Last updated: October 6, 2023
ABOUT US
This privacy policy (“Privacy Policy”) conveys how Offworld Industries Ltd. (“we”, “us”, “our”) collects, uses, stores, transfers, discloses or otherwise processes your personal information, whether we have collected your personal information through our website https://www.joinsquad.com (“Website“), in communications with us, or through any other means set out in this Privacy Policy. For greater certainty, if you play any one or more of our game(s), personal information collected from you when you access or play such game(s) may be governed by a separate privacy policy that is specific to such game(s).
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 Website 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 use this Website, or do not understand or agree to this Privacy Policy, we kindly ask you not to 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 and browsing our Website, and by sharing any of your personal information through our Website, 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 this Website. If you do not understand or agree to this Privacy Policy or are a minor, please do not access, use or browse our Website.
WHAT PERSONAL INFORMATION WE COLLECT FROM YOU
From time to time, we may ask you to provide your personal information, including when you visit the Website, submit an inquiry to us, inquire about employment opportunities, or engage with us for promotional purposes. In particular, we may collect the following types of personal information from you: your full name, contact information (including your home or work address, telephone number, email address, or any other information you supply to us for contact purposes), any opinions or other personal information you volunteer to us using our Website or online forms thereon, and any personal information you share with us in job applications you send us (e.g. your educational history, qualifications, work preferences, accommodation requests, list of references, and attitudes and opinions contained therein, as well as information about the job openings that you apply for). Our Website also contains links to third party sites and social media platforms, such as links to Twitter and Facebook, which you can click to log into those third party platforms and engage with those platforms. We may retain your personal information for as long as permitted under applicable law.
We collect some information that is not attributable to any identifiable individual. For example, when you visit our Website, our web server automatically recognizes your computer’s domain name, type of browser and operating system you are using, the date and time you visit a particular page, and the address of the website you visited before you visited our Website. Likewise, this site may use “cookies”, which are small text files sent from our Website to the hard drive of your computer or device to store bits of information related to your interaction with our Website. Although you can configure your web browser to reject cookies, you might not be able to access certain pages or use certain functions of our Website if you disable cookies on your web browser. For more details, please refer to “Cookies” section of this Privacy Policy below.
Our Website also allows you to share certain information, which could include your personal information, through social media networks such as Twitter and Facebook. When you click on the social media buttons on our page (e.g. Twitter or Facebook buttons on the bottom of our Website), you may be able to share personal information from your browser to the social network provider. Where you decide to share your personal information to any social media network, the personal information you share will be subject to the social network provider’s own terms of use and privacy policies.
We may also collect information, including personal information, on what pages you access or visit, either directly or via third parties such as Google Analytics. The information, including personal information, we collect is used for many different purposes in order to serve you better. Among these purposes are to improve the content of the Website, and to customize the content and/or layout of the Website for each individual visitor.
PURPOSES FOR WHICH WE COLLECT AND USE YOUR PERSONAL INFORMATION
We collect, use, store, transfer, disclose and otherwise process your personal information for a variety of purposes, as follows:
- complying with corporate financial and regulatory responsibilities, including audit requirements (both internal and external) and cost/budgeting procedures, which involves the processing of identification information, contact details, information about customers, and job applications;
- to facilitate 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 their future obligations;
- complying with applicable laws, regulatory, and employment-related requirements along with the administration of those requirements, which involves the processing of identification information, contact details, information about employees and customers;
- responding to and complying with requests and legal demands from regulators or other authorities in or outside of your home country which involves the processing of personal information, contact information, information about employees and customers;
- providing IT systems and support to customers, job applicants, and users of our Website, and to enable us to identify and resolve issues in our IT systems, and to keep our systems secure against privacy-related breaches or unauthorized accesses to, or disclosures of, personal information;
- monitoring and ensuring compliance with applicable policies and procedures and laws, including conducting internal investigations or cooperating with external investigations, which involves the processing of personal information;
- communicating with you, which involves the processing of identification information, contact details, information about your job application, respond to your questions or any forms submitted on our Website;
- improving our marketing efforts and Website, including tailoring our Website and web forms to your preferences, which involves tracking pages you visit and requests you made on our Website.
- confirming your identity for the purpose of responding to your requests and making hiring decisions;
- marketing of our products and services to you, if you have consented to receive marketing or other communications in electronic form, such as newsletters, special offers and general information about our products and services; and
- facilitating and coordinating your access to and compatibility for other third party service providers that may host our products or services.
The purposes listed above are a reasonably necessary part of your relationship with us. We may otherwise use your personal information where permissible by law, for example to respond to an emergency, or in the course of an investigation into illegal behavior.
ANTI-SPAM
Where applicable and required by applicable laws, we will seek your express consent to send you communications in electronic form, including by way of commercial electronic messages. Please contact us at privacy@offworldindusties.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 as permitted by applicable laws. For example, we may contact you to provide other forms of communications you have consented to receive, regarding the products or services we provide to you, or if you contact us with an inquiry, or communications that form part of our existing business relationship with you.
TRANSFERS AND DISCLOSURES OF PERSONAL INFORMATION
We will not disclose your personal information to any external organization without your consent unless we are required or permitted to do so by law, or unless you are otherwise informed in this Privacy Policy, including in the event of a corporate amalgamation, reorganization, change of control or sale.
Your personal information may be stored, processed or otherwise used by us, our affiliates or our service providers using resources and servers located outside of the country in which you access the Game, or in jurisdictions outside Canada. As a result, such country’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws. Such affiliates or service providers may include entities that process personal information for purposes such as:
- processing and administrating job applications and our hiring and recruitment process
- improving our marketing efforts and monitoring usage and other analytics to improve and enhance our Website, which may include providing or transferring your personal information to third party services providers that determine the effectiveness of our marketing campaigns
- improving our Website, including tailoring our Website and web forms to individual preferences, which involves tracking pages you visit and requests you made on our Website
- affiliated and non-affiliated service providers who support our games and our business, and perform various functions on our behalf, including without limitation cloud service, web hosting, payment processing, 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 games, business, your experience, or for general support
- 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; and
- 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.
Whenever we hire other organizations to provide support services, they will be required to conform to our privacy standards. Service providers we use may be located in Canada, the United States, the United Kingdom, the European Union and/or other jurisdictions, and may have servers located in multiple jurisdictions.
SECURITY AND RETENTION
We take steps 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 only retain personal information for as long as is necessary for the purpose for which it was collected. When we no longer are 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.
COOKIES
We may use “cookie” technology to obtain non-personal information from visitors to the Website, including the use of Google Analytics. Cookies are pieces of information stored on a user’s computer by a website so preferences are remembered on future requests. Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. Cookies allow us to customize your user interface to speed up the navigation process and to make the Website experience more efficient. They also allow us to analyze how visitors engage with the Website. If your browser is configured to reject cookies, you will not be able to use the features of the Website. When you log in, a cookie can tell us whether you’ve visited us before or are a new visitor. We do use the cookie to help us identify Website features in which you have the greatest interest, so that we can provide you with more of what you want.
THIRD PARTY LINKS
The Website may contains links to other websites operated by third parties. Clicking on a third party link will direct you to that third party’s website and we cannot be responsible for personal information that third parties may collect, store and use, including through their websites. You should always read the privacy policy of each website you visit carefully.
CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time as we add new products and services, update our practices, as we improve our current offerings, and as technologies change. If we make a change to this Privacy Policy this will be reflected in the above Last Update date. We encourage you to check back periodically to see if we have made any changes. If we make any material or substantive changes in this Privacy Policy, we will notify you by posting a clear and conspicuous notice of these changes on the Website and in this Privacy Policy.
ACCESS, CORRECTION AND ACCOUNTABILITY
We will strive to keep all personal information in our files complete, up-to-date and accurate.
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. You or a person authorized on your behalf has the right to request to see and obtain a copy of your personal information and to request changes or corrections to inaccurate or incomplete 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.
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
CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE AT COLLECTION – WEBSITE USERS
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 use our Website, which includes submitting an inquiry to us, placing an order for our products or services, or engaging with us for promotional purposes. These categories correspond with the following categories listed in the CCPA’s definition of personal information:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, 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, address, and telephone number.
- 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.
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.
Please find our CCPA Privacy Policy, which includes additional information about how we process California residents’ personal information and California residents’ privacy rights, here: www.offworldindustries.com/ccpaprivacypolicy.
CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE AT COLLECTION – JOB APPLICANTS
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 apply for a job with us. These categories correspond with the following categories listed in the CCPA’s definition of personal information:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, 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, address, telephone number, education, employment, employment history, or medical information.
- Professional or employment-related information.
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
- Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s characteristics, attitudes, and abilities.
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.
Please find our CCPA Privacy Policy, which includes additional information about how we process California residents’ personal information and California residents’ privacy rights, here: www.offworldindustries.com/ccpaprivacypolicy.
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 use our Website that includes submitting an inquiry to us, placing an order for our products or services, inquiring about employment opportunities, or engaging with us for promotional purposes. 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 individuals that are in the EU, EEA and UK.
For the purposes of EU/EEA and UK data protection laws, Offworld Industries Ltd., privacy@offworldindusties.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:
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, (b) tell you about other products and services that we offer, or (c) consider your job application.
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, and where that is not the case we will ensure appropriate safeguards are in place in accordance with EU/EEA and UK data protection laws.
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.
