Privacy Policy

This Privacy Policy ("Policy") describes the personal information that Codename Entertainment Inc. ("Codename", "we" or "us") collects from or about you when you use our website, social games and related services, including applications for mobile devices, or participate in our events, how we use that information, and to whom we disclose it.   "Personal information" means information about an identifiable individual, and does not include general, statistical or aggregated information.       

Please read this Policy carefully.  If you do not agree with this Policy, you should not access or use our website or applications.  This Policy should be read in conjunction with the www.[codenameentertainment].com website Terms of Use, into which it is incorporated by reference.

This Policy was last updated on May 18, 2017.  We reserve the right to revise this Policy at any time and, as such, you should review its terms each time that you use our website or applications. Any changes to this Policy will be promptly communicated on this page, but will not go into effect until at least five (5) days after they are posted.

Accountability and Openness / Compliance

Codename is responsible for personal information under our control.  We have established policies and procedures to effectively safeguard any confidential personal information that we have on file or which we collect, and to deal with complaints and inquiries.  We only collect personally identifiable data when it is voluntarily submitted by you through the use of our games, websites and applications, and are committed to maintaining the accuracy, confidentiality and security of your personal information.  We will ensure that you have access to information regarding the policies and procedures that we use to manage your personal information. 

Codename has designated a privacy officer ("Privacy Officer") who is accountable for our compliance with this Policy, and for ensuring that information about our policies and practices relating to the management of personal information is easily accessible.  All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing, and sent by email to privacy@codenameentertainment.com or by post to:

Privacy Officer
Codename Entertainment Inc.
#9 – 625 Alpha Street
Victoria, BC
Canada V8Z 1B5

Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it.  This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user. 

Consent

Except as expressly provided in this Policy or as otherwise permitted by law, consent is required for the collection of personal information and the subsequent use or disclosure of that information.  Consent may be express or implied.  For consent to be meaningful, it must be informed consent and will only be valid if it is reasonable to expect that the individual understands the nature, purpose and consequences of the collection, use or disclosure of the personal information to which they are consenting.  Typically, consent will be sought for the use or disclosure of personal information at the time of collection, and reasonable efforts will be made to ensure that you understand the purpose(s) for which the information will be used or disclosed.   In certain circumstances, consent regarding use or disclosure may be sought after the information has been collected, but before use, such as when Codename wishes to use personal information already in its possession for a purpose that was not previously identified.

By voluntarily submitting your personal information, registering with us, or using our website, games, applications, or web-based services, you signify your agreement to the terms and conditions of this Policy and to our use of your personal information in accordance with this Policy.  You may make inquiries, or change or withdraw your consent to the collection, use and/or disclosure of your personal information at any time by contacting the Privacy Officer in writing at either of the addresses listed above.  In some circumstances, a change or withdrawal of consent may affect your ability to use an application and/or our ability to provide you with information, products or services. 

Collection and Retention of Information

We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose - Why We Collect, Use and Disclose Information).  In most cases, we will collect personal information directly from you when you interact with us with respect to our games, websites, applications, events, or any other product or service that we offer.  Occasionally, we may collect personal information from a third party based on your consent or as otherwise permitted by law.  Personal information will always be collected using means that are fair and lawful.

Examples of personal information that we may collect, use and disclose include your name and email address, gender, whether you are a minor, and other information that you may provide to us in conjunction with your use of our games, website, applications, and services.  Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected.  Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media.

Users may visit our website without telling us who they are, or revealing any information about themselves.  However, like many organizations’ websites, our web server automatically logs certain non-identifying information related to a user’s visit to the website, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed our website, the Internet address of the website from which the user linked directly to our site, the operating system that the user is using, and the pages of the website that the user has visited.   We will not attempt to link this information with the identity of individuals visiting our website unless we have permission to do so.  We may, however, review server logs and anonymous traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage.  The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals.  In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.

If you provide comments or other feedback to us, you agree that such comments or other feedback become the property of Codename, and we may use and disclose them for any purpose provided that we do not associate them with your personally identifiable information.

Cookies

A "cookie" is a small piece of information stored on your computer by a web page. It is used to identify you to the web server. It tells the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system.

We may use cookies to determine your access privileges on our websites, to complete and support a current activity, and to track website usage.

Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent.    If you decline cookies, you will still be able to use the website or application, but your ability to access certain features and functions may be affected.

Purpose - Why We Collect, Use and Disclose Information

We will identify the purposes for which we collect personal information before or when we request the information.  We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent.  The information that we collect is used and disclosed only for business purposes.  These include: 

  • to enable you to register to access restricted areas of our websites and/or to subscribe to and use our games and applications, and to communicate with you regarding their use;
  • to identify you in our games, and to display you in rankings and leaderboards;
  • to provide you with support updates, forum notifications and game bonuses;
  • to provide you with personalized content, and to maximize our ability to provide you with information that is useful and relevant to you;
  • to allow you to participate in contests and rewards programs;
  • to obtain feedback regarding our games, applications, websites and events;
  • to verify that any information submitted by you is accurate and complete;
  • to communicate with you and to create a record of your involvement with us;
  • to track your interests and preferences in order to customize and enhance your use of our games;
  • to conduct polls and surveys;
  • to provide you with information and promotional materials regarding Codename, and our products and services;
  • internal business purposes, such as administering or improving our games, applications and websites;
  • to protect us against error, fraud, theft or damage to our assets, our business or our property;
  • to comply with any legal, accounting and regulatory requirements, including reporting requirements;
  • any other reasonable purpose for which you provide consent, or for which consent may be implied in accordance with this Policy and applicable law.

Where personal information that has been collected is to be used for a purpose not previously identified, and for which consent cannot be reasonably implied, the new purpose will be identified and consent obtained prior to the use of that information for the new purpose unless otherwise permitted by law.

Disclosure to Third Parties

Your personally identifiable information is never sold and, except as specifically provided in this Policy or permitted by law, will not be shared with third parties unless we provide you with both prior notice and choice. 

You acknowledge that, in the course of our supply of products and services to you, we may delegate our authority to collect, access, use, and disseminate your information to third party subcontractors.  Third party subcontractors may include web hosts and payment processors.  If we transfer any personal information to a third party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them. However, you agree not to hold us liable for the actions of any third party subcontractor, even if we would normally be held vicariously liable for their actions, and understand that you must take legal action against them directly should they commit any tort or other actionable wrong against you.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request, request of a law enforcement agency, search warrant, subpoena or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to protect our assets, the users of our website, products or services, or the public.

Subject to certain restrictions, Codename may also use and disclose your personal information without your knowledge or consent where necessary in connection with a proposed or completed business transaction.  "Business transaction" includes those transactions described in the Personal Information Protection and Electronic Documents Act, S.C. 200, c. 5, as amended. In each such case, Codename and the other part(ies) to the transaction or proposed transaction will enter into an agreement limiting the purposes for which the personal information may be used and disclosed, ensuring its protection by means appropriate to the sensitivity of the information, and providing for the return or destruction of the information if the transaction does not proceed, or if the transaction does proceed, to notify you within a reasonable time that your personal information has been disclosed.

Finally, extreme caution and common sense should be exercised when you disclose your personal information directly to third parties, including other users, in connection with your use of certain of our games, applications, chat rooms, venues, and other web-based services.  You acknowledge that, in such cases, this Policy does not apply as Codename cannot control the collection, use or disclosure of any personal information that you provide directly to third parties and, accordingly, will not be liable for any misuse by such third parties. 

Safeguards – How Information is Protected

We have implemented reasonable physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held.  The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information.   We use user IDs, passwords, and encryption technology, maintain our servers in locked premises, and restrict the employees and contractors who have access to personal information to those having a "need to know" and who are bound by confidentiality obligations, in order to ensure that information is handled and stored in a confidential and secure manner.  Any credit card information that you submit will not be stored on our servers, but rather will be sent to a PCI Level 1-compliant payment processor for storage. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information.   While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.

We will continually review and update our security policies and controls as technology evolves.  However, no security technology can be guaranteed to be failsafe.  Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us.  Therefore, by downloading and using our information, applications and services, and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.

Accuracy / Access

Codename has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date.  You may make a request in writing for access to your personal information.  We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. 

Subject to certain limitations, we will endeavour to provide you with reasonable access to your personal information.  In certain circumstances, Codename may not be able to provide you with access to all or some of your personal information, in which case you will be advised in writing. 

If you demonstrate the inaccuracy or incompleteness of your personal information, the information will be amended as appropriate.  You should advise us immediately if you discover inaccuracies in our data, if your personal information changes, or if you wish to have your information removed from our files.  All notices and requests should be in writing and sent to the Privacy Officer at one of the addresses set out above (see: Accountability and Openness / Compliance).

International Transfer and Storage of Information

You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States.   We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada.  By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information outside of Canada.

Third Party Content and Links to other Websites

Our games may require access through third party platforms.  Our websites may contain optional links to advertiser and other third party Internet sites and services.  You acknowledge that these third parties may collect data from users or their computers.  The accessing and use of third party websites is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites.  This Policy applies only to Codename websites and applications, and we encourage you to review the privacy policies contained on each Internet site and in each application that you use.

Minors

Minors should not use our games, applications or website unsupervised, and we request that minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use our games, applications or website in conjunction with and under the supervision of an adult. Codename does not knowingly collect personal information from minors.

Governing Law

You agree that your access to and use of the Codename websites and applications, and this Policy, are governed exclusively by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles).  In case of any inconsistency between this Policy, and applicable law, applicable law shall prevail and this Policy shall be interpreted so as to apply only to the extent permitted by law.