PRIVACY POLICY

Last Updated: August 1, 2018

1. DEFINITIONS

2. WHO IS PROCESSING YOUR DATA?

3. WHAT INFORMATION DO WE COLLECT, AND HOW LONG DO WE KEEP IT?

4. WHY DO WE PROCESS YOUR DATA?

5. HOW WE SHARE YOUR DATA

6. INTERNATIONAL TRANSFER

7. WHAT RIGHTS DO I HAVE?

8. TRACKING TECHNOLOGIES

9. INTERNET PROTOCOL

10. SECURITY MEASURES

11. MINORS

12. CONTACT INFORMATION, FURTHER INFORMATION OR COMPLAINTS

Universe Projects Inc., its subsidiaries, partners, and affiliates (collectively "UP", "we", "us"), respects the privacy of its online visitors, gamers, and users (collectively "users", "you", "your"), and ensures a secure environment for their data. This document ("Privacy Policy") explains how and why we collect, use, retain, disclose, safeguard and dispose of the information you provide us. UP builds online, mobile, and computer videogames, most of which are generally free to play ("Services").

We may change this Privacy Policy at any time by posting a new version available on our home page. The new version will be effective as of the "Last Update" set out in this Privacy Policy. We will notify you by email, or we will provide a post on our website, if we make material changes to the Privacy Policy and you will have the option to opt-out of our Privacy Policy and Services.

This Privacy Policy is incorporated as part of the UP Terms of Service (https://www.universeprojects.com/tos) and applies to all Services provided to you by UP. It does not apply to Services provided to you by third party providers, other individuals, whether such was introduced to you through links on our website or references through our Services or games.

1. DEFINITIONS

The following definitions apply in this Privacy Policy:

  • "Consent" means the voluntary, unequivocal, expressed, informed, and unambiguous indication from you stating that you, wish to affirm or agree to this Privacy Policy or permit the processing of your Personal Information.
  • "Controller" means the person or organization responsible for deciding the purpose of processing the Personal Information.
  • "GDPR" means the General Data Protections Regulation, which serves to regulate privacy and data protection for residents of the UK and EU. To read the full text, please visit GDPR Text.
  • "Personal Information" or "personally identifiable information" means any information related to a natural person or what is sometimes called a 'data subject', whether collected on the internet or not, which can be used to directly or indirectly identify the person (sometimes referred to as 'personal data'). This can be anything from a name, telephone number, photo, email address, bank details, posts on social networking websites, medical information, or a computer internet protocol ("IP") address. Personal Information also includes characteristic, opinions, health, or financial information about/of an individual.
  • "Processing" means any work we do with Personal Information, including how we change Personal Information into non-personally identifiable information or aggregate information (i.e. pseudonymization), whether by automated means or not. This includes collecting, retaining, using, disclosing, and destroying the information.
  • "Third Party" means a person or organization other than the Controller or Processor who is authorized by agreement or contract with the Controller or Processor to access and process the Personal Information.

For greater certainty, the terms used in this Privacy Policy have the same meanings as in our Terms of Service, which is available on our website https://www.universeprojects.com/tos. In the case there is a conflict of terms, the interpretation and definitions in the Terms of Service shall apply.

2. WHO IS PROCESSING YOUR DATA?

For the purposes of this Privacy Policy, UP is a data controller and processor of your personal data. We are a registered company located at 211-89 Stonehurst Ave, Ottawa, ON K1Y 4R6.

3. WHAT INFORMATION DO WE COLLECT, AND HOW LONG DO WE KEEP IT?

We only collect information in relation to our legitimate interests (namely, to provide computer and mobile application games to you), and with your Consent. UP will only retain and process information that is absolutely necessary and will limit access to your Personal Information to those who need it to provide the Services. We do not collect or process Personal Information further than what we require for the basic functionalities of our games and Services. We collect information from or about you in the following ways:

  • Account Information: Provided when creating your Account, including user name, password, email address, date of birth, and country of origin.
  • Customer Support Information: Gathered while assisting users through our customer support Services.
  • Communication Information: Access to contents of communications on Forums.
  • Server Logs: Typically retained for up to 30 days.
  • Device Information: Related to the devices used to access our Services.
  • Marketing Communications: Information collected for communicating about products and Services.
  • Legal Records: Retained for up to 7 years for potential legal matters.
  • UGC and Game Data: Information on User Generated Content and users' game history.
  • Publicly Available Information: Acquired from social media platforms.

WE DO NOT COLLECT, USE, STORE, OR DISCLOSE SENSITIVE INFORMATION RELATED TO YOUR PERSONAL FINANCES OR HEALTH. PLEASE DO NOT SEND US ANY SUCH INFORMATION.

4. WHY DO WE PROCESS YOUR DATA?

We process Personal Information and non-identifiable information for our own security, diagnostic, authentication and billing purposes. We collect IP address information to prevent hacking and fraud, and for diagnostics and data traffic analysis to improve our games and Services.

UP collects and uses your data for the following legitimate reasons:

  • Gameplay and User Experience: To improve our games.
  • User Account: To keep track of assets and communicate with friends.
  • Business Optimization: For troubleshooting, research, and service development.
  • Customer Service: To investigate and address any difficulties.
  • Social Features: For communications between users.
  • Legal Requirements: To investigate or address claims or disputes.

For residents and data subjects from the EU, we will ask for Consent before collecting your information.

5. HOW WE SHARE YOUR DATA

UP generally does not share or disclose your Personal Information to others without notifying you or unless required by law or otherwise set out in this Article. Information may be viewable by friends, people in games, or the public if you play our games. UP may provide information to third party companies for payments and communication, which include:

  • Paypal
  • Steam
  • Google Play Store
  • Apple App Store
  • CoinPayments

For legal reasons, UP may share your information as necessary to enforce our Terms of Service or in the event of a dispute.

6. INTERNATIONAL TRANSFER

Your personal data will be transferred to and processed in the United States. We use European Commission approved contract clauses to protect your personal data when shared with third parties.

7. WHAT RIGHTS DO I HAVE?

  • Right to Access: You may request a report about the data UP stores about you.
  • Right to be Forgotten: You may request deletion of your data.
  • Right to Object: You can object to the processing of your data.
  • Right to Information Accuracy: You can correct inaccuracies.
  • Right to Restrict Processing: You can request limitations on processing.
  • Right to Data Portability: We will provide your basic account information on request.

To exercise any of your rights, contact support@universeprojects.com.

8. TRACKING TECHNOLOGIES

UP may use tracking technologies like cookies for various purposes, including analyzing trends and gathering demographic information about our user base.

9. INTERNET PROTOCOL

An IP address is the unique number used to identify your computer every time you log on to the Internet. UP may track such IP addresses for administration and security purposes.

10. SECURITY MEASURES

We maintain physical, technical and administrative safeguards to protect your Personal Information. Security processes include:

  • Encryption of data
  • Strict filtering rules
  • Firewall protections
  • VPN solutions
  • Background checks for team members

11. MINORS

UP does not knowingly collect Personal Information from children under the age of majority. If parents or guardians believe that we have collected their children's personal information, they may request deletion by contacting support@universeprojects.com.

12. CONTACT INFORMATION, FURTHER INFORMATION OR COMPLAINTS

If you have questions or concerns regarding data protection at UP, you may contact us at: support@universeprojects.com

For EU data subjects, you may contact your independent public authority responsible for monitoring the application of the GDPR.