REVERSEWINTERSTUDIOS PRIVACY POLICY

Last updated on August 5th, 2020

The ReverseWinterStudios Privacy Policy is designed to help you better understand the information we collect and the different ways we may use or share it.

This policy applies to your use of the ReverseWinterStudios services. By “ReverseWinterStudios services,” we mean any of our websites, stores, games, game developer tools, applications, or other products or services that link to this policy. Additional terms and conditions may also apply to your relationship with ReverseWinterStudios, depending on how you choose to interact with us. Please read this entire policy to make sure you fully understand it. You should also be sure to carefully review other terms potentially applicable to your visit and your use of specific ReverseWinterStudios services (such as Bloodland or the use of your ReverseWinterStudios Account with third-party games), and confirm that you understand and agree to them, before using the ReverseWinterStudios services.

ReverseWinterStudios and our subsidiaries operate and support the ReverseWinterStudios services from different locations around the world. When we say “Reverse”, we’re referring to the relevant ReverseWinterStudios entity identified for your region in the “How to Contact Us” section of the policy below. This ReverseWinterStudios entity is responsible for providing the ReverseWinterStudios services to you and is the controller of the information collected under this policy.

Please see “Contact Us” below to learn more about sending us any privacy-related questions or concerns you may have.

 

Information We Collect

We generally collect information in three ways: (1) you voluntarily provide information to us, such as by creating an account, making purchases, or signing up for email alerts, (2) we collect information automatically from your use of the ReverseWinterStudios services, such as through cookies or our games and other software, and (3) other parties, such as game console platforms and social networks, may provide information to us. Each of these methods is described in more detail below.

 

(1) Information You Provide

You may provide your personal information to us when you choose to use the ReverseWinterStudios services. Because we change our offerings and features from time to time, the options you have to provide us with information also may change. Some of the most common examples of situations in which you may provide information to us include:

• Creating a ReverseWinterStudios account;
• Licensing and downloading our games;
• Using the ReverseWinterStudios services’ social features (see “When You Use Social Features of the ReverseWinterStudios Services”);
• Purchasing something from us or otherwise engaging in a transaction with us;
• Signing up for email alerts or subscribing to receive other information from us;
• Completing a survey;
• Using a mobile device, such as a phone, to play our games or use our applications; and
• Contacting us for any reason, such as by email, including for technical support or customer service.

The specific types of information you may be able to provide us will often vary depending on the ReverseWinterStudios services you are using and how you interact with them.

For example, you’ll need a ReverseWinterStudios account to access certain parts of the ReverseWinterStudios services. If you’d like to create one, you may be asked to provide basic registration details like your name, a public-facing display name, password, country of residence, and email address. We automatically assign each new ReverseWinterStudios account with a number (a “ReverseWinterStudios account ID”) during the registration process, which helps to uniquely reference your ReverseWinterStudios account across the ReverseWinterStudios services and facilitate features like cross-play.

If you’d like to make a purchase or add funds to your account we may ask you to provide billing information (like your card’s payment account number and expiration date if you are making a credit card purchase) to enable the transaction. Sometimes we ask for other information like your phone number, postal address, billing address, and date of birth. We’ll also collect information when you choose to share it with us directly in any other way, including by sending it as part of a communication with ReverseWinterStudios (like through Support requests) or other users of the ReverseWinterStudios services (like through in-game chat or blog posts).

 

(2) Information We Collect Automatically

We collect information automatically through technologies such as web browsers, cookies, log files, web beacons, and our back-end servers collect usage data transmitted from the ReverseWinterStudios services. We use the information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud or misuse of our services, and conducting data analytics. The type of information that we automatically collect may vary, but generally includes:

• Technical information about your computer, device, hardware, or software you use to access the Internet or our services, such as IP address or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications);
• Usage information and statistics about your interaction with the ReverseWinterStudios services, which may include the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, the application you used or the game you played, how long you used or played it and when, and other usage statistics;
• Crash reports, which may be automatically generated when a game or application crashes and includes information about your system and the crash;
• Information that facilitates a safer and more personalized experience, such as your display name or other user identification provided in connection with your application use or gameplay, saved preferences, game progress, and device identifiers or usage information for authentication and fraud prevention purposes; and
• The location of your device, such as may be derived from your device’s IP address.

Please note that if certain features on the ReverseWinterStudios services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the ReverseWinterStudios services or others’ websites over time. These features are subject to those third parties’ privacy notices and policies.

 

Fraud Prevention & Anti-Cheat:

Providing users with a fair, balanced, and competitive experience on the ReverseWinterStudios services is extremely important to us. We strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity on the ReverseWinterStudios services. When you create a ReverseWinterStudios account, buy our products or services, play our games, or otherwise interact with the ReverseWinterStudios on or through the ReverseWinterStudios services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about the game binary or your computer to detect cheating, and may be provided by ReverseWinterStudios.

 

(3) Information We Receive from Others

In some cases, other parties provide us with information about you or allow us to collect information about you. We generally collect information from other parties in four ways: (1) you interact with ReverseWinterStudios using a service that is not controlled by us, such as a social network, (2) you choose to use a social feature of the ReverseWinterStudios services, (3) you access ReverseWinterStudios services through another party, such as a gaming console or mobile device operator, or (4) you link a third-party account to your ReverseWinterStudios account. In some cases, we are not able to control the amount or type of information that other parties, like social networks, make available to us. In those cases, we use only the data that we need to provide the types of services we think our users want and expect. Although we cannot control your privacy settings at those websites or how those other parties protect your privacy, once we receive information about you through those websites, we will treat it in accordance with this policy.

 

When You Interact with ReverseWinterStudios on Third Party Services

When you interact with ReverseWinterStudios on a website or app not controlled by ReverseWinterStudios, that website or app may allow ReverseWinterStudios access to certain information about you. For example, social networks may provide us with information from your profile on their services or other information that you agreed the social network or other parties could provide to us.

 

When You Link a Third-Party Account to Your ReverseWinterStudios Account

If you choose to link a third party account, such as a gaming console or social media account, to your ReverseWinterStudios account, the third party will provide ReverseWinterStudios with information about that account. Because those organizations determine what information they will collect from you, it may vary according to their services, but is likely to include details such as your third party account display name and user ID, as well as associated device information, name, and email address.

 

How We Use and Share Information

As a general matter, we use and share the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and market the ReverseWinterStudios services where we have an appropriate basis to do so.

 

(1) Use

We rely on several different legal bases to process personal information for the purposes disclosed in this policy. These often depend on the exact nature of your relationship with ReverseWinterStudios, but common examples include:

• To support our legitimate interests, such as:

• To communicate with you, respond to your requests, or provide you with updates and information;
• To better understand our users and their preferences;
• To personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;
• To develop, deliver, and improve our products, services, and other offerings, some of which may be offered in partnership with other parties;
• To manage and customize advertisements or promotional offers;
• For security purposes; and
• For internal purposes such as auditing and data analysis.
• To provide services that are subject to terms you have accepted, such as enforcing our licenses, agreements, and terms of service, which may include reasonable monitoring to detect and prevent misuse or fraud, keep our games fair for all users, and otherwise protect and defend the ReverseWinterStudios services.
• When you give consent, which you can withdraw at any time.
• To comply with legal obligations.

We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected. For example, if you create a ReverseWinterStudios account, we will store the personal information associated with your ReverseWinterStudios account for as long as needed to maintain your account, provide the ReverseWinterStudios services you requested, enforce any applicable terms that govern your use of the ReverseWinterStudios services, and maintain appropriate records to reflect our delivery of the ReverseWinterStudios services to you. We periodically review the personal information we retain to determine whether continued storage is proper. 

 

(2) Sharing

Service Providers. We share personal information with service providers that we’ve engaged to help support the ReverseWinterStudios services by performing certain services on our behalf and under our instructions. For example, if you make a purchase on the ReverseWinterStudios services, we’ll generally share your billing information with a third-party payment processor to enable your transaction. Other common examples include partners that assist with cloud storage, email marketing of products and services offered by ReverseWinterStudios, Support ticketing, and monitoring and securing the ReverseWinterStudios services. These service providers are not authorized by us to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements.

Affiliates: We may share personal information we collect with ReverseWinterStudios. subsidiaries to support ReverseWinterStudios services worldwide. 

Marketing Partners: We may share certain limited information, such as device identifiers, with marketing partners for purposes of executing and optimizing campaigns, and gauging the effectiveness of advertising and other marketing strategies solely on ReverseWinterStudio's behalf.

ReverseWinterStudios Store Partners: If you purchase a game from the ReverseWinterStudios Store, we may share certain information associated with your ReverseWinterStudios account with the game’s developer or publisher to support your gameplay and permit them to contact you for appropriate purposes. For example, to support gameplay we may share your ReverseWinterStudios account ID and entitlement to the game. To support in-game social features we may also share your ReverseWinterStudios display name and your ReverseWinterStudios friend's list. You may also opt-in to share your contact information with a game developer or publisher.

If a store partner removes their game from the ReverseWinterStudios Store, we also will transfer information necessary to support your continued gameplay on another platform to them. When ReverseWinterStudios provides your information to these independent developers and publishers, their use and disclosure of the information is governed by limitations in our agreements with them. However, they also provide their end-users with privacy notices or policies that govern their use of your information. Personal information you share with them or that is not provided by ReverseWinterStudios will be subject to the developers’ and publishers’ privacy notices and policies, and may not be subject to this policy.

ReverseWinterStudios Account Services: If you sign in to a third-party developer’s game or application using your ReverseWinterStudios account, you may choose to share details about your ReverseWinterStudios account such as your ReverseWinterStudios account ID, ReverseWinterStudios display name, linked account identifiers, online presence, and your ReverseWinterStudios friends using the same game or application. These third-party developers’ uses of this ReverseWinterStudios account information is governed by limitations in our agreements with them. Personal information you share with them or which is not provided by ReverseWinterStudios is subject to the third-party developers’ privacy notices and policies, which may differ from ReverseWinterStudio’s practices as described in this policy. Please review third-party developers’ privacy policies carefully, and ensure you understand and are comfortable with how they handle your information, before using your ReverseWinterStudios account to access their products or services.

Social Features: We may share, or provide you with opportunities to share, information about you with other users of the ReverseWinterStudios services as described in this policy. We also provide services that allow our users to communicate with ReverseWinterStudios and each other, in which case personal information may be shared and account IDs may be displayed. For example, we may share information about you with your social contacts when you and they use the same social features of our games and applications.

We may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iii) if necessary to protect the vital interests of another individual (such as to prevent death, bodily harm, or serious damage to property). We reserve the right to transfer information about our users in the event we sell or transfer all or substantially all our business or assets.

 

How We Protect Information

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases, you need to keep your user credentials and password confidential and secure so that your information is protected. 

 

Children’s Privacy

The ReverseWinterStudios services are intended to be appropriate for general audiences and are not directed to children (usually considered to be under 13, depending on where you reside). ReverseWinterStudios does not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).

We may ask you to provide age-related information in order to help us comply with laws like COPPA. For example, we may request your date of birth to determine whether COPPA requires us to obtain verifiable parental consent from your parent or guardian before allowing you to access the ReverseWinterStudios services.

If a user indicates they are a COPPA minor, we’ll require that user to complete a parental approval process before continuing to access the relevant ReverseWinterStudios services. This process is designed to notify parents that their child has requested access to the ReverseWinterStudios services, inform them about ReverseWinterStudio's privacy practices, offer them the opportunity to approve ReverseWinterStudios’s collection and use of their child’s information as described in this policy, and describe the controls that we make available to them.

Authorized child accounts are otherwise treated much like other ReverseWinterStudios accounts. They can generally play approved games, access communications and social features (like chat and friends lists), and freely interact with most of the ReverseWinterStudios services (including downloading other games from the ReverseWinterStudios Store). For additional details, please see the “Information We Collect” and “How We Use and Share Information” sections of the policy above.

 

Transfers of Information

ReverseWinterStudios is a company with operations around the world. By using the ReverseWinterStudios services, you acknowledge and agree that your information may be processed outside your country of residence, including in other jurisdictions (like the United States) that may have different data protection frameworks than your region. To learn more about the ReverseWinterStudios entity responsible for operating the ReverseWinterStudios services in your region, see “How to Contact Us” below.

We’ve implemented and maintain a framework consistent with applicable law and this policy for transfers of information outside the country of collection. For example, when we transfer personal data collected in the European Union to locations outside the European Economic Area, we rely on transfer mechanisms adopted by the European Commission to help establish adequate safeguards, like Standard Contractual Clauses. We may also need to transfer your information to provide the ReverseWinterStudios services to you in accordance with our existing agreements with you, such as the Terms of Service. 

 

Updates to Our Privacy Policy

This policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or use the ReverseWinterStudios services to make sure that you have reviewed the most recent version.

 

How to Contact Us

If you have general questions or concerns about the ReverseWinterStudios services (such as game-related issues, trouble accessing your ReverseWinterStudios account, bugs or other technical problems, payment matters, or content and entitlement issues), please contact our Support team.

To learn more about ReverseWinterStudio's privacy practices or this policy, contact us (via the contact form under privacy).