INFINITE GAME PUBLISHING INC.
PRIVACY POLICY

LAST MODIFIED: June 14, 2012

This privacy policy (this “Policy”) describes Infinite Game Publishing Inc.’s (“we”, “us”, “our”, “IGP”) practices with respect to the collection, use, storage and disclosure of personal information we collect from users of our IGP Offerings. This Policy is incorporated by reference to the Terms of Use http://infinitegamepublishing.com/terms-of-use, and forms an integral part of it. Any capitalized term used but not defined in this Policy will have the meaning defined in the Terms of Use.
We may modify this Policy from time to time. When we post changes to this Policy, we will revise the “last modified” date at the top of this page. We encourage you to periodically review this Privacy Policy to be informed of how we collect, use, protect and disclose your information. By accessing and/or using any IGP Offerings, you signify your understanding of, and agreement with, this Policy. If you do not agree with our policies, please do not access any IGP Offerings.

Introduction


We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information.

The Personal Information Protection and Electronic Documents Act (Canada), or similar privacy legislation applicable in your Province if you live in Canada (“Applicable Privacy Legislation”) regulates the way private sector organizations operating in Canada may collect, use, keep, secure and disclose personal information. “Personal information” means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, social insurance number, sex, income and family status. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose personal information in accordance with Applicable Privacy Legislation.

As required by Applicable Privacy Legislation, we have appointed a Privacy Officer who is responsible for compliance with this Privacy Policy and Applicable Privacy Legislation. Information on how to contact the Privacy Officer can be found below.

  1. Collection and Use of Personal Information
    We collect two types of information through our IGP Offerings: personal information and non- personal information. The types of information we collect depend on the nature of your interaction with us.
    1. Personal information—We may collect personal information such as:
      1. your contact information – e.g., name, postal address, telephone number, and email address;
      2. your personal preferences – e.g., product wish lists, language preferences, and marketing consent, your account information, and information about your gameplay;
      3. your IP address, and
      4. your transaction information – e.g., products purchased, method of payment, amount paid, and credit or debit card number.
    2. Non-personal information—Non-personal information does not identify you as an individual. For example:
      1. we may collect certain non-personal data when you visit our IGP Offerings, such as the type of browser you are using or the referring URL;
      2. we may collect and summarize customer information in a non-personal, aggregate format for statistical and research purposes; or
      3. we may collect user gameplay statistics, game cheat tracking, and similar information with respect to our game- related IGP Offerings.

      In most cases, you may choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the product, service, or information that you requested. Certain types of personal information, such as your IP address, will be collected automatically when you access any IGP Offering.

  2. Use of Personal Information
    We may use your personal information for a number of different business purposes, for example to:
    1. administer your accounts and fulfill your specific requests for products, services or information;
    2. allow us to communicate with you and authenticate your identity;
    3. provide customer support to assist you with your questions or complaints;
    4. conduct surveys in order to improve our services;
    5. measure and improve the effectiveness of our IGP Offering or our marketing endeavours;
    6. detect and protect against fraud and error, and enforce our agreements with you, including (without limitation) to process and collect payments and debts owed to us;
    7. track and analyze your purchases and preferences to better understand your product and service needs and eligibility;
    8. to allow certain of our third party service providers, partners;
    9. to allow certain of our affiliates, third party service providers, partners and licensors to help us provide our services to you; and
    10. for other purposes as described in this Policy.

We limit the personal information we collect and use to that which is necessary to fulfill the purposes identified above. Except as set out in this Policy, we will not collect, sell, distribute or use personal information for any other purposes without your further consent, as required by law or as authorized by Applicable Privacy Legislation.

  1. Your Consent
    We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Legislation. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection.
    1. Express Consent—Sometimes you will be asked to give your express consent, such as by checking a box to indicate your consent to receive marketing communications.
    2. Implied Consent—Other times, we may obtain your consent implicitly when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for use of your personal information would be reasonably apparent to you.
    3. Withdrawal of Consent—You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure or your information. We will accommodate your request subject to legal and contractual restrictions related to your transactions. If you have “opted in” or subscribed to one of our publications, newsletters, mailing lists, or similar materials, we will always provide you the opportunity to "opt out" or unsubscribe.

    Information We may Collect Directly from You
    Listed here are some further examples of the ways that we collect personal information directly from you and how we use it.

    1. Purchases, Returns and Exchanges — For purchases, or if permitted with respect to any of our return policies for us to offer returns, we may ask for personal information such as your payment/credit card information (for collecting and processing payments or refunds), IP Address (for fraud detection purposes and recordkeeping purposes), and your name, home address, billing address, and telephone number (for verification and fraud detection purposes). You may also be asked to produce photo ID for verification purposes only. We may use a third party service to process payments and refunds.
    2. Purchase Follow-Up and Surveys—Following a purchase or your use of the IGP Offerings, we may send you a follow-up communication to thank you for your business, or we may contact you to ensure that you are completely satisfied. We may use contact information collected online or via telephone to conduct occasional surveys and other customer research. These surveys are entirely voluntary and you may easily decline to participate.
    3. Our IGP Offerings — While some of our IGP Offerings can be used anonymously, in most cases (for example, to engage in most features or functions of our IGP Offerings, or to order products and services from or through our IGP Offerings) you may be asked to provide certain personal information, such as:
      1. your first name, last name, e-mail address, postal address,
      2. account information to log on to such IGP Offerings using an account connected to your personal information, such as answers to security questions, login history, account status,
      3. support ticket(s) and statuses for customer service, in-game messages, forum posts and other content provided by you or sent to you by other users of the IGP Offerings.

      Basically, this is the information we need to offer you the IGP Offerings. We use this information to create your account, contact and correspond with you about your purchases, respond to your inquiries, and monitor functions of our IGP Offerings that you choose to use, such as online forums.

    4. Sign-Up for Newsletters or Updates—We also offer you the opportunity to sign up to receive newsletters, updates or similar communications from us from time to time. Should you choose to enrol we will collect your contact information, such as name and email address. This information will only be used to send you such communications that you have requested. You may “unsubscribe” at any time as directed in such communications. We may offer you the ability to sign up for third parties’ newsletters, updates or similar communications; the privacy policies of those parties will be provided to you at such time and their use of your personal information will be subject to those terms and conditions.
    5. Participate in a Contest or Promotion—From time to time, we may run contests or promotions. If you participate, you may be asked for contact information as well as additional optional survey information (for example, product preferences). Personal information from contest entries will be used only to administer the contest and contact you if you win. For research and analysis purposes, we may also summarize contest survey information in a manner that no longer identifies individual participants. All contests and promotions are subject to this Policy and the rules that will be available with each particular campaign. Some contests may be conducted by third parties and will be subject to the third party’s policies.
    6. Tell a Friend—While visiting our IGP Offerings you may choose to use the “Tell a Friend” tool (or similar tool), which allows you to inform a friend about products of interest to you. The information you provide will be used to send a one-time email to your friend, inviting them to our Web Sites. We will not add your friend to a mailing list and will not send them further email unless they choose to receive such communications from us. When using the “Tell a Friend” tool (or a similar tool) you are contacting your friend directly and as such you acknowledge that you are responsible for this correspondence and not us. If you provide us with personal information concerning another individual (e.g., email address), you represent and warrant that you have obtained all necessary consents from that individual to enable us to use that personal information for the identified purpose.
    7. Social Networking Sites—If you access one of our IGP Offerings that connects to your social media accounts (collectively, “Social Media”), IGP may receive information about your Social Media site profile, including without limitation your first, last and user names, and Social Media site profile ID and icon, in accordance with the terms of such Social Media site. We may record information regarding the use of that Social Media connection, and we may collect other information that is visible on your Social Media page in accordance with the relevant terms of use associated with that social networking site.
  2. Information We Collect Automatically
    In some cases, we automatically collect certain information.
    1. Our Web Sites—When using our IGP Offerings, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access our IGP Offerings, the Internet address of the website, if any, from which you linked directly to our IGP Offerings, the operating system or other system characteristics of the computing device you are using, the portions of the IGP Offerings you visit, read or view, and the content you download from the IGP Offerings. This information is used for IGP Offering and system administration purposes, and to improve the Web Sites, and to provide our services to you.
    2. Cookies—The IGP Offerings consisting of websites may use “cookies”, a technology that installs a small amount of information on a user’s computer to permit the IGP Offering to recognize future visits using that computer and to track your use of our IGP Offerings. Cookies enhance the convenience and use of the IGP Offering. For example, the information provided through cookies is used to recognize you as a previous user of the IGP Offerings, to offer personalized content and information for your use, to track your activity at the IGP Offerings, to respond to your needs, and to otherwise facilitate your experience. You may choose to decline cookies from website IGP Offerings if your browser permits, but doing so may affect your use of the IGP Offerings and your ability to access certain features of the IGP Offerings or engage in transactions through the IGP Offerings.
    3. Web Site Tracking Information—With respect to our websites, we may use web beacons or pixel tags to compile tracking information reports regarding user demographics, traffic patterns, and purchases. We may use a third party to conduct these functions (such as the “Google Analytics” offering). We may then provide these reports to advertisers and others. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. For our own research purposes, we may link tracking information with personal information voluntarily provided by IGP Offering users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy
    4. Other Information Collected Automatically—We may receive a confirmation when you open e-mail from us, if your computer supports such capabilities. The browser or client software that you use to access IGP Offerings may transmit certain geographic information and information regarding the capabilities or features of your computer or software to us. We may also track other types of information, such as what games users download and install, any download errors, what games users purchase, how long our users have been participating in any IGP Offerings, the last time a user accessed a IGP Offering, user behaviour, gameplay, and whether a user has won any of our games, sweepstakes, contests or other promotions featured on a IGP Offering.
    5. Supplementing Information—From time to time we may supplement information you give us with information from other sources, such as information validating your address or other available information you have provided us. This is to help us maintain the accuracy of the information we collect and to help us provide better service.
  3. Storage of Your Information
    Infinite Game Publishing may process and store your information in Canada or the United States, and therefore Canadian governments, courts, or law enforcement or regulatory agencies (or, by treaty, foreign countries) may be able to obtain disclosure of your information through Canadian laws. By consenting to the information practices set out in this Policy, you specifically consent to your information being processed and stored in Canada or the United States.
    Without limiting our obligations under Section 9 below, please note that the IGP Offerings necessarily involve the use of the Internet and other public and private networks, all of which are outside of IGP’s control. Transmissions over the Internet or such networks may be intercepted by other parties or stored, cached, routed, transmitted or received in jurisdictions outside of Canada or the United States. Data, messages, information or materials sent over the Internet or such networks may not be completely private, and your anonymity on the Internet is never guaranteed. As we ourselves will be careful with your information, we ask that you also please be careful with the information you provide through IGP Offerings (for example, by limiting the public display of personally identifiable information, or by using difficult passwords that you change from time to time).
  4. Disclosure and Sharing of Your Information
    We do not sell or license your personal information to any other party. However, in the normal course of business we may share some of your personal information with our affiliates and partners, and with third parties acting on our behalf or as permitted or required by Applicable Privacy Legislation.
    1. Service Providers — We may use third party service providers ((for example, web hosting providers and/or payment processers) to manage one of more aspects of our business operations, including the processing or handing of personal information. When we do use an outside company, we use contractual or other appropriate means to ensure that your personal information is used in a manner that is consistent with this Policy. Some of these operations may result in personal information collected by us being stored or processed in the Canada and United States and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the USA PATRIOT Act and other applicable laws of the United States, as well as Canadian laws.
    2. Information Shared Amongst Our Affiliates, Subsidiaries and Divisions — We may share personal information gathered on our Web Sites with and amongst our corporate subsidiaries, affiliates or divisions for internal business purposes in accordance with this Policy. If we do, we will ensure that your information continues to be used only in accordance with this Policy and your expressed choices.
    3. Business Transfers—As we continue to grow, we might sell or buy certain subsidiaries and/or business units. In such transactions, customer information is generally one of the transferred assets, but would remain subject to the protections described in this Policy (unless you consent otherwise). Also, in the unlikely event that we (or substantially all of our assets) are acquired by another party, customer information would in most cases be one of the transferred assets. Any such transfers will be in accordance with applicable laws.
    4. Legal Disclosure—We may disclose your information as permitted or required by law. For example, we may be compelled to release information by a court of law or other person or entity with jurisdiction to compel production of such information. If we have reasonable grounds to believe information could be useful in the investigation of improper or unlawful activity, we may disclose information to law enforcement agencies or other appropriate investigative bodies.
    5. Protection of Us or Others—We may disclose your information if there is a violation of the any agreements between us and you (such as, without limitation, any Terms of Use, User Agreements, End User License Agreements); if we have a good faith belief that the law requires or authorizes it; or if needed to protect the rights, property or safety of us, our customers or others. This includes exchanging information with entities for fraud protection and credit risk reduction.
  5. Security of Personal Information
    The security of your personal information is a high priority for us. We maintain appropriate safeguards and current security standards to protect your personal information, whether recorded on paper or captured electronically, against unauthorized access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers; we employ technological tools like firewalls and passwords; and we ensure our employees are trained on the importance of maintaining the security and confidentiality of personal information. Reasonably secure methods are used whenever we destroy personal information.
    1. Forums, Chats and Messaging — IGP Offerings may operate forums, message boards or chat areas where users can exchange ideas and communicate with each other. When posting to a message board or chat area, the information is being made publicly available in an online environment. Any information posted is the sole responsibility of the individual user.
    2. Links to Other websites—Our IGP Offerings may contain links to other websites, products, services, offerings or Internet resources which are provided solely for your convenience and information. When you follow one of those external links, you are contacting another resource. We have no responsibility or liability for, or control over, those other resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other offerings to learn how they collect and use your personal information.
    3. Children—We do not offer products for purchase by children, and we do not knowingly collect personal information from children. If you are under 13, you may not use or access the IGP Offerings. IGP respects the privacy of parents and children and is committed to complying with applicable legislation. If a parent believes that his or her child has submitted personal information to us, he or she can contact the Privacy Officer (see below). We will promptly delete the information upon learning that it relates to a child under the age of 13. We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly.
  6. Requests for Access to and Correction of Personal Information
    Applicable Privacy Legislation allows any individual the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist the individual with the access request. This includes:
    1. identification of personal information under our custody or control;
    2. information about how personal information under our control may be or has been used by us; and
    3. the names of any individuals and organizations to which the individual’s personal information has been disclosed.

We will respond to requests within the time allowed by Applicable Privacy Legislation and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information we holds about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

  1. Removal of Your Information
    We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.
  2. Concerns or Questions regarding our Compliance
    Questions or concerns regarding our compliance with this Policy may be directed to the Privacy Officer:

Attention : Privacy Officer
c/o Infinite Game Publishing, Inc
1000 Sherbrooke Street West, Suite 2700, Montreal, Québec H3A 3G4, Canada