Velan Studios Privacy Policy

Your privacy is important to Velan and we take our responsibility for caring for it seriously.  This policy describes how Velan Studios, Inc. (“Velan”) processes personal information we collect when you use our products and services (collectively, “Services”).  

Currently, Electronic Arts, Inc. (“EA”) provides some customer account management and other services (“EA Services”) in connection with our Knockout City game.  Some of your information may continue to be processed by EA through November 30, 2022.  During this period, this Velan Privacy Policy will apply to all information processed by Velan.  The EA Privacy and Cookie Policy www.ea.com/legal/privacy-and-cookie-policy will apply to all information processed by EA. 

1. Information We Collect

The information we collect depends on the Services you use and how you use them.

A. Information You Give Us

We collect information you provide us, such as:

  • Your Velan Account Information, including your email address, user name, real name, country, date of birth, telephone, number and password;
  • Security questions and answers;
  • Information you provide in response to surveys about our Services;
  • Information you provide when seeking help form us, such as your name, telephone number, and records (including call recordings) of the issues you experience; and
  • Billing information, such as your name, payment card number, payment account details, and shipping address.

B. Information You Provide While Playing Online

When you play online or participate in social features such as chat, audio, visual or electronic information you share may be accessed by us or used by other players and may become publicly available.  

While you are playing in multiplayer mode online, your in-game profile information, game play, and statistics are visible.  In some multiplayer modes, we may record your gameplay and replay it to other players.  In competitive game modes, we may record your gameplay, and your controller button inputs, and replay these together with your in-game profile information and game statistics to other players in-game and at live Velan or partner events.

C. Other Information We Collect When You Use Our Services

We may collect certain information automatically when you use our Services, such as:

  • IP address;
  • Information about your device, hardware and software, mobile device identifiers, platform type, settings, components, and presence of plugins;
  • Approximate geolocation data (inferred from IP address or device settings);
  • Browser information, including your browser type and language preference;
  • Referring and exit pages, including pages viewed and other interactions with web content;
  • Device event information, including crash reports, request and referral URLs, and system activity details (for example, whether you encountered an error playing our games or lost internet access); and
  • Other information you may provide (such as your likeness or image).

We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5), and application data caches.

D. Information Provided to Us by Third Parties

We may receive information about you contained in third-party user accounts when you access our Services through a third-party game store (such as the Epic Game Store or EA Origin) or platform (such as Xbox, PlayStation, and Nintendo Switch).  Your use of Velan Services through these third-parties indicates your agreement for transfer of information to us.  You may wish to refer to the privacy policies of these third-parties for more information concerning information they collect about you and may transfer to Velan.  We never receive credit card number or other financial information from these third-parties.

Social Gaming Platforms.  We may also receive information about you from social gaming platforms (such as Discord and Twitch) and link to your Velan Account.  

Mobile Platforms.  If you purchase or play our games on your mobile device or tablet, we receive information about you from the app stores and other mobile platform providers.  This information may include your user name or device ID and the fact that you made a purchase, as applicable, but does not include any financial information.  Some of our mobile platform partners may send information to us that you authorize them to provide.  Our mobile games also may request additional personal information from you, such as push notification tokens, your device’s specific location or contact list, and we will collect this information only if you give us your consent.

Other Third Parties.  We may receive information from other third parties, like Facebook or Apple Game Center, when you use these services with our games.  We may also receive information about you when other players choose to share their contact lists with us or from publicly-available websites.

E. Categories of Personal Information Processed

Depending on your use of our Services, the following categories of personal information may have been collected, shared, sold, or disclosed in the preceding 12 months:

  • Identifiers, such as a real name, user name, account name, email, online identifiers, device identifiers, IP address, or mobile device identifiers;
  • Purchase information, such as payment card number, payment account details, billing address, and other payment information;
  • Characteristics of protected classifications under state or federal law, such as age or gender;
  • Commercial information, such as products or services used and purchase history;
  • Internet activity information, such as browsing history, search history, and information regarding interactions with our games, websites, applications, or advertisements;
  • Approximate geolocation data, such as location inferred from IP address or other device settings;
  • Audio or electronic information, such as when you play our games, play certain multiplayer modes, use chat features, or participate in competitive game modes or live events;
  • Inferences, such as consumer preferences drawn from information you provide and other sources.

We may collect additional information, such as:

  • If you are the recipient of a contest or sweepstakes prize that requires tax reporting, we may collect information required by tax authorities, such as social security numbers;
  • If you participate in our competitive gaming events, we may collect identifiers associated with your government-issued documents (such as a passport or drivers’ license number) and financial information (such as bank account information) and health-related information; and
  • If you participate in our user experience research, we may collect financial information (such as bank accounts), health-related information and video footage of your gameplay, as well as your recorded image throughout the session.

F. Legal Basis for Processing

Our legal basis for processing your personal information depends on the type of information we collect about you, the context in which we collect it, and your country of residence (as indicated by you or inferred by us based on your IP address and other information.  

We process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, or where we have a legal obligation to process your information.  For example, we typically rely on:

  • Consent when placing cookies on your device on the web to send you email marketing, or deliver third party targeted advertising to you using our Services; 
  • Our legitimate interests to process your information when providing you with customer service support, to serve targeted marketing of our Services, for fraud prevention and security purposes; and
  • On contractual necessity to process information when you create a Velan Account to enable us to provide you with our Services.

2. How We Collect Information

We and authorized third parties use technologies described below to collect information to deliver the Services.

A. Cookies and Similar Technologies

Cookies are small text files stored on your Internet browser. We and our third-party partners use cookies and similar tracking technologies to help us understand things like what web pages, features, or ads you view and what games you play. This information helps us keep track of your shopping cart, measure the effectiveness of our advertising, make sure you don't see the same ad repeatedly, and otherwise enhance your experience. You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you'd like help in managing your cookie preferences. We also offer cookie consent tools in certain regions to help you manage your cookies.

We may use tracking pixels or clear GIFs to collect information about your use of our Services and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud, and enforce our User Agreement. We do not respond to Do Not Track (DNT) signals. You may opt out of certain types of tracking on the web, including certain analytics and tailored advertising by changing the cookie settings in your browser or via our consent tools, as applicable.

We also use Analytics, Advertising, Anti-Cheat, and Anti-Fraud technologies in our Services. These technologies may utilize the same cookies or similar mechanisms as further described below.

B. Analytics Technologies

We use internal and third-party analytics technologies to collect information about how you use our Services, your computer or device and the health of our Services.

For instance, we may collect and store data from your computer or device when you use our Services. This information includes technical and related information about your computer or device and operating and/or network systems (such as IP Address and device ID), information about your engagement with certain features, gameplay and usage statistics, system interactions and peripheral hardware for purposes described in Section 3 below. If you play a game offline without connecting to the Internet, this data will be stored on your device and transmitted to us when your device connects to the Internet. If you participate in online Services, we may also collect, use, store, transmit and publicly display your personal and/or statistical data regarding your game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.

Third-party analytics technologies integrated into our Services may combine the information they collect in connection with your use of Velan’s Services with information they have independently collected over time and/or across different platforms. Many of these companies collect and use information pursuant to their own privacy policies.  

C. Ad Serving Technologies

Some of our Services employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies to deliver offers and advertising to you within Velan Services as well as on third-party platforms and sites, and to measure the performance of our advertising campaigns. Some of these technologies can sync or connect behavior across different websites, mobile apps and devices to tailor offers and advertising to your interests. For instance, you may be presented with an offer for a game we think you might enjoy. Or, if you express interest in a game, you may receive an advertisement later for that game or similar Services on Velan or third-party sites. Other in-game advertising technologies enable offers to be temporarily uploaded to your game, web browser, or mobile device and later replaced while you are online.

These technologies collect and use information so we can serve appropriate offers and advertising to you, to measure effectiveness and distribution of these offers and advertising, and to understand how users interact with our Services. In addition to identifiers and certain information listed in section 1(C) above, this information may include:

  • Advertisements served and the location of the ad;
  • Length of time an advertisement was visible;
  • Domain type, IP address, size of the advertisement;
  • Your interaction, if any, with the ad; and
  • Advertisement response.

D. Third-Party Advertising Companies

Third-party advertising companies may combine the information collected in the context of delivering an offer to you via our Services with other information they have independently collected over time and/or across different websites. Many of these companies collect and use information pursuant to their own privacy policies.

To learn more about some of these ad networks' practices, or to opt out of third-party targeted advertising, you can visit www.networkadvertising.org, www.aboutads.info/choices, youradchoices.ca, or www.youronlinechoices.eu. Note that opting out does not mean you won't see ads; rather, it means that the advertising you see may not be as relevant to you.

E. Anti-Cheat and Fraud Prevention Technologies

We strive to provide a safe and fair gaming environment for all players. When you use our Services, we or third parties with whom we work may use cookies and similar technologies and collect data about your machine or device, to create a machine "fingerprint" or "hash" of your machine components, for fraud prevention, security, and authentication purposes. We may also monitor publicly-available information, third-party sites, or use anti-cheat technology within our Services, including automated anti-fraud and abuse algorithms. If you believe your access to our Services was blocked by this technology in error, please contact us at the addresses set forth in Section 11 below.

3. How We Use Your Information 

We use your personal information in the following ways:

To operate our business and to enhance and personalize your game experience, including to: 

  • Operate, improve, and develop our Services;
  • Undertake research and analysis to develop and demonstrate our technology, and to better understand our players;
  • Populate online leaderboards and enable online matchmaking;
  • Provide replays to you and other players via spectator modes;
  • Help you find your friends or tell your friends about our Services;
  • Facilitate sharing on social networks;
  • Manage and serve targeted and contextual advertising;
  • Measure the effectiveness and distribution of advertising, including understanding who engages with our Services and how they interact with our Services;
  • Measure the health of our Services;
  • Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
  • Set up and maintain accounts for which you register;
  • Provide game experiences that you may like;
  • Set up and facilitate loyalty programs;
  • Facilitate your gameplay on multiple devices and/or platforms, as applicable;
  • Identify, fix, and troubleshoot bugs or functionality errors;
  • Provide software updates;
  • Authenticate and activate your games and save game-play data, including progress;
  • Facilitate competitions and contests;
  • Perform audits, transactions, and other compliance activities;
  • Adhere to your preferences and to deliver content;
  • Help keep our Services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies; and
  • Other purposes you consent to, are notified of, or are otherwise disclosed to you when you provide personal information.

To provide you support, including to:

  • Help identify and troubleshoot problems with your account or Services;
  • Facilitate surveys or questionnaires;
  • Communicate with you and respond to your specific requests or questions; and
  • Manage and send you confirmations and important information about your account, Services, purchases, subscriptions, and warranties.

To personalize our communications with you, including to:

  • Present offers and/or information relating to games and/or Services you might like;
  • Make game or other Service recommendations to you; and
  • Provide you with Service updates.

We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

4. Information We Share with Third Parties

Except as described below, we do not share, sell, or otherwise disclose personal information to third parties:

Service providers. We employ third parties located in and outside of your country of residence to collect or process personal information on our behalf for the purposes described in Section 3. These purposes include conducting market surveys, providing IT and related services, facilitating credit card processing, facilitating live events, sending emails, or delivering and optimizing our Services. We require that any third party use the data only on our behalf and for purposes consistent with this policy.

Business partners. We may provide personal information to business partners with whom we jointly offer Services. These partners include the companies that provide the platform on which you play our games, such as Epic, Sony (PlayStation®4 system or PlayStation®5 console), Microsoft (Xbox), or others.

Advertising partners. Through our Services, we may allow third-party advertising partners to utilize technologies and other tracking tools to collect information regarding your use of Velan’s Services and your device (such as your IP address, mobile identifiers, pages visited, location, browser information, time of day). We also may combine and share such information and other information (such as your de-identified account information, demographic information, hardware specifications, and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you.

If you prefer not to share your personal information with third-party advertising partners, you may contact us at please contact us at the addresses set forth in Section 11 below.

Disclosures to protect us or others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: 

  • comply with law enforcement or national security requests and legal process, such as a court order or subpoena; 
  • protect your, our or others' rights, property, or safety; 
  • enforce our policies or contracts; 
  • collect amounts owed to us;
  • or assist with an investigation or prosecution of suspected or actual illegal activity. In particular, if we receive a report that you have violated our policies, we may disclose that report and other relevant information to the platform on which you play our games.

Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party.

Third-party plugins. When third-party technologies or social tools are integrated into our Services, those third parties may collect information about your use of our Services. An example is the Facebook "Like" button.

Cross-Platform Sharing. Some of our games allow you to connect and play with friends and members of a game's community, regardless of what platform they play on. We call this ability to match players across platforms "Cross-Play." When Cross-Play is enabled and you play with someone on another platform, that other platform may receive your platform's ID (such as Xbox Gamertag, or Online ID of your account for PlayStation™Network) along with other information necessary to enable Cross-Play. In addition, we may provide information regarding your use of Cross-Play features to the platform on which you play our games. Some of our games may also allow you to continue progress on a game between platforms, as well as enable the ability for your purchases on one platform to be available on another platform. We will share your information with platforms to the extent necessary to enable these features. Other platforms receiving your information may include Sony (PlayStation®4 system or PlayStation®5 console), Microsoft (Xbox), Nintendo (Nintendo Switch), Google (Stadia), Valve (Steam), and additional platforms as they become available for these features. Your information received by these platforms may be subject to their respective privacy notices.

With Your Consent. We may share information with other third parties with your consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions, or if you tell us that you want to link your Velan Account with another company’s services. Use of the information you agree to share will be subject to those third parties' respective privacy notices.

5. Where We Hold Your Information 

Personal information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which Velan or its subcontractors or partners operate.  By consenting to the transfer of your personal data outside of your country of residence, you acknowledge that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.  

6. How We Protect Your Information

Data security is a Velan priority.  We take a range of technical and organizational measures to protect your data.  However, no security measures are 100% perfect, especially with respect to systems connected to the internet.  Thus, we cannot guarantee the security of your information and recommend you use care in deciding what information to share with us.

7. Children

Although our games are not solely intended for use by children, we take care to follow the different minimum age guidelines set by the laws of the individual countries where our games are made available.  

When players identify themselves as being children, we will obtain consent form parents for the use of their children’s personal information where required by applicable law.  

If you are a parent or guardian and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, please contact us via the options in Section 11 below. 

If we become aware that a child has provided us with personal information without parental consent, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and will terminate the child's account and/or revert them to the underage experience, as applicable.

If we make material changes to how we collect, use, share or otherwise process your child's personal information, we will notify parents as required by applicable law.

We encourage you to talk with your children about communicating with strangers and the risks of disclosing personal information online. You and your child also should review the privacy settings applicable to their use of our Services.

8. Your Choices and Controls

If you no longer want to receive marketing emails from Velan Studios, you may click the unsubscribe link included in the footer of any marketing email we send.

You can exercise any of your privacy rights by contacting us at the addresses in Section 11, below.

To protect your account security and personal information, you may be asked to verify your account ownership. Once you have verified your account ownership, you may also be required to provide your confirmation authorizing an agent to exercise these rights on your behalf. If you have additional questions about exercising your privacy rights, you may contact us at the addresses in Section 11, below. 

Your right to deletion. You may deactivate your Velan account by contacting us  contacting us at the addresses in Section 11, below. If you do so, you will no longer have access to the Services associated with your account. Note that Velan may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you with, create, and improve our Services, and to comply with the law. 

Your right to access. You can access the personal information we hold about you by contacting us at the addresses in Section 11, below. 

Your right to correction. You can request correction of your personal information where it is inaccurate. In some cases, we may provide self-service tools that enable you to update some of your personal information.

Your right to opt out or object to certain processing. You may have the right to opt out of disclosing, sharing, or selling your personal information to third parties, if applicable, or object to some processing of your data, where such requests are permitted by law.  Please contact us at the addresses set forth in Section 11 to exercise your rights.

You also may adjust your browser settings to block certain online tracking technologies, such as cookies, as described in Section 2(A).

You have a right not to receive discriminatory treatment for the exercise of these privacy rights.

9. Third-Party Services

Our websites and Services may contain advertising or links to third-party services (such as the Facebook "Like" button or links to third-party websites). If you click on those links, including an advertisement, you will leave the Velan Service and go to the third-party service or site that you selected. If you visit a third-party website or use a third-party service, you should consult that service's or site's privacy policy as your use of third-party sites or services is governed by their privacy policies.

10. Changes to Our Policy

We may occasionally update this privacy policy. When we do, we will revise the "last updated" date at the bottom of the policy. If there are material changes to this policy, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.

11. Contact Us.

If you have questions about this policy please contact us at:

privacy@velanstudios.com 

Velan Studios, 5 Third Street, Suite 300, Troy NY 12180.  ATTN: Chief Privacy Officer.

12. Right to Contact Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer. Contact details for Data Protection Authorities in the EEA are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

To contact the Swiss authorities please visit this website at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. To contact the UK authority please visit this website at https://ico.org.uk/global/contact-us/.

Where appropriate, your local data protection authority may also forward the matter to the Department of Commerce or FTC for consideration.

Last Updated: June 1, 2022.

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