Privacy Policy

This Privacy Policy sets out the privacy policies and practices for Hothead Games Inc. (“Hothead”) with respect to the collection, use, and disclosure of personal and non-personal information.

COLLECTION OF PERSONAL INFORMATION

Hothead generally collects your personal information through:

  1. your access to and use of Hothead software applications for mobile devices or other devices (“Hothead Applications”),
  2. your access to and use of Hothead’s website (www.hotheadgames.com) (the “Website”),
  3. any dealings that you have with Hothead (for example, by contacting Hothead for any purpose), and
  4. third-party organizations, including those that distribute Hothead Applications or who process payments for in-app purchases within the Hothead Applications (as of the date above: Apple, Google and Amazon), our advertising partners (including advertising networks, many of which are specifically listed below), and credential management partners, such as Facebook. The type of information that we collect in these circumstances will vary depending on the third party and the type of Hothead Application, but will generally include contact and demographic information such as your name and email address, age, user ID, account or registration information and location information. When you use a social media credential to log in, additional information we receive may include your public profile (including photo) and friends list.

In certain circumstances, third parties may collect your personal information in connection with your access to and use of the Hothead Applications or the Website. This includes our advertising partners, such as:

  • Unity Technologies, who may collect the personal information set out in its privacy policy as it exists from time to time, which policy (as of the date of this Privacy Policy) is located at https://unity3d.com/legal/privacy-policy);
  • Facebook Inc. and Facebook Ireland Limited, who may use cookies, web beacons, and other technologies to collect or receive the personal information of users;
  • ironSource Mobile Ltd., who may process the personal information set out in its privacy policy as it exists from time to time, which policy (as at the date of this Privacy Policy) is located at https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/;
  • Soomla Inc., who may use tracking technology to process personal information in accordance with its privacy policy as it exists from time to time, which policy (as at the date of this Privacy Policy) is located at https://soomla.com/privacy-policy/; and
  • Vungle and certain of its advertising-related partners, each of whom may use tracking technology to collect, use and share ad-related data (for example, unique device identifiers, information about ads viewed or clicked, and streaming data).

We also have several other advertising partners, which may change from time to time and include AdColony, AdMob, AppLovin, Chartboost, Crashlytics, Flurry, Fyber, Keywords International Limited, Helpshift, HyprMX, Kiip, Kochava, MoPub, Singular, Swrve and Tapjoy. These partners may collect, use and disclose personal information as set out in their respective privacy policies.

Personal information is any information that relates to an identified or identifiable natural person. This might include your name, address, email address or phone number, and sign-in information for third-party social networking services. The personal information that Hothead collects will vary depending on the type of products or services that you are using, including the Website or Hothead Applications, and how you access and use those products or services, but may include your name, contact information (such as email address, mailing address, fax number, and telephone number), demographic information (such as gender, age, and occupation), your device’s IP address, unique device identifier, MAC address, or other transactional or identifier information regarding your device or systems, geolocation information, “cookies”, social media information, and personal preferences. This information may also include the length of time you used or played any Hothead Applications, the features of Hothead Applications that you used, your game progress, and other game-related statistics.

Hothead may also collect and analyze non-personal information to evaluate how users use the Website or Hothead Applications. Such non-personal information may include general technical information about your computer, device, hardware, or software that you use to access the Website or Hothead Applications, or any of the information described above in circumstances where that information does not relate to an identified or identifiable natural person.

PURPOSE FOR PROCESSING PERSONAL INFORMATION

Hothead may process (for example, collect, use and disclose) information, including personal information, in the following ways:

  • to develop, deliver, maintain and improve Hothead Applications, the Website and other Hothead products and services and to better tailor them to meet the needs of Hothead’s users, customers and potential customers (including for analytics purposes);
  • to develop, deliver, maintain and improve Hothead’s marketing and promotional efforts and manage its relationship with you;
  • for third parties to provide Hothead and you with their products and services (including in relation to advertising), including to make ad targeting decisions, conduct audience segmentation and targeting in connection with online behavioral advertising, provide monetization services to their customers, assist their customers with maintaining their services, improving their services, and analysing the marketplace for their services as well as for the performance of their services, improving their services, and researching and developing new services, for fraud prevention, bot detection, quality rating, analytics, enhancements. These include:
    • any purpose for which HyperMX Mobile LLC (whose technology is incorporated into our service) processes personal information in relation to offers and the operation of our platform, as set out in its privacy policy from time to time, which policy is located at hyprmx.com/pp.html;
    • any purpose for which Unity Technologies processes personal information for advertising purposes in accordance with their privacy policy (see above);
    • any purpose for which AppLovin Corporation processes personal information as set out in its privacy policy from time to time, which policy is located at https://www.applovin.com/privacy/; and
    • we may disclose your personal information to MoPub (whose privacy policy is located at https://www.mopub.com/legal/privacy/) or any of their partners (a list of whom is located at https://www.mopub.com/legal/partners/) for personalized advertising purposes;
  • optimization, viewability, geolocation services, ad security, ad verification services, and service misuse prevention;
  • to communicate with you in connection with Hothead Applications or the Website;
  • to assist law enforcement agencies with the investigation of actual or potential fraud or other offences;
  • for any other purpose in connection with Hothead’s or a third party’s legitimate business interests (including in connection with actual or potential the sale, reorganization, or management of all or part of its business or operations);
  • to establish or exercise legal rights or defend against legal claims; and
  • as otherwise required or permitted by law.

Any of the foregoing may involve us combining the personal information we collect with personal information collected by third parties, such as our advertising partners, business partners and services providers.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

We rely on your consent to serve as the legal basis for our processing of your personal information in accordance with this Privacy Policy. We may occasionally rely on other legal bases in order to process your personal information in certain ways, for example where the processing is necessary in order to comply with a legal obligation to which Hotheads is subject. Where consent serves as the legal basis for our processing of your personal information, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to that withdrawal, by notifying Hothead’s privacy officer (contact at the bottom of this Privacy Policy).

RETENTION OF PERSONAL INFORMATION

Hothead will retain personal information:

  • in relation to a Hothead Application, until we permanently discontinue the game (we assume you want to be able to restore your gameplay at any time, so we only delete information where we are discontinuing the game and have decided to never restore it); and
  • otherwise, only as long as necessary for the purposes outlined in this Privacy Policy or as required or permitted by law.

DISCLOSURE OF PERSONAL INFORMATION

Hothead may disclose your personal information to the following organizations or types of organizations:

  • third party service providers and Hothead’s affiliated entities who carry out work on behalf of, or provide products and services to, Hothead,
  • law enforcement agencies,
  • legal, financial, insurance, and other advisors, and
  • as otherwise required or permitted by law.

Hothead will not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. Hothead acts as the controller in relation to your personal information, but there may be some circumstances in which a third party recipient of that information may also act as the controller of that information.

Transfer of personal data outside of the EU

In certain cases where your personal information has been collected in the EU, that personal data may be transferred outside of the EU. Hothead (or its partners) will take steps to ensure such transfer is carried out in accordance with applicable data protection laws. This includes that any third party recipient outside of the EU will ensure an adequate level of protection, for example, by adhering to the EU-US or Switzerland-US Privacy Shield or entering into the EU standard contractual clauses with the party that transferred that information.

YOUR RIGHTS

When appropriate, you may request to (i) opt-out of receiving communications from Hothead, (ii) remove your personal information from Hothead’s records, or (iii) elect to no longer receive information from Hothead. If you wish to opt-out in the manner as listed above, please contact Hothead’s privacy officer (contact at the bottom of this Privacy Policy). You may also be able to opt out of the collection and use of your information by third parties for ad targeting purposes through avenues such as http://www.aboutads.info/choices.

In addition, you may have the right in certain circumstances under privacy laws to request from Hothead:

  • access to,
  • rectification or erasure of,
  • restrictions in relation to the processing of (including in relation to direct marketing), and
  • data portability in relation to,

the personal information that we hold about you.

Please contact Hothead’s privacy officer in order to make such a request.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 allows users who are California residents and have provided their personal information to us to request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. To make such a request, please contact our privacy officer (contact at the bottom of this Privacy Policy).

Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year.

PRIVACY OF CHILDREN

Hothead does not knowingly collect personal information from children under 16 without appropriate parental notice and consent. If you are under 16, please do not attempt to use the Hothead Applications or the Website or send any information about yourself to Hothead, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to Hothead. In the event that Hothead learns that it has collected personal information from a child under age 16 without verification of parental consent, Hothead will delete that information as quickly as possible. If you believe that Hothead might have any information from or about a child under 16, please contact Hothead’s privacy officer.

SECURITY

Hothead takes steps to protect the loss, misuse, and alteration of the personal information that it holds. Hothead seeks to limit access to personal information to individuals who Hothead reasonably believes need to access the information to utilize the information as set out in this Privacy Policy. However, it is possible that any information transmitted via the Internet may be intercepted by unknown third parties.

COMPLAINTS

You may direct a written complaint regarding compliance with this Privacy Policy to the privacy officer and, within a reasonable time upon receiving the written complaint, the privacy officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the privacy officer will inform you whether the complaint will be allowed or denied. If the privacy officer allows the complaint, Hothead will take appropriate measures necessary to rectify the source of the complaint. Separately, you may also be able to lodge a complaint with a supervisory authority or privacy commissioner.

LINKS

Hothead is not responsible for the privacy practices of other websites, games or applications, including those that you access via a link provided in the Hothead Applications or on the Website. Hothead encourages you to read the privacy policy of websites, games or applications operated by third parties. This Privacy Policy applies solely to information collected by Hothead in accordance with the section above entitled “collection of personal information”.

CHANGES TO THIS PRIVACY POLICY

Hothead may update this Privacy Policy from time to time. It is your responsibility to periodically review this Privacy Policy to remain informed of Hothead’s current privacy practices. Your continued access to or use of the Website and Hothead Applications after such update constitutes your acceptance of this Privacy Policy as amended.

CONTACT

If you have any questions about this Privacy Policy, Hothead’s privacy practices in connection with the Website or Hothead Applications, please contact Hothead’s privacy officer as follows:

Hothead Games Inc.
Attention: Director of Technology (Privacy Officer)
Address: 1555 W Pender St., Vancouver, BC, Canada V6G 2T1
email: privacy@hotheadgames.com

 

Version 3.0
Last updated: September 10, 2018