complaint. You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction.
  • A Right to Restriction of Processing of your Personal Data. You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR.
  • A Right to Personal Data Portability. You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR.
  • A Right to Post-Mortem Control of Your Personal Data. Certain jurisdictions grant post-mortem controls of your personal data and if such rights are applicable in your jurisdiction, you may have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death though a will or through your estate.
  • A Right to Opt-out of Marketing Communications. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link on any marketing e-mails SkyBox sends you.  To opt-out of other forms of marketing, please contact us using the contact details provided below.

12. CHANGE OF OWNERSHIP OR BUSINESS TRANSITION

In the event of, or in preparation for, a change of ownership or control of SkyBox or a business transition such as the sale of SkyBox or the sale or license of some or all SkyBox’s assets, we may disclose and/or transfer your personal and anonymous data to third-parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

13. SECURITY

We are committed to ensuring that your data is secure.  To prevent unauthorized access, disclosure, or breach, we put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process.

14. CONTACT PREFERENCES

We communicate with our users primarily through the Service itself and our online forums, but we may sometimes collect the email address of some of our users in order to respond to support requests or comments.  If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body or by modifying your email settings within the Service.  On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

15. UPDATES

SkyBox reserves the right, in its sole discretion, to modify the Privacy Policy at any time (“Updates”) and shall make Updates available on SkyBox’s website.  You are deemed to accept Updates by continuing to use the Service.  Unless SkyBox states otherwise, Updates are automatically effective 30 days after posting on SkyBox website.

16. CONTACT US

If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Data Protection Officer at info@skyboxlabs.com or:

Privacy Support Team
Suite 200, 4190 Lougheed Highway
Burnaby, British Columbia
Canada V5C 6A8