Business Manager

Privacy Policy

At Project Whitecard, we collect personal data to support our products and services, while respecting the The Personal Information Protection and Electronic Documents Act (PIPEDA), and regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, “General Data Protection Regulation”, or “GDPR”). According to GDPR, “personal data” means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. By using Project Whitecard’s services, you authorize Project Whitecard Inc. and its affiliated companies, such as but not limited to Project Whitecard Inc. and Project Whitecard Digital Inc., to process your personal data according to this Privacy Policy. If you do not accept the terms of this Privacy Policy, please refrain from using our online games, applications or our games’ online functionalities, our websites, our mobile apps and any other online Project Whitecard products and services (hereinafter “Services”). In accordance with this Privacy Policy, the Data controller is Project Whitecard, with its headquarters at:

Suite 206

698 Corydon Avenue

Winnipeg, Manitoba, Canada

R3M 0X9

INFORMATION WE COLLECT

When you visit the Services, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Services, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Services, and information about how you interact with the Services. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Services, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Services.

Additionally when you make a purchase or attempt to make a purchase through the Services, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information.”

When you create an account on any of out Services, we collect certain information from you, including your name, billing address, payment information (including credit card numbers), email address, and phone number.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

INFORMATION YOU GENERATE USING OUR SERVICES

When you use our Services, we’ll collect information about the ways in which you use and interact with our Services, such as when and for how long you play our games, game features and other players you interact with, purchases you make, progress or levels you achieve, and other gameplay activities.

If you choose to use communication features in Project Whitecard Services that allow you to communicate or share information with other players or users, then we’ll collect information on what is communicated or shared. This includes:

• your participation in player forums and message boards;
• your public posts or comments on other players’ profiles or gameboards;
• your non-public messages or invitations to other players, made either directly on our websites or through in-game mechanisms;
• your chats with other players (whether by instant message, live chat, or video); and/or
• your posted photos, drawings, or other user-generated content.

We may access in real-time, record, and/or store archives of these communications, comments, photos, drawings, and other user-generated content on Project Whitecard’s servers to make use of them to protect the safety and well-being of our players; to protect Project Whitecard’s rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this.

HOW WE USE YOUR PERSONAL INFORMATION

We use the Order Information that we collect generally to fulfill any orders placed through the Services (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

• Communicate with you;
• Screen our orders for potential risk or fraud; and
• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Services (for example, by generating analytics about how our customers browse and interact with the Services, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. We use Google Analytics to help us understand how our customers use the Services – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

COOKIES

As further described in our Cookie Notice, we use cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize you and/or your device(s) on, off, and across different Services and devices. We also allow others to use cookies and similar technologies as described in our Cookie Notice. You can control or opt out of the use of cookies and similar technologies that track your behavior on the sites of others for third-party advertising, as described in our Cookie Notice.

We, our service providers, and our business partners use these cookies and other similar technologies to collect and analyze certain kinds of technical information, including:

• IP address;
• the type of computer or mobile device you are using;
• platform type (like Apple iOS or Android);
• your operating system version;
• your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
• application performance and de-bugging information;
• your browser type and language;
• referring and exit pages, and URLs;
• the number of clicks on an app feature or web page;
• the amount of time spent on an app feature or web page;
• domain names;
• landing pages;
• pages viewed and the order of those pages; and/or
• game state and the date and time of activity on our Services.

In some cases, we will connect the above information with your social network ID or Project Whitecard user ID.

If you play Project Whitecard games on a mobile device, in addition to your device identifiers (described above), we may also collect:

• the name you have associated with your device;
• your country;
• your telephone number (if you provide it);
• your specific geolocation (with your permission);
• information about the Project Whitecard games and other third-party apps you have on your device.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-d….

You can opt out of targeted advertising by:

FACEBOOK – https://www.facebook.com/settings/?tab=ads

GOOGLE – https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Services’ data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

Having regard to the fact that Project Whitecard processes information concerning you, you may assert certain rights about which we want to inform you in this section. You may assert all the rights in writing at the above-given postal address or by e-mail at privacy@projectwhitecard.com.

You have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Services), or otherwise to pursue our legitimate business interests listed above.

You may request, at any time, that all of your user data that has been collected or stored can be deleted by making a request to the email address or mail address under the Contact Us section below.

We only need to process your accurate personal data. You have the right to the rectification of your personal data which are processed incorrectly.

Under any circumstances you have the right to demand that we erase your personal data. However, this is not always possible. If you think that your personal data are no longer needed for the purpose for which they have been processed; if you believe that your personal data are processed by Project Whitecard illegally; or if Project Whitecard process personal data of a child without any parental consent given for such processing, you may demand that we erase your personal data. However, it is not always possible to erase the personal data provided by you for instance because of the fact that if we erased them, you would no longer have access to the Services.

Another right you may assert is the right to data portability based on which we will hand over the personal data provided by you in a commonly used, structured and machine-readable format or if you require, we will transfer them to another controller of your own choice, where such transfer is technically feasible.

If you believe that your personal data processed by Project Whitecard are incorrect, you have the right to demand that we restrict the processing of your personal data for a period necessary to verify the accuracy of your personal data and to rectify them if needed. You also have this right if the processing of your personal data is illegal but you do not wish for your personal data to be erased; if Project Whitecard no longer needs your personal data for the above-specified processing purposes but you demand that your personal data are preserved for the purposes of the determination, exercise or defence of your legal claims; or if you have objected to the processing of your personal data on the basis of Project Whitecard’s legitimate interest.

With regard to the fact that some of your personal data we process on the basis of our legitimate interest, you have the right to object to this processing. Based on the objection we will consider whether it really is in our interest to process your personal data for the given purpose. If we conclude that we do not have any significant legitimate reasons that prevail over your interests, rights or freedoms, we will terminate the processing of and destroy such personal data. However, it needs to be stressed that such objection should be well-founded. Therefore, we recommend you to firstly obtain all the necessary information at the above-mentioned email address.

DATA RETENTION

When you place an order through the Services, we will maintain your Order Information for our records unless and until you ask us to delete this information.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@projectwhitecard.com or by mail using the details provided below:

Suite 206

698 Corydon Avenue

Winnipeg, MB, Canada

R3M 0X9