(Last updated March 25, 2021.)
➢ Disclosure to California Residents
➢ Information We Collect
➢ How We Collect Your Information
➢ How We Use Information We Collect
➢ Sharing your Information
➢ Our Policies Concerning Children
➢ How to Control Your Information
➢ Opt Out Options o Opting Out of Promotional Communications
➢ Security of Your Information
➢ Sharing your Information For Direct Marketing Purposes
➢ Links to Other Sites
➢ Responding to Do Not Track Signals
➢ International Transfer
➢ Contact Us
Disclosure to California Residents: In our efforts to comply with applicable regulation, we ask and advise that California residents review the “CCPA Disclosure” at the end of this document. Although we do not sell user data, we will provide notice if at any time those circumstances change.
2. Information We Collect
When you interact with our Services, we may collect and store information from you directly as described below:
2.1 Registration Information
You will need to create a user account through our system before you can play or access Drifters Loot the Galaxy or any other Blind Squirrel product or service (your “Account”). Your Account is used to enjoy the multiplayer and player versus player modes available in our Game, and may be used to publicly identify you as part of the social features of the Services, which may include user-to-user interaction, chat or messaging functionality, competitive gameplay and matchmaking, and other similar features.
We may also offer you the option to complete a user profile or provide information in a player dashboard that is accessible and editable only by you, and that may be viewable to other Blind Squirrel users. Your user profile may include a profile photo, a Blind Squirrel username, biographic details that you provide, details about the Games you play, and a Blind Squirrel user ID number that is created by Blind Squirrel and used to identify your profile.
Your Blind Squirrel username will be public and will be shown to other users, but will only permit access to information that is considered public or that you have designated as public in your user profile settings. The information you include in your profile is optional, and we advise you to limit the information you share through this feature if you have concerns about your privacy.
Your Account will be used to identify your transactions and payment history, player sessions and player ratings or rankings, individual user settings and customized characters, in-game currency, and other in game features that we may make available from time to time. We discourage you from sharing your Account information or password with anyone, and we will never request such information in order to provide Services to you.
2.2 Payment Information
When you order any good or service through the Game, including any virtual currency or virtual good, the purchase will be made directly through our payment, currency, and account solutions providers which may collect relevant information in connection with such purchase. Please review the terms and conditions and privacy policies of the third party marketplace through which you accessed the Game for more information. In addition, each time you make a purchase, we will collect information relating to that in-app purchase, including but not limited to player ID, device ID, session ID, your current available currency, the USD value of the currency, an other information related to the transaction. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Game without having to re-enter it each time. Please note that purchases from third parties may also be subject to additional policies.
2.3 Information Collected by Customer Support
When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game play or activity on the Games, and your user name or ID number. We will also store the correspondence and any information contained within.
2.4 Technical and Usage Information
When you access our Services, we may collect (i) certain technical information about your gaming device, mobile device, or computer system, including IP Address, device ID (IDFA, Google Advertising ID or other identifiers), anonymized Player and Account ID, session ID, marketplace purchases, transaction history and currency information, game play and player information, and the current version of your operating system; and (ii) usage statistics about your interactions with the Games. In certain Games we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Games. This information is typically collected through the use of third-party software development kits.
2.5 Location Information
We or our third party providers may collect information for payment processing, region-locking, and other such purposes, which may include information about the territory or region from which you access the Game by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you.
3. How We Collect Your Information
We may collect information about you in any one or more of the following ways:
3.1 Communications Features
You may be able to take part in certain activities through our Services that give you the opportunity to communicate or share information not just with Blind Squirrel, but also with other users of our Services. These include:
We may use, record and store archives of these communications on Blind Squirrel’s servers to protect the safety and well being of our users and Blind Squirrel’s rights and property in connection with the Services.
3.2 Cookies and Automated Information Collection
When you access our Services, we collect certain technical information in order to (i) analyze the usage of our Services; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf may use Log Files and tracking technologies to collect and analyze certain types of technical information, including Cookies, Flash Cookies, and Web Beacons.
“Log Files” means certain information about how a person uses our Services, including both registered and unregistered users (either, a “User”). Log Files may include information such as a User’s Internet Protocol (IP) addresses, device name, user language, time played, platform type, number of page clicks, player levels, player history, the amount of time spent on particular levels, campaign progression, pvp sessions and rankings, Game state and the date and time of activity on our Site or the Games, webpage interactions and pages viewed, and other similar information. In some cases, we will associate this information with your Account ID number for our internal use.
”Web Beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to know if a certain page was visited or whether an e-mail was opened, to advertise more efficiently by excluding our current users from certain promotional messages, to identifying the source of a new installation, to delivering ads to you on other websites. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
“Flash Cookies” are local shared objects, which help us to prevent fraud, remember your in-Game preferences and speed up load times.
3.3 Other Sources
We may collect or receive information from other sources including (i) other Blind Squirrel users who choose to upload their email contacts, and (ii) third party information providers. We do not condition participation in our Services on you providing more personal information than is reasonably necessary for that activity.
4. How We Use the Information We Collect
In general, we collect, store and use your information to provide you with a customized experience. For example, we may use information collected from you in any one or more of the following ways:
We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:
We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes:
With your consent, we may use your personal information:
If you have provided your e-mail address to us, we may use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-Game activity, including comments from friends and notifications about in-Game status. With your consent, we may also send promotional email messages (“Promotional Communications”) directly or in partnership with parties other than Blind Squirrel. Each Promotional Communication will generally offer recipients choices about withdrawing consent so you no longer receive additional messages.
5. Sharing of Your Information
We may share your information (in some cases personal information) with third parties in the following circumstances:
5.1 Third Party Service Providers and Third Party Products and Services
We will provide your information to third party companies to perform certain services, including but not limited to payment processing, data analysis, e-mail delivery, hosting services, customer service and to assist us in our marketing efforts. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on Blind Squirrel’s behalf.
We do not routinely share personal information with third parties except as may be necessary to provide Services to you. We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; (iii) certain technical information (including IP Addresses and device or player IDs) to develop and deliver Services to you, including payment solutions; (iv) personally identifiable information, including payment information, address, phone number, identify verification, credit card number, and other personal information as may be necessary to provide such Services.
We may also allow third parties to collect these types of information within the Games and they may share it with us. Advertisers may collect this information through the use of tracking technologies like browser cookies and web beacons.
We may disclose aggregated and anonymous information to describe the Services to prospective partners, advertisers, and other third parties, and for other lawful purposes. We may use aggregate, non-personally identifiable information for our own internal promotion or marketing purposes and we may share such aggregate non-personally identifiable information with others for marketing purposes.
In certain instances, you may need to opt in or opt out of advertising directly through our partners.
You may view a complete list of our third party service providers with links to their respective privacy policies as follows:
Third Party Service Provider Policies
5.2 Friends and Other Players
In many Games, friends and other players will be able to see your Game profile, which may include your name or a “game name” and your profile photo, which in certain cases can reveal your Blind Squirrel ID. Access to a Blind Squirrel ID may allow others to view the public information associated with your related Blind Squirrel account. This information may also be shared with friends you invite to play when you participate in our Referral Program.
5.3 Safety, Security and Compliance with Law
Your information may be disclosed: (i) when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations; (iii) where we believe that the Games are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect the rights or property of Blind Squirrel, including to enforce our Terms of Service.
5.4 Sale or Merger
In the event that Blind Squirrel undergoes a business transition, such as a merger, acquisition by another company, change of control, or sale of all or a portion of its assets, we may transfer all of your information, including personal information, to the successor organization in such transition.
6. Our Policies Concerning Children
Our Services are intended for a general audience and are not intended for children under the age of 13. We do not knowingly collect personal information from users deemed to be children under their respective national laws. If we learn that we have collected personally identifiable information ("PII") of any child we will take steps to delete such information from our files as soon as possible. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission. We recognize a special obligation to protect personal information obtained from young children. Should you wish to have your child’s personal information deleted from our records, please contact us at firstname.lastname@example.org. We will be happy to remove your child’s information as appropriate.
7. How to Control Your Information
Under the EU General Data Protection Regulation, individuals residing in the EU and other territories that have adopted GDPR compliance or comparable regulation have a right to:
You may send an e-mail to email@example.com with your request to exercise any of the rights identified above. Place the reason for your request (e.g. “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and e-mail address in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content through the Services, we may not be able to delete it. Accounts created with Blind Squirrel are considered active until we receive a user request to delete them or deactivate them. Any request to deactivate or delete an account will not automatically result in information deletion unless so requested by the End User, and only to the extent we are not required to retain such data to satisfy our legal obligations.
Please note that requests to restrict processing or delete your data may require the termination of your user account if we require the information subject to the deletion request to maintain your user account or otherwise provide gameplay services to you.
We are unable to delete data controlled solely by third parties; for example, if you purchase our Game through Steam, we won’t be able to delete your Game from your Steam library, nor the data collected by Valve in connected with your purchase or your Valve account. Similarly, if you access any our of Services through third party social media or service platforms, such as Discord, or if you are routed to a third party service provider’s web page through our Services, you will need to make any deletion requests to those respective third parties separately.
8. Opt Out Options
8.1 Opting out of Promotional Communications
You can choose to opt out of receiving promotional e-mails and product updates from Blind Squirrel by clicking on the “unsubscribe” link in any such e-mail, or by opting out of such communications in your Game or Account preferences. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, usually within 10 business days.
8.2 Opt Out Limitations
9. Security of Your Information
Accessing your account or any personally identifiable information stored through your account is password protected and requires two-step authentication using OTP when first accessing our Services through any new computer or device, or when cookies are disabled. It is important that you protect and maintain the security of your Account and that you immediately notify us of any unauthorized use of your Account. We encrypt the transmission of all information using secure socket layer technology (“SSL”).
We further encrypt all data we store or share, and each transfer of data is tokenized and signed with a secret. However, while we take reasonable precautions against possible security breaches of our Services, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted through our Services; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access.
11. Sharing Your Information for Direct Marketing Purposes
We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in” to receive information from a third party that is participating in a sweepstakes or other promotion through our Services. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt in to such use when you provide personal information through our Services.
12. Links to Other Sites
13. California Residents: Responding to Do Not Track Signals
In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the web sites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning out collection and use of personally identifiable information will continue to operate as described in this policy.
14. International Transfer
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your personal information to us, we may transfer your personal information to the United States and process it there.
15. Contact Us
Blind Squirrel Entertainment, Inc.
1251 E Dyer Road, Suite 200
Santa Ana, CA 92705
Blind Squirrel Entertainment complies with the California Consumer Privacy Act of 2018 (CCPA), effective January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.
Categories of Data we Collect and their Uses
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Identifiers, Commercial information, Internet or other similar network activity, and Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
We generally do not sell our player data. However, if we do sell your personal information for a business purpose, we will also disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Calling us at (714) 460-0860
Emailing us at firstname.lastname@example.org
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: