updated October 2, 2019
Collection of Information
INFORMATION YOU PROVIDE TO US
We collect information you provide directly to us. For example, we collect information when you create an account, manage your user profile, participate in any interactive features of the Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The types of information we collect include your name, email address, postal address, photograph, avatar, password, phone number, username, gender, birth day, forum posts and comments, messages between users and other contact or identifying information you choose to provide, but, as you’ll see when you interact with one or more of the Services, the exact types of information we collect will depend on the Service you choose to use. Prize winners of contests or sweepstakes may also have to provide their Social Insurance Numbers, which are used exclusively for prize fulfillment and related tax purposes.
INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES
When you access or use our Services, we automatically collect information about you, including:
We collect device-specific information when you access our Services from a mobile device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country, language, screen size and resolution, and battery life remaining.
We collect information about your use of the Services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and, with respect to our website, the page you visited before navigating to our Services.
Information Collected by Cookies and Other Tracking Technologies:
We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
Other Information Collected with Permission:
Our mobile applications that are distributed through various “app” stores also request permission to automatically collect other information from your mobile device, including your email address. We only collect this information with your authorization in accordance with your device operating system’s permission process.
INFORMATION WE COLLECT FROM OTHER SOURCES
We also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.
Use of Information
We use information about you for various purposes, including to:
- Provide, maintain and improve our Services;
- Setup your gWallet account and manage the credits that you earn and use across our Services;
- Provide and deliver the products and services you request and send you related information, including confirmations and invoices;
- Send you communications about products, services, offers, promotions, rewards, and events offered by Zenblank and other companies, and provide news and information we think will be of interest to you;
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions and requests and provide customer service;
- Monitor and analyze trends, usage and activities in connection with our Services;
- Personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities;
- Process and deliver contest entries and rewards; and
- Carry out any other purpose for which you consent at the time of collection.
Sharing of Information
- With vendors, consultants and other service providers who need access to such information to provide services to us or to you;
- With other users of the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.
- In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
- If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Zenblank or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
- With your consent or at your direction.
We also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Social Sharing Features
The Services offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Analytics, Advertising and Other Services Provided by Other Companies
The information we collect about you may be transferred to, and accessed from within, Canada, which may not offer the same level of data protection as your home jurisdiction. We will take steps to maintain an adequate level of protection for this information in the jurisdictions in which we process it.
Zenblank takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Website (Game Forums) Account Information
You may update, correct or delete your website (game forums) account information, which includes your username, password, email address and avatar, by logging into your website account and managing your profile. If you wish to delete or deactivate your website account, please email us atprivacy]@[zenblank.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your website account information for a certain period of time.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
With your consent, we send push notifications (or “alerts”) to your mobile device to provide game activity information, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.
You may opt out of receiving promotional messages from Zenblank by following the instructions in those messages or by contacting us at privacy]@[zenblank.com. If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.
Third Party Analytics and Advertising Services
We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links on this page to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer). You can also use your device settings to manage interest-based advertising that appears on mobile applications; to do so, select “limit ad tracking” on Apple iOS operating systems and “opt-out of interest based ads” on Android operating systems.
C/O Parkdale Centre for Innovation
1464 Queen St W,
Toronto, ON M6K 1M2
Legal Basis for Processing
We will only process personal data about you in accordance with the following legal bases:
- As necessary to perform our responsibilities under our contract with you. For example, to process your order and fulfill the products or services you purchase.
- When we have a legitimate interest in processing your personal data. For example, to communicate with you about changes to our Services or legal documents, to prevent fraud, to deliver advertising, provide, protect and improve our products and services.
- If we request your consent to a specific processing activity (such as to send you marketing emails), and you provide your consent in the manner indicated.
- In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.
Data Subject Requests
You have the right to access personal data we hold about you and to ask that this data be corrected. In certain cases, you may also have the right to request that we erase data we are processing or to restrict or object to certain of our processing activities. You may also have the right to request that we provide you with the personal data you have provided us in a portable form for transmission to another controller’s service. If you would like to exercise any of these rights, you may contact us as indicated above.
We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
EU-Canada and Swiss-Canada Privacy Shield Frameworks
We adhere to the EU-Canada. and Swiss-Canada Privacy Shield Framework Principles issued by the Canadian regulators (the “Principles”) in connection with personal data received from the EEA and Switzerland in reliance on the Principles. We also receive some data in reliance on other compliance mechanisms, including agreements based on the EU standard contractual clauses.
With respect to personal data received or transferred pursuant to the Principles, we are subject to the regulatory enforcement powers of the Canadian Trade Commissioner Service.
You may contact us about any question or complaint regarding adherence to the Principles as indicated in the “Contact Us” section above.