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RAW: 24 – Privacy Policy

This Privacy Policy sets out the privacy policies and practices for Hothead Games Inc. (“Hothead”) with respect to the collection, use, and disclosure of personal and non-personal information.

COLLECTION OF INFORMATION

Hothead generally collects or receives information through:

  • your use of Hothead software applications for mobile devices or other devices (“Hothead Applications”),
  • your access of Hothead’s website (www.hotheadgames.com) as operated or provided by Hothead (the “Website”).
  • Hothead collects personal information from you if you request information from Hothead or uses products or services provided by Hothead and may collect additional personal information in the course of providing that information or through your use of Hothead’s products or services. We may also collect personal information from you in the following circumstances:

    • Downloading Hothead Applications or making in-application purchases;
    • Using your mobile device to access and use Hothead Applications;
    • Visiting the Website; and
    • Contacting Hothead, such as by email, for technical support, customer service or other reasons.

    Personal information is any information about you that is personally identifiable like your name, address, email address or phone number, sign-in information for third party social networking services (if applicable), and any other information that is not otherwise publicly available. The personal information that Hothead collects will vary depending on the type of products or services that you are using, including the Website or Hothead Applications, and how you access and use those products or services.

    The personal information that Hothead collects may include your name, contact information (such as email address, mailing address, fax number, and telephone number), demographic information (such as gender, age, and occupation), and personal preferences.

    Hothead may also collect and analyze non-personal information to evaluate how visitors use the Website or Hothead Applications. Such non-personal information may include:

    • General technical information about your computer, device, hardware, or software that you use to access the Website or Hothead Applications, such as your device’s IP address, unique device identifier, MAC address, or other transactional or identifier information regarding your device or systems;
    • Information about your use and interaction with the Website or Hothead Applications. This information may include the length of time you used or played any Hothead Applications, the features of Hothead Applications that you used, your game progress, and other game-related statistics;
    • Information regarding the mobile device used to access the Website or Hothead Applications, including location information. If a mobile phone is used to access Hothead Applications, Hothead may receive your phone number from a third party; and“Cookie” information, which are small text files stored on your device when you visit websites, used namely to measure session activity on the Website and for authentication. The only information a cookie can collect is information supplied by you. A cookie cannot read data off of your device.

    DOWNLOAD OR PURCHASE OF HOTHEAD APPLICATIONS AND IN APP PURCHASES THROUGH THIRD PARTIES

    Hothead may receive information, including personal information, from organizations that distribute and/or Hothead Applications and who process payments for in app purchases within the Hothead Applications. This information may include account or registration information. The type of information provided will vary depending on the third party organization and the type of Hothead Application that is purchased, and will generally include information such as your name, email address, age, user ID and location.

    USE OF INFORMATION

    Hothead may use information, including personal information, to develop, deliver and improve Hothead Applications, the Website and other Hothead products and services and to better tailor them to meet the needs of Hothead’s users and customers. Hothead may also use information to improve Hothead’s marketing and promotional efforts and manage its relationship with you. Hothead may also use contact information provided by you to contact you in connection with Hothead Applications or the Website. Hothead may use personal information for additional purposes that may be identified at or before the time that the information is collected from you.

    Hothead will retain personal information only as long as necessary for the purposes outlined in this Privacy Policy or as required or permitted by law.

    Hothead may share personal information with third-party subcontractors and agents who work on Hothead’s behalf and third party service providers to provide certain products and services. Such third parties do not have the right to use personal information beyond what is necessary to assist Hothead, and they are contractually obligated to maintain confidentiality and security of the personal information and are restricted from using such information in any way not expressly authorized by Hothead.

    DISCLOSURE OF INFORMATION

    Hothead may disclose your personal information as follows:

    • to third party service providers and to affiliated entities in order to carry out work on behalf of Hothead,
    • to law enforcement agencies for the purposes of investigating fraud or other offences,
    • to legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of its business or operations,
    • to establish or exercise Hothead’s legal rights or defend against legal claims,as consented to by you from time to time, including to fulfill any other purposes that are identified when or before the personal information is collected, or
    • as otherwise permitted pursuant to applicable laws.

    Hothead will not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. Consent may be express or implied, and given in writing by using or not using a check-off box, electronically, orally, or by the user’s conduct, such as use of the services or products.

    ADVERTISING

    We may share the collected non-personal data for purposes of advertisement by us or our third party partners and contractors. We may employ third party ad serving technologies that collect this information through the use of tracking technologies like browser cookies and web beacons. This information may include demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service (including but not limited to IP address, unique device identifier, MAC address, software, applications, hardware and browser information, internet and on-line usage information and in-game information). The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. The information collected may be used to display to you behaviorally targeted advertising, and to undertake web or game analytics.

    OPT-OUT

    When appropriate, users of the Website or Hothead Applications are given the opportunity to (i) opt-out of receiving communications from Hothead, (ii) remove their personal information from Hothead’s records, or (iii) elect to no longer receive information from Hothead. If you wish to opt-out in the manner as listed above, please contact Hothead’s privacy officer at privacy@hotheadgames.com.

    CALIFORNIA PRIVACY RIGHTS

    California Civil Code Section 1798.83 allows users who are California residents and have provided their personal information to us to request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail or write us at:

    Hothead Games Inc.Attention: Gregan Dunn – Director of Business DevelopmentAddress: 1555 W Pender St., Vancouver, BC V6G 2T1e-mail: privacy@hotheadgames.comFax: 604.605.0017

    Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third party direct marketing purposes during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year.

    PRIVACY OF CHILDREN

    Hothead does not knowingly collect personal information from children under 13 without appropriate parental notice and consent. If you are under 13, please do not attempt to use the Hothead Applications or the Website or send any information about yourself to Hothead, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to Hothead. In the event that Hothead learns that it has collected personal information from a child under age 13 without verification of parental consent, Hothead will delete that information as quickly as possible. If you believe that Hothead might have any information from or about a child under 13, please contact Hothead’s privacy officer.

    SECURITY

    Hothead takes steps to protect the loss, misuse, and alteration of Hothead’s users’ personal information. Hothead limits access to personal information to individuals who Hothead reasonably believes need to access the information to utilize the information as set out in this Privacy Policy. However, it is possible that any information transmitted via the Internet may be intercepted by unknown third parties.

    CORRECTIONS/CONTACT

    You may contact Hothead’s privacy officer to modify or correct any of your personal information that is under Hothead’s control. You may also direct a written complaint regarding compliance with this Privacy Policy to the privacy officer and, within a reasonable time upon receiving the written complaint, the privacy officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the privacy officer will inform you whether the complaint will be allowed or denied. If the privacy officer allows the complaint, Hothead will take appropriate measure necessary to rectify the source of the complaint.

    LINKS

    Hothead is not responsible for the privacy practices of other web sites, games or applications. Hothead encourages you to read the privacy policy of web sites, games or applications operated by third parties. This Privacy Policy applies solely to information collected through Hothead Applications and the Website.

    CHANGES TO THIS PRIVACY POLICY

    Hothead may update this Privacy Policy from time to time. It is your responsibility to periodically review this Privacy Policy to remain informed of Hothead’s current privacy practices.

    CONTACT

    If you have any questions about this Privacy Policy, Hothead’s privacy practices in connection with the Website or Hothead Applications, or Hothead’s collection, use, disclosure, or retention of your personal information in connection with the Website or Hothead Applications, please contact Hothead’s privacy officer as follows:

    Hothead Games Inc.Attention: Gregan Dunn – Director of Business DevelopmentAddress: 1555 W Pender St., Vancouver, BC V6G 2T1e-mail: privacy@hotheadgames.comFax: 604.605.0017

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