Applicable from: MARCH 2019

Last Modified: JUNE 22, 2019

STITCH HEADS PRIVACY POLICY

Stitch Heads B.V. (“Stitch Heads” or “us” or “we” or “our”) is committed to maintaining the security,confidentiality and privacy of your personal data. This Stitch Heads Privacy Policy (“Policy”) explains how we collect, protect, use and share information gathered from you or about you online through www.stitchheads.com and www.kabouncegame.com (“Websites”) and through our games, applications, websites, and services (collectively, “Services”) that link to this Policy regardless of how you access or use them. It does not apply to information that you may submit to us, or to websites maintained by other companies or organizations to which we may link.

Our Privacy Policy is part of the End User License Agreement and Terms of Service http://www.kabouncegame.com/EULA for the Services in your region, which are incorporated by reference. This means your visit is also subject to the End User License Agreement and Terms of Service. Please review all relevant terms, and make sure you understand and agree to them, before using our Services.

Within the meaning of the General Data Protection Regulation (‘GDPR’), “Personal Data” is information that can be used to uniquely identify you, such as your name, email address, demographic information such as age gender and zip code, or credit card number. If you are residing outside of the European Union, personal data means “Personally Identifiable Information”.

1.What Data is Collected

You may be given the opportunity to register a player name when accessing one of our Services. For purposes of registration, we collect personal data about you. We also may collect your IP address, browser type, domain name, access times and referring website address. This information is collected during registration or in response to specific requests from you, for subjects including but not limited to signing up for an email newsletter, chat room, or other online information service we may offer, or contacting us.

Our Websites and Services contain links through which an online user can email us. We collect personal data contained in the email for the purpose of responding to a user’s questions and/or comments.

From time to time, we may post on our Websites job openings at Stitch Heads and provide an email address to which interested applicants can submit their resume. Although we can assure you that any personal data contained in a resume will be used solely for its intended purpose (i.e., to evaluate the applicant’s qualifications), such information is not subject to this privacy policy.[KdT1]

No matter what method we use to collect personal data and no matter how we use that information, we will only collect the information deemed reasonably necessary to fulfil your online requests and our legitimate business objectives. We collect two types of data, “personal data” that identifies you as a specific individual, and “non-personal data” that does not. The particular kinds of personal and non-personal data we gather depends on your interaction with Stitch Heads.

The data we collect includes but is not limited to:

CONTACT DATA. We collect names, email addresses, postal addresses, telephone numbers, and similar contact data.
AUTHENTICATION DATA. We collect usernames and similar data that helps secure and provide

access to our Services.

DEMOGRAPHIC AND PREFERENCE DATA. We collect demographic data (including but not

limited to your date of birth, gender, country, and preferred language)

general interests and preferences USAGE DATA. We collect data about how you interact with and navigate our Services, as well as

the device and software you use to do so. This includes data regarding:

your use of our Services (such as timestamps, clicks, scrolling, browsing times, searches, referral/exit pages, and in-game interactions);
your computer or device (such as IP addresses, unique device IDs, processing capabilities, manufacturer and model, language and other regional settings, geographic location, and screen resolution and similar settings);
your connection to our Services, including details about the network and software you’re using (such as browser type and version, operating system name and version, ISP, and your preference settings); and
how our Services perform, including problems you may encounter (such as loading errors and response times).

2.HOW DATA IS COLLECTED

You will be aware of collection when personal data is collected because you will be asked to fill out a form. However, we may collect some personal data about you by using data collection technology, so that it may not be readily apparent to you that it is being collected.

When collecting personal data, we will state the purpose of collection.

Stitch Heads collects your data in three general ways:

You provide it directly (such as by completing a registration form or survey);
We record it automatically (including but not limited to the use of analytics); and
We receive it from third parties (including but not limited to social media companies).

DATA YOU PROVIDE

Common ways you might provide us with data include but are not limited to:

responding to surveys;
participating in contests or similar promotions;
sending us email inquiries;
requesting products or services from us; and
using interactive features including in-game chat.

If you choose to make content or a document public, we recommend you redact any and all references to people and addresses, as we can’t protect public data and we are not responsible for any violation of privacy law you may be liable for.

Types of data we acquire in this way include:

Address
E-mail address

Data We collect Automatically

(1) LOG FILES. We automatically gather data about the ways you interact with our Services and store it in log files. This may include but is not limited to Usage Data (see What Data is Collected) about your visit, including data that your device or browser sends to us when you access our Services. This includes the following data:

Player name
Player ID (unique number per platform that identifies the player on the platform and is tied to the account).
IP address
Time and date
Progression in the game (a check whether the player has competed in in-game events granting a right to in game benefits)
Player level and statistics including hours played, rank, online or offline play, the server the play on.

Furthermore, we also acquire the data below in the event of reported cheating or harassment.

Reported Player
- Platform (Steam, Twitch, PlayStation 4)
- Player name (Nickname / game name on Steam or PlayStation etc.)
- Player ID
- Reason of reporting (Cheating, harassment, or otherwise disputable behaviour)
Reporting Player
- Platform (Steam, Twitch, PlayStation 4)
- Player name (Nickname / game name on Steam or PlayStation etc.)
- Player ID
- Reason of reporting (Cheating, harassment, or otherwise disputable behaviour)
Time and date.

(2) COOKIES AND OTHER TRACKING TECHNOLOGIES. “Cookies” are small pieces of data that online services you use place on your device for record-keeping purposes. “Web beacons” are transparent pixel images that allow online services to collect data about the ways you interact with them (including whether you’ve opened an email or clicked on an advertisement). Other common tracking technologies include tags, scripts, local shared object, local storage, and similar tools.

Our Services may use cookies, web beacons, and other tracking technologies to automatically collect, store, and read files on your device. They may be delivered in a first-party (i.e., by Stitch Heads) or third party (i.e., by other companies) context. These tools help our Services work and operate more efficiently, as well as capture Usage Data (see What Data is Collected) and similar data about your browsing experiences. You will always have the option to reject cookies and other tracking technologies, with the exception of those technologies that are essential for the performance of the website and our services.

We use data gathered through tracking technologies for several reasons, including:

To monitor, secure, and maintain our Services;
To enhance your browsing experience;
To analyze and improve our operations (including aggregating traffic and usage patterns);
To support and gauge the effectiveness of our communications and marketing campaigns
(including but not limited to letting us know if you’ve clicked on our ads or opened our emails);
To better personalize your visit and store your preferences and settings; and
To otherwise manage our relationship with players.

You can learn more about cookies, including details of how to manage or disable them, by visiting http://aboutcookies.org/ or consulting your browser’s privacy features. Some ways of managing traditional cookies may not impact the use of other tracking technologies, but certain browsers may offer their own tools for disabling other tracking technologies.

Please note that disabling tracking technologies may prevent you from using the full functionality of our Services and they may not work as we intended.

(3) ANALYTICS PROVIDERS. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Services. This includes vendors we’ve engaged to provide services on our behalf (including but not limited to website analytics), as well as third parties that deliver content (including but not limited to videos from YouTube) or offers (including advertisements from ad networks) contained in our Services. We may receive reports based on our partners’ use of these tools on an individual or aggregate basis.

We use third-party analytics providers including Google Analytics to help evaluate and report on use of our Services. These companies may set and read their own tracking technologies to gather data about your online activities across websites and services. Some analytics providers offer you choices about how they collect and use data directly on their websites. To learn more about opting out of Google Analytics, go to the following page: https://tools.google.com/dlpage/gaoptout

Other Sources

Sometimes we obtain info from third parties (including but not limited to social media companies, marketing partners, or public databases) to use along with the info we collect from you. This information will always be acquired on a legal basis.

Our partners may share Demographic and Preference Data, Usage Data, or other similar data with us to support our marketing initiatives.

3.PURPOSE & SHARING OF DATA

Stitch Heads will only use your personal data to provide and improve Stitch Heads Services, operate our business, advertise effectively or to communicate with you about such Services or the Websites. With respect to any content or documents you may choose to upload to Stitch Heads, we take the privacy and confidentiality of such seriously.

USE OF PERSONAL DATA

The personal data we collect helps us operate our business, provide and improve our products and services, communicate with you, and advertise effectively. The particular ways we use personal data often depend on how you choose to use our Services.

We collect, use and disclose your personal data for the following purposes:

provide and administer requested products and services, and to disclose the data for any purpose related to operation of accounts and provision of requested products and services;
respond to inquiries and fulfill requests
deliver and tailor our communications with you, including but not limited to sending you important account-related announcements or promotional communications that we believe may interest you. (for details about managing your communication options, check out User Choices and Controls below);

administer surveys, contests, sweepstakes, and similar offerings;
monitor, analyze, protect, and improve our operations, including fighting cheating, harassment and similar practices;
promote products and services and measure the effectiveness of those campaigns;
personalize your experience, including by presenting content or features better tailored to your interests;
monitor your compliance with any of your agreements with us;
protect us, yourself and others from fraud and error and to safeguard our business interests;
operate and expand our business; and
facilitate social sharing and related functionality.

We also process personal data as described in Compelled Uses and Disclosures below.

SHARING PERSONAL DATA

We share personal data as described in this Policy and as necessary to provide services you request or process transactions you authorize.

(1) SUBSIDIARIES AND AFFILIATES. We share personal data with Stitch Heads’ subsidiaries and affiliates to be used jointly by us and them as described in this policy.

(2) VENDORS AND SERVICE PROVIDERS. We share personal data with vendors and service providers that operate on our behalf for the purposes discussed in this policy. Including any purchases of our Services, for which we retain the right to share your payment-related data with entities we’ve engaged to process payments and provide similar financial services (including but not limited to fraud prevention). If we do share personal data with vendors, they’re only allowed to process it as necessary to perform the services we’ve requested.

(3) DATA YOU SHARE. You are aware that we may use the data you share publicly through interactive features we control, including but not limited to forums and in-game chat We reserve the right (but have no obligation) to monitor your use of them. To request removal of your personal data from forums or similar features controlled by Stitch Heads, contact Us. We may not be able to remove your personal data in some cases, but we will inform you on the reason.

(4) CORPORATE TRANSACTIONS. We may disclose personal data in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You agree that your data may be one of the assets transferred to the acquiring entity in such situations.

(5) COMPELLED USES AND DISCLOSURES. We may use, disclose, and preserve personal data as we determine in our sole discretion is necessary or appropriate to:

Comply with applicable law or respond to legal process (including from law enforcement or other public or government authorities);

Operate and secure our Services (including stopping attacks on our systems);
Protect players and third parties (such as to help prevent serious injury or crime); and
Protect our own rights, property, and operations (including but not limited to enforcing our contracts and terms, including the End User License Agreement and Terms of Service (www.kabouncegame.com/EULA), this Policy and pursuing available remedies or limiting the damages we may sustain).

USE AND SHARING OF NON-PERSONAL DATA

We use and share non-personal data for many of the same reasons as personal data: it helps us operate our business, provide and improve our products and services, and advertise effectively. Because it doesn’t personally identify you, we often process non-personal data to support our operations in different ways as well. We reserve the right to process non-personal data for any lawful business purposes not otherwise prohibited by this policy.

Some of the most common reasons we use and share non-personal data include but are not limited to:

personalize your experience with our Services;
track usage patterns and analyze trends;
promote products and services and measure the effectiveness of those campaigns;
control the display of content and advertisements;
monitor and improve our Services;
conduct research (including by collaborating with third parties, such as universities);
administer our Services, secure our operations, and prevent fraud
diagnose technical issues including but not limited to server problems;
manage our relationship with our players; and
share in-game data with Stitch Heads’ developers for the use of contributing to the player experience (including but not limited to your win / loss record, customization setups, and average number of kills and deaths).

Note that non-personal data includes aggregated, anonymized, or otherwise de-identified data that doesn’t individually identify you

4.THIRD-PARTY WEBSITES AND SERVICES

We work with third parties to make your experience better, but our privacy policy does not and cannot apply to entities we don’t own or control. We’re unable to guarantee that other third-parties adhere to the same practices as us, you should review its or their privacy policies to understand their personal information practices.

There are several ways you might share info with third-party websites or services in connection with your visit, including:

EXTERNAL LINKS. If you click on links to external websites or services that are operated by third parties, they may collect, use, and share your personal info pursuant to its or their own policies (not ours). Including a link to or from third-party services doesn’t mean we’ve endorsed their practices.
SOCIAL MEDIA FEATURES. Our Services use interfaces with social media companies to provide features that facilitate social sharing and connections (including but not limited to the Facebook “Like” button and other widgets). These features may collect info about your interactions with them and our Services, and may use tracking technologies including cookies to function properly. How social media companies process your info is controlled by their own privacy policies.
THIRD-PARTY TRACKING. Our Services may contain cookies, web beacons, and other common tracking technologies that help us collect and analyze info in connection with your visit (see Data We Collect Automatically). Third parties (including but not limited to analytics companies) may set and read their own tracking technologies on our Services. If they do, they’re responsible for using these tools as described in their respective privacy policies.

Please remember to contact third parties directly (and not Stitch Heads) if you have any questions or concerns about their practices.

5.CHILDREN’S ONLINE PRIVACY

Our Services are not intended for persons under the age of 16. We don’t direct content specifically at, and don’t knowingly collect personal data from, any such persons. If you’re younger than 16 years of age, please don’t use our Services or otherwise provide us any personal data. If Stitch Heads discovers that a person under the age of 16 has provided Stitch Heads with personal data, Stitch Heads will immediately delete that person’s personal data from our Services. If you’re the legal guardian of a child younger than 16 and have reason to believe he or she has provided personal data to Stitch Heads, please Contact Us immediately to request that we delete it.

6.USER CHOICES AND CONTROLS

You have choices regarding your use of our Services and the ways we process info. These rights can be invoked by sending us an e-mail to the address mentioned under nr. 10.

LIMIT PERSONAL INFO YOU SHARE. The main way we collect personal info is when you give it to us voluntarily. You can choose to browse some parts of our Services without ever purchasing products or services, or otherwise submitting personal info to Stitch Heads (see Data You Provide). If you do provide us with personal info, we generally retain it as long as it is necessary to provide our Services and operate our business (including for purposes such as complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, and enforcing our contracts and terms, such as this Policy and the End User License Agreement and Terms of Service (www.kabouncegame.com/EULA)), unless a longer retention period is permitted or required by law.
ACCESS OR DELETE YOUR PERSONAL DATA. You have a right to access, or request to update or delete your personal data held by Stitch Heads. Upon written request and authentication of your identity, we will provide you your personal data under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so. We will make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request. In some situations, Stitch Heads may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, , the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of Stitch Heads). Stitch Heads may also be prevented by law from providing access to certain personal information. Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you. Note that requesting deletion of your personal info may also result in termination of our Services to you.
You have the right to make a complaint about the way we handle your personal data to the Dutch Privacy Authority, called the Autoriteit Persoonsgegevens.
UPDATE YOUR COMMUNICATION PREFERENCES. While we offer players the option to receive updates and promotional communications from Stitch Heads, you can change your preferences at any time. To opt-out, simply “unsubscribe” by following the instructions in any of our promotional emails. These choices don’t apply to mandatory communications that are part of our Services, including but not limited to important account-related notices.
CHANGE YOUR BROWSER SETTINGS. Many Internet browsers allow you to reject, manage, and delete cookies. You may also be able to manage other forms of tracking technologies, such as HTML5, by changing your browser settings (see Data We Collect Automatically).
CONTROL THIRD-PARTY TRACKING. Ad companies, analytics providers, and similar third parties may place their own tracking technologies on our Services (see Data We Collect Automatically). If you don’t want to take advantage of the services that such tracking technologies provide, you may be able to opt-out by visiting http://www.aboutads.info or http://www.networkadvertising.org/choices/, or if you’re located in the EU, http://www.youronlinechoices.eu/. Some companies also allow you to opt-out by contacting them directly.
UPDATE YOUR THIRD-PARTY PRIVACY SETTINGS. If you authorize third-party services to share info with us, you may be able to control the types of info they make available by directly updating your privacy settings on their service.

7.SECURITY OF DATA

We are committed to securing personal data and employ industry standard techniques to protect against unauthorized access of data about you that we store, including personal data, but can’t guarantee the security of any data we collect from you.

We use physical, technical, and organizational security safeguards to help protect your personal data from unauthorized access, use, or disclosure. Including but not limited to storing personal data in secure operating environments that are not available to the public and are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse and alteration of the information under our control. We also use technologies such as encryption and hashing to protect some of the data we collect.

Data will not be sent to parties outside of the European Economic Area. If for some reason this should however be necessary, you will be informed prior to sending the data.

We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us.

However, please note that no server, communications network, or data transmission over the Internet is completely secure. Our Services are no exception. We can’t guarantee the security of any data transmitted through our Services and make no assurances about our ability to prevent any such loss or misuse.

Note that confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Please notify Stitch Heads’ Privacy specialist in writing if you do not want Stitch Heads to communicate with you through these means.

It’s up to you whether you’d like to share personal data with us; if you do, you’re acknowledging and agreeing that you’re doing so at your own risk based on the terms set out in this statement.

8.Retention OF DATA

Any data you share with us will be retained for a set period of time. Below this will be specified:

General data, necessary for the use of our services, will be retained for a period of two years after your account becomes inactive. An account is deemed to be inactive when there has been nog log-on for a period of three months.
Data specifically needed for fiscal or other legal purposes, will be retained for the period as specified by law.
Data that might be necessary for legal proceedings, will be retained for as long as legal proceedings are reasonably expected and no final verdict has been passed by the highest legal authority.

9.ACCURACY OF DATA

We will make a reasonable effort to ensure that personal data we are using or disclosing is accurate and complete.

If you demonstrate the inaccuracy or incompleteness of personal data, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

10.UPDATES & REVISIONS

We will update our privacy policy from time to time to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. When we do make changes, we will update the “Last Modified” date at the top of the Policy and post it to our Services. If we make material changes to the policy or the ways we process personal info, we’ll provide you additional notice as well (such as by prominently posting a notice of the changes on our Services before they take effect or sending you a notification directly).

We encourage you to check back periodically to review our privacy policy for any changes since your last visit. This will help ensure you better understand your relationship with Stitch Heads, including the ways we process your data.

11.CONTACT US

We have designated a Privacy specialist who is responsible for our compliance with this Policy. The Privacy specialist may be contacted as described below. Any inquiries, complaints or questions regarding this Privacy Policy should be directed in writing to support@stitchheads.com.