Privacy Policy

Summary of the Policy

What Personal Data is collected by BHVR?

• Profile and Identity data (e.g. internal identifier);
• Technical data (e.g. IP address);
• Contact data (e.g. email address), and all other Personal Data detailed at section 2.1 below.

What purposes are the Personal Data used for?

• To provide and operate the Services, incl. for the purposes of providing online leaderboards, matchmaking, and friends search;
• To deliver relevant content and personalized/targeted advertisements;
• To analyze and provide statistics of the use of the Services;
• To manage clearly unlawful conduct and misuse of the Services;
• To deliver personalized newsletter, and promotions;
• To process job applications;
• For other purposes detailed at section 3.1.

Is the Personal Data shared with third parties?

We may share your Personal Data with third parties, such as service providers, business partners and advertising partners. In certain cases, we will obtain express consent before sharing your Personal Data with third parties, if required by applicable laws. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We allow our third-party service providers to process your Personal Data for specified purposes and in accordance with our instructions and contractual obligations we enter with them. See section 5 for more information.

1. Scope and Services

1.1 Scope of Policy

This Policy applies when you use any of the Services (as defined below) offered by Behaviour Interactive Inc. or any of its affiliates (collectively referred to as “we”, “our” or “BHVR”), unless an affiliate has published its own privacy policy.

The terms of this Policy (together with our end-user license agreement (EULA) and terms of use (available here https://www.bhvr.com/behaviour-tou/) applies to your use of the Services. In certain circumstances, we may provide you with other privacy-related notice. This Policy supplements such other notices.

Definition of Services

This Policy aims to give you information on how we collect, use, process and disclose Personal Data that you provide us through your use of our websites and apps, our games and products, BHVR account, social media channels, customer and technical support and any other service BHVR provides, which may be hosted on video game digital distribution services, or downloaded or streamed onto your device (the “Services”).

2. Personal Data Collected

2.1 Type of Personal Data

We may collect, use, store, and disclose different kinds of personal data about you, as follows:

• Contact Data: delivery address, email address and telephone numbers.
• Content Data: includes information stored on your device, including friends’ list, and login information.
• Employment Data: includes any personal information you provide or which you attach to your application when you apply for one of our available positions.
• Identity Data: names, usernames or similar identifiers (e.g. identification codes of platform used on your device or used for in-game currencies), date of birth, gender.
• Marketing/Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Profile Data: includes your username and password, in-game purchase history, your interests, preferences, contest winner status, survey responses containing personal data, information you provide when contacting our support services, and any other information you choose to share with us through the Services.
• Technical Data: includes internet protocol (IP) address, your general (non-precise) location, login data, browser information & plug-ins, time zone, operating system and platform, and other technology on the devices you use to access our Services.
• Transaction Data: includes details about payments to and from you and details of purchases.
• Usage Data: includes information, statistics, and preference about how you use our Services.

(collectively referred to as “Personal Data”).

We may also collect, use, store, and disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data as this data will not (directly or indirectly) reveal your identity.

We do not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious, political or philosophical beliefs, sexual orientation, health information), unless you provide your express consent.

2.2 If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, as necessary to be able to provide you with the Services). In this case, we may have to cancel the Services and/or you may be unable to use certain Services or features.

3. How is your Personal Data Used

3.1 Purposes for which we will use your Personal Data

Below is a description of how we may use your Personal Data (and, if you are based in the UK or the European Union, which of the legal basis we rely on to do so).

3.2 Opting out and changing purpose

You can ask us to stop sending you marketing messages at any time. Opting out of receiving marketing communication will not impact Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

3.3 Unrelated purposes

We will only use your Personal Data for the purposes for which we collected it. If we need to use your Personal Data for another purpose, we will notify you and explain the legal basis for doing so. Where required or permitted by law, we may process your Personal Data without your knowledge or consent.

4. How is Your Personal Data Collected

4.1 Direct interactions

You may give us your Identity Data when you: apply for and/or use our Services (including subscriptions to publications, newsletters and downloading or registering for a Service or when you become beta tester, influencer or playtester); create an account; enter a contest, event or survey; make purchases; request marketing information; contact support; request technical assistance; give us feedback; or apply to one of available positions.

4.2 Data Available Publicly & Social Media

You may provide Personal Data when you publish it on public areas of our Services or transmit it to other users or to third parties (“User Contributions”), such as chats and forums (“Forums”). Data disclosed in Forums becomes public and may be read or used by others. We cannot control the actions of others; disclose Personal Data at your own risk.

4.3 Automated Technologies, Cookies, Analytics Metric Tools and Other Technologies

As you use our Services, we may automatically collect Personal Data by using cookies and similar technologies, including for behavioral tracking. You can set your browser to accept or refuse non-essential cookies. Our Services may also integrate third-party ad technologies (e.g., UnityAds) which may collect data such as age/gender, IP/country/city, ad placement and views, device identifiers and settings, usage of Services and third-party sites, and responses to advertisements.

4.4 Third parties

We may receive Personal Data about you from service providers, publicly available sources, business partners and clients, advertising partners, and other third parties when you have agreed they share certain Personal Data with us (e.g., authentication partners or platforms you connect). We may combine this with information we collect directly.

5. Disclosure of your Personal Data

We may share your Personal Data with third parties for the purposes described in section 3, including internal BHVR group companies; service providers; business partners; advertising partners (see list at https://www.bhvr.com/partnerprivacy/); parties in connection with corporate transactions; government authorities; and other third parties when you have agreed we share certain Personal Data with them. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

6. Location and Transfer of Your Personal Data

Personal Data may be hosted and processed on servers operated by trusted partners in the United States (such as AWS), as well as on servers located in Canada or Europe. Transfers outside the EEA, UK, Canada or US are protected by appropriate safeguards (e.g., approved contracts). By submitting your Personal Data or engaging with the Services, you consent to this transfer, storage, use, or processing.

7. Retention Period of Personal Data

We keep your Personal Data only for the period required for the purposes for which it is collected, and to satisfy legal or reporting requirements. In some cases, we anonymize data for research or statistical purposes and may use it indefinitely; otherwise, Personal Data will be deleted.

8. Safeguards of your Personal Data

We store information on secure servers and use strict procedures and security features. We may store data on your device using application data caches and other technology. We have procedures to deal with suspected Personal Data breaches and will notify you and regulators where required. We are not responsible for circumvention of privacy settings or security measures; BHVR declines liability if Personal Data is subject to unauthorized use or access.

9. Your Legal Rights

9.1 Rights

Depending on your jurisdiction, you may have rights to request access, correction, erasure, object to processing, restrict processing, data portability, and withdraw consent. You may also ask us not to process your Personal Data for marketing and to appeal adverse decisions. For ads personalization, consent may be withdrawn in the related game.

9.2 Fees and Verification

You will not have to pay to exercise your rights, though we may charge a reasonable fee or refuse requests that are unfounded, repetitive, or excessive. We may request information to confirm identity before fulfilling requests.

9.3 U.S. State Laws

Some U.S. state laws provide additional rights. BHVR will comply based on the place of residence of the individual making the requests.

10. Children

Services are not intended for Children under the applicable age of majority. We do not knowingly collect Personal Data from Children. If we learn we collected Personal Data from a Child without parental consent, we will delete it. In some games/jurisdictions, play may be allowed with parental consent.

11. Third-Party Links

Our Services may include links to third-party websites, plug-ins and applications. Clicking such links may allow third parties to collect or share data. We do not control those sites or their privacy statements. Certain products/services offered in partnership with third parties may require you to provide Personal Data to them; their privacy policies will apply.

12. Direct Marketing

We only send direct marketing communications by email or text with your express consent or following your request/purchase. We obtain your express consent before sharing Personal Data with any third party for marketing, including ads personalization. You may withdraw consent at any time or opt out via the steps in such communications or in-game settings.

13. Changes to the Policy

We update our Policy regularly. Changes will be posted on this page and, where appropriate, notified by email or when you log in. The new policy may be displayed on-screen and you may need to read and accept changes to continue using the Services. Continued use constitutes acceptance.

14. Contact

If you have questions or want to exercise your legal rights (including to appeal adverse decisions), contact us:

• http://support.bhvr.com
• By mail: Attn: Legal Department, Behaviour Interactive Inc., 500-6666 Saint-Urbain Street, Montreal, Quebec H2S 3H1, Canada.
• Privacy Officer: privacy@BHVR.com

15. California Privacy Rights

Notice at Collection

15.1 Personal Information We Collect

While providing the Services, BHVR collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include publicly available information, deidentified or aggregated information.

Categories collected include: identifiers; customer records information; protected classification characteristics (e.g., gender, date of birth); commercial information; biometric information (which may include Sensitive Personal Information used to uniquely identify you); internet or similar network activity; sensory data; professional/employment-related information; non-public education information; inferences. Sensitive personal information categories may include gender and biometric information.

See section 7 for retention.

15.2 How is Personal Information Collected

See section 4.

15.3 Purposes for Collection of Personal Information

See section 3.1. Additional purposes include those described at collection, and evaluating/conducting corporate transactions. We will not collect additional categories or use for materially different purposes without notice.

15.4 Disclosing of Personal Information

We disclose personal information to third parties for business purposes under contracts requiring confidentiality and limited use. In the preceding twelve (12) months, we may have disclosed personal information for business purposes to the categories indicated in section 5. Some uses may be considered “sales” or “sharing” for cross-context behavioral advertising under the CCPA; BHVR does not exchange personal information for money.

15.5 Your Rights & Choices

California consumers have the right to know, delete, correct, opt-out of sharing/sale for cross-context behavioral advertising, restrict sensitive personal information processing, and non-discrimination.

Exercising Your Rights: Submit requests via https://support.bhvr.com or by mail to Attn: Customer Support (Privacy Officer), Behaviour Interactive Inc., 500-6666 Saint-Urbain Street, Montreal, Quebec H2S 3H1, Canada.

Verification & Limits: We must verify your identity/authority. You may submit two Right to Know requests in a 12-month period. We confirm receipt within ten (10) business days (contact support@BHVR.com if not received) and aim to respond within forty-five (45) days, with possible 45-day extension.

We do not charge a fee unless the request is excessive, repetitive, or manifestly unfounded. Once you opt out, we will wait at least twelve (12) months before asking to re-confirm; you may opt back in at any time via preferences.

15.6 Other California Privacy Rights

California’s “Shine the Light” law (Civil Code § 1798.83) permits residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes (if any). To make such a request, email support@BHVR.com.