Last Updated: May 12, 2023
This Privacy Policy relates to [Squad] (the “Game”). The Game is developed by Offworld Industries Ltd. (“Offworld”, “we”, “us”, “our”), and is hosted and operated by us and/or our third party game server hosting provider(s).
We address this Privacy Policy to every individual who plays our Game (“Player”, “you”, or “your”) to convey how we collect, use, store, transfer, disclose, or otherwise process personal information we have collected from you when you access or play our Game. For visitors to our website, https://www.joinsquad.com/ (“Website”), we have a separate privacy policy that is intended to inform you how we collect, use, store, transfer, disclose, or otherwise process personal information through our Website or in your correspondence with us through our Website. We invite and strongly encourage you to carefully read this Privacy Policy and the privacy policy on our Website.
If you reside in California, please also see our California Consumer Privacy Act (CCPA) Notice at Collection further below for additional information we are required to provide to you under California law. If you reside in Virginia, please also see our Virginia Addendum further below for additional information we are required to provide to you under Virginia law.
If you are in the European Union (“EU”), European Economic Area (“EEA”) or the United Kingdom (“UK”), please also see our EU/EEA Addendum further below for additional information regarding the processing of your personal information.
Important Notice
We do not knowingly collect or process any personal information from individuals under the age of majority or anyone who does not understand or agree to this Privacy Policy. This Game is not directed to any person under the age of majority. If you are under the age of majority in the province, state or country from which you wish to access and play this Game, or do not understand or agree to this Privacy Policy, we kindly ask you not to use our Game, and to not disclose or communicate any of your personal information to us (any information that would allow you to be personally identified). If we are made aware that we have unknowingly collected any personal information from a minor, and are asked to erase such information from our database, we will do so without undue delay. By accessing or playing our Game, and by sharing any of your personal information through our Game, you agree to this Privacy Policy and represent and warrant to Offworld that you have reached the age of majority in the province, state or country from which you are accessing and playing this Game. If you do not understand or agree to this Privacy Policy or are a minor, please do not access or play our Game.
Changes To This Privacy Policy
This Privacy Policy may be amended from time to time. The most current version of our Privacy Policy will be marked with the “Last Updated” date listed at the top of this Privacy Policy. We invite and encourage you to regularly review the latest version of this Privacy Policy before playing our Game.
WHAT PERSONAL INFORMATION WE COLLECT FROM YOU
From time to time, we may collect personal information from you when you play our Game, whether your personal information is volunteered to us in the context of our Game or we need to collect your personal information for the purpose of operating the Game. We may collect the following personal information from you:
• Profile data: personal information when you setup the Game and your profile, including your name, display name, country of origin and your user ID.
• Game related data: information relating to your gameplay within the Game and application usage, including your in-game progression (i.e. your game level, scores, gameplay progress, battle statistics, match data, results), saved preferences, and how you interact with the Game and any information you provide to us through the Game;
• Chat and audio data: if you enable text or voice chat in-Game, we may process such data in order to deliver your messages to other users of the Game;
• In-game transactions: if you conduct transactions in relation to the Game, we may collect such information to facilitate your transaction and may maintain transaction records (which may include user ID, country and user information, cost, currency, product purchased, purchase history, IP address, details of transactions linked to user ID, and device details such as network type, network monitoring data)
• Crash data: personal information contained in crash reports, which may include Game and log-related data from when you play or open the Game, and information which may allow a Player to be personally identified by their unique identification code;
• Hardware information: technical information which may be automatically collected about your computer, device or hardware when you access or play our Game, including information about your web browser type, Internet Protocol (“IP”) address, user ID, device identifiers, hardware information (such as operating system and version, network information including strength and type, processes, modules, hardware specifications including driver information, make and model) and cookies that are installed on your device;
• Other: any other personal information which you may voluntarily disclose to us for the purpose of responding to your requests or providing support or updates to you in relation to the Game.
Purposes For Which We Collect And Use Your Personal Information
We may collect, use, store, transfer, disclose or process your personal information for the following purposes:
• hosting and administering game servers and enabling and moderating your gameplay of the Game including providing you feedback and information about your gameplay and progress, allowing you to connect to our servers and playing with other players, ensuring your smooth gameplay experience;
• to communicate with you including but not limited to responding to your questions or concerns, sending notifications, updates and emails to you about the Game, soliciting feedback from you about the Game, sending you administrative information such as updates to this Policy, and sending you news and general information about the Game and any other of our similar games, unless you have opted not to receive such information;
• providing IT systems and support to any Player of the Game to enable us to identify and resolve issues in our IT systems, keep our systems secure against privacy-related breaches, unauthorized accesses to, or disclosures of, personal information, respond to your requests and questions and provide overall support to you on the Game;
• facilitating and coordinating your access to and compatibility for other third party service providers that may host our products or services, or perform various functions on our behalf in relation to the Game. We may, from time to time, provide or transfer your personal information to affiliated and non-affiliated third party service providers who support the Game or our business, and perform various functions on our behalf, including without limitation cloud service, server hosting and data storage providers, maintenance service providers, customer service providers, data, game and web analytics service providers, and technical support providers for the purpose of enhancing our Game, your experience, or for general support;
• improving our marketing efforts and monitoring usage and other analytics to improve and enhance our Game, which may include providing or transferring your personal information to third party services providers that determine the effectiveness of our marketing campaigns relating to the Game, or monitor, track, analyse and report data relating to the use of the Game (e.g. Gamesight and Microsoft Playfab);
• compliance with our legal and regulatory obligations, such as if we are asked or required to disclose any of your personal information to a regulator, judicial authority, law enforcement agency or any other applicable authorities;
• facilitating potential or actual acquisitions, disposals, mergers, or joint ventures, including enabling due diligence to be conducted by potential buyers or joint venture partners, and negotiations to take place, and enabling a buyer to prepare to comply with future obligations;
• improving the Game in light of the feedback and opinions you may provide;
• to collect debts owed to Offworld; and
• protecting each Player and Offworld against fraud, cheating and spams relating to the Game, or to help prevent the loss of life or serious injury of anyone or any Player of the Game, which may include providing or transferring your personal information to third party service providers that provide services such as cheat prevention tools and player account authentication (e.g. Easy Anti-Cheat/ Epic Online Services).
The purposes listed above are a reasonably necessary part of your relationship with us.
Transfers And Disclosures Of Personal Information
Your personal information may be stored, used, or processed by us, our affiliates or our service providers, in support of the Game, both inside and outside of Canada. This means that personal information we collect from you in one province could be transferred or communicated outside of that province or outside of Canada.
As a result, that jurisdiction’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws, which may differ from terms in this Privacy Policy.
Whenever we hire other organizations to provide support services, they will be required to conform to our privacy standards and to allow us to audit them for compliance. [Service providers we use may be located in the United States and may have servers located in other jurisdictions such as Europe].
Security And Retention
We take steps intended to protect the security and confidentiality of your personal information. We protect the personal information within our custody or control with appropriate organizational, technological and physical safeguards.
Our security measures include restricted access to records and data processing equipment, password protocols, and encryption and security software. We conduct audits and monitor compliance with our privacy practices.
We only retain personal information for as long as is necessary for the purpose for which it was collected. When we are no longer required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold.
Rights To Your Personal Information
In some jurisdictions, you may have the right to access personal information that we currently hold about you, request to rectify or correct your personal information, and withdraw your consent to our collection and use of your personal information. For more information about how you can exercise any of these rights, please do not hesitate to contact us using the contact information provided below.
Anti-Spam
Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. This consent is sought by Offworld Industries, Ltd. and you can contact us at contact@offworldindustries.com if you have any questions. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message.
Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive about products or services we provide to you. We may also contact you in response to any inquiries or requests you submit to us using contact details herein.
By accessing or playing our Game, you acknowledge and agree that you will not use the Game, or any functionalities contained therein to transmit unsolicited marketing communications, harassing or hateful content, or for any illegal activities in Canada, its provinces, or anywhere else in the world.
Contact Us
If you have any comments, questions, or concerns related to the contents of this Privacy Policy or our information practices on our Website, please do not hesitate to contact our Privacy Officer using the contact information provided immediately below:
Privacy Officer,
Offworld Industries Ltd
privacy@offworldindustries.com
California Consumer Privacy Act (CCPA) Notice At Collection – Squad
These additional disclosures supplement the Privacy Policy above and apply to you only if you reside in California. These disclosures do not reflect our practices where an exception applies under the California Consumer Privacy Act of 2018 or its regulations (“CCPA”).
Please see “WHAT PERSONAL INFORMATION WE COLLECT FROM YOU” above for information about the categories of personal information that we collect from you when you play our Game. These categories correspond with the following categories listed in the CCPA’s definition of personal information:
• Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application.
• Geolocation data.
• Audio or similar information.
We only collect sensitive personal information, as the CCPA defines this term, if you voluntarily disclose it to us.
Please see “PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL INFORMATION” above for information about the purposes for which we use your personal information. We do not “sell” or “share” (as the CCPA defines these terms) personal information about you. We retain each of the categories of personal information collected under this Notice at Collection as long as necessary to fulfil the purposes for which it was collected and comply with applicable legal requirements, in accordance with this Privacy Policy, per “SECURITY AND RETENTION” above.
Virginia Addendum
These additional disclosures supplement the Privacy Policy above and apply to you only if you reside in Virginia. These disclosures do not reflect our practices where an exception applies under the Virginia Consumer Data Protection Act (“VCDPA”).
Please see “WHAT PERSONAL INFORMATION WE COLLECT FROM YOU” above for information about the categories of personal data that we collect, use, disclose and otherwise process when you play our Game. Please see “PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL INFORMATION” above for information about the purposes for which we process your personal data and the categories of third parties to whom we may disclose personal information. We do not sell personal data to third parties or process personal data for targeted advertising.
Under the VCDPA, Virginia residents have the following rights subject to applicable limitations:
• Confirm whether or not Offworld is processing the consumer’s personal data and to access such data;
• Correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data;
• Delete personal data provided by or obtained about the consumer;
• Obtain a copy of the consumer’s personal data that the consumer previously provided to Offworld in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
• Opt-out of the processing of the consumer’s personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not engage in these types of processing.
If you are a resident of Virginia, you may exercise these rights by contacting us at the details under “CONTACT US” above. We may request information from you to verify your identity. If we decline to take an action regarding your request, we will inform you of this, including the justification for declining to take action and instructions on how to appeal the decision. We will inform you of any action or inaction taken in response to such appeal. If the appeal is denied, you may contact the Virginia Attorney General to submit a complaint.
EU/EEA and UK Addendum
In addition to the information provided in this Privacy Policy above, the information in this EU/EEA and UK Addendum below applies to users that are in the EU, EEA and UK.
For the purposes of EU/EEA and UK data protection laws, Offworld Industries Ltd, privacy@offworldindustries.com, is the controller of the personal information that we collect from you or that you provide to us.
How We Use Your Personal Information And Our Legal Basis For Processing
We process your personal information for the following purposes and rely on the legal bases set out in the table below under EU/EEA and UK data protection laws to process your personal information:
• hosting and administering game servers and enabling and moderating your gameplay of the Game including providing you feedback and information about your gameplay and progress, allowing you to connect to our servers and playing with other players, ensuring your smooth gameplay experience; It is necessary for our legitimate interests to administer Game server hosting and moderation of the Game. It is also necessary for performance of our contract with you.
• to communicate with you including but not limited to responding to your questions or concerns, sending notifications, updates and emails to you about the Game, soliciting feedback from you about the Game, sending you administrative information such as updates to this Policy, and sending you news and general information about the Game and any other of our similar games, unless you have opted not to receive such information;Where we are required to obtain your consent to send you unsolicited electronic direct marketing messages, we rely on your consent. In all other circumstances, it is necessary for our legitimate interests to contact you to respond to your questions or concerns and to communicate with you regarding updates to our Game.
• providing IT systems and support to any Player of the Game to enable us to identify and resolve issues in our IT systems, keep our systems secure against privacy-related breaches, unauthorized accesses to, or disclosures of, personal information, respond to your requests and questions and provide overall support to you on the Game; It is necessary for our legitimate interests to identify and resolve IT issues and to keep our systems secure and to support players of our Game.
• facilitating and coordinating your access to and compatibility for other third party service providers that may host our products or services, or perform various functions on our behalf in relation to the Game. We may, from time to time, provide or transfer your personal information to affiliated and non-affiliated third party service providers who support the Game or our business, and perform various functions on our behalf, including without limitation cloud service, server hosting and data storage providers, maintenance service providers, customer service providers, data, game and web analytics service providers, and technical support providers for the purpose of enhancing our Game, your experience, or for general support; It is necessary for our legitimate interests to facilitate and coordinate access to and compatibility for other third party service providers that host our products or services for the purposes of providing and enhancing our Game and your experience.
• improving our marketing efforts and monitoring usage and other analytics to improve and enhance our Game, which may include providing or transferring your personal information to third party services providers that determine the effectiveness of our marketing campaigns relating to the Game, or monitor, track, analyse and report data relating to the use of the Game (e.g. Gamesight and Microsoft Playfab); It is necessary for our legitimate interests to improve the effectiveness of our marketing campaigns and to make any marketing more relevant to you.
• compliance with our legal and regulatory obligations, such as if we are asked or required to disclose any of your personal information to a regulator, judicial authority, law enforcement agency or any other applicable authorities; It is necessary to comply with legal obligations that we are subject to.
• facilitating potential or actual acquisitions, disposals, mergers, or joint ventures, including enabling due diligence to be conducted by potential buyers or joint venture partners, and negotiations to take place, and enabling a buyer to prepare to comply with future obligations; It is necessary for our legitimate interests in relation to facilitating potential or actual acquisitions, disposals, mergers or joint ventures.
• improving the Game in light of the feedback and opinions you may provide; It is necessary for our legitimate interests to process information regarding feedback and opinions that you share with us in order to improve and enhance our Game.
• to collect debts owed to Offworld; It is necessary for our legitimate interests to collect debts which are owed to Offworld.
• protecting each Player and Offworld against fraud, cheating and spams relating to the Game, or to help prevent the loss of life or serious injury of anyone or any Player of the Game, which may include providing or transferring your personal information to third party service providers that provide services such as cheat prevention tools and player account authentication (e.g. Easy Anti-Cheat/ Epic Online Services). It is necessary for our legitimate interests in order to protect our players against fraud, cheating or scams in relation to the Game. It is also necessary for the protection of vital interests of the data subject to prevent loss of life or serious injury.
The provision of your personal information may be necessary for the purposes of entering into a contract with us or to receive the products and/or services you request, or may otherwise be voluntary. However, if you do not wish to provide your personal information to us, we may not be able to: (a) provide the products or services you request, or (b) tell you about other products and services that we offer.
Transfers Of Your Personal Information
If you are located in the EU/EEA or UK, your personal information may be transferred outside of the jurisdiction in which you are located. We may transfer your personal information to jurisdictions that are deemed as adequate for the purposes of EU/EEA and UK data protection laws, for example Canada, and where that is not the case we will ensure appropriate safeguards are in place under EU/EEA and UK data protection laws. For more information, please contact us at the details above (please see “Contact Us” above).
Retention Of Your Personal Information
We only retain personal information for as long as is necessary for the purpose for which it was collected. When we are no longer required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold.
To determine the period for which it is necessary to process and retain your personal information, we take into account the type of personal information collected, the purpose(s) for which the personal information was collected, the duration for which it is necessary to process that personal information for those purposes, and any legal, regulatory or other obligations that we may be subject to or applicable limitation periods for bringing or defending potential legal claims under applicable laws.
Your Rights
Under EU/EEA and UK data protection laws, you have certain rights which we have summarised below:
• Access: You have the right to confirm with us whether your personal information is processed by us. If we process your personal information, you have the right to request access to that personal information including the categories of personal information processed, the purpose of the processing and the recipients or categories of recipients.
• Rectification: You have the right to rectify inaccurate or incomplete personal information concerning you. You have the right to have incomplete personal information completed.
• Erasure: In certain circumstances, you may have the right to ask us to erase personal information concerning you.
• Restriction of processing: In limited circumstances, you may have the right to request that we restrict processing of your personal information.
• Data portability: In certain circumstances you may have the right to receive personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to request that we transmit that personal information to another entity.
• Objection and rights relating to automated decision-making: Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information, including profiling, by us and we can be required to no longer process your personal information. For example, you have the right to object to our processing of your personal information on the basis of our legitimate interests, under certain conditions. You also have the right to object to our processing of your personal information for direct marketing purposes as set out below. If we process your personal information using automated decision making which has a legal or similarly significant effect on you, you may have the right to request intervention in relation to such an automated decision so that you can express your view and to contest the decision.
• Direct marketing: You have the right to withdraw your consent for receiving direct marketing from us at any time. You can do this for example by clicking on the “unsubscribe” link in the email that we have sent to you, or by contacting us at the details above (please see “Contact Us” above).
• Withdrawal of consent: If we process your personal information on the basis of your consent, you have the right to withdraw your consent at any time.
You also have a right to lodge a complaint with a data protection authority in your jurisdiction:
• If you are in the UK, your supervisory authority is the Information Commissioner’s Office (ICO) (www.ico.org.uk).
• If you are in the EU/EEA, you can find contact details for the data protection authority in your jurisdiction here.
