Spiritwalk Games, Inc.
Privacy Policy
Effective Date: August 2016

At Spiritwalk Games, Inc. (“Spiritwalk”), maintaining the trust of our users is of the utmost importance to us. We have developed this privacy policy to explain how we collect, use, share and disclose information about our users, and to show our commitment to fair information practices and the protection of user privacy. We do not sell any personal or other identifying information about our users, and we do not disclose any personal information to third parties for direct marketing purposes. We also do not and will not provide personal information about our users to any third parties that do not have a legitimate need for that information in connection with their business relationship with Spiritwalk.

We do, however, collect certain information from our users; we do this so that our users can access Spiritwalk’s website, video games and other software products (collectively, the “Services”), and participate in and take advantage of the products, services and information we offer via those Services. This privacy policy describes information that Spiritwalk collects, as well as the ways in which we may use and share that information.

This policy will be posted on and/or accessible from within any website, mobile application or video game that Spiritwalk operates. The Services may at times refer you or link you to websites operated by third parties, or may provide you with URLs or other information so that you can access third-party websites. Third-party websites will have their own privacy practices and policies, which may differ materially from Spiritwalk’s policies and practices. It is your responsibility to read and confirm your agreement with the privacy policies and practices of any and all third-party websites, applications and software, whether you access them using the Services or from outside the Services based on information you may have obtained from the Services.

Important Notices

Notice Concerning Children

PLEASE NOTE: Our content and Services are intended for a general audience. We operate a business that is targeted at adult customers and users only, and we do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a user of the Services is under age 13, we will promptly delete any personal information that might be stored about that user.

Notice Regarding International Users

The Services are hosted in, and are directed at users from, the United States. Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. Spiritwalk and its Services are subject to U.S. laws, which may not afford the same level of protection as the laws of other countries (which may include the laws of your country if you are outside the United States).

Collection and Use of Information

Personal Information. As used in this privacy policy, “Personal Information” refers to information that can be used, directly or indirectly, alone or together with other information, to identify a specific individual. A user’s Personal Information includes (without limitation) his or her name, address, telephone number, and email address. Personal Information may also include information about activities or activity level, game achievements or other player statistics or accomplishments, and information about a user’s location, to the extent that the user elects to share any of that information with us, or to provide us with access to any of that information that may be stored on or otherwise available from his or her computer, phone or other device from which he or she accesses or communicates with any of the Services. 

In operating the Services, our practice is to collect limited personal information from our users, and only where and to the extent necessary, so that we can deliver to our users the Services they are using or requesting to use. You always have the option not to provide us with any Personal Information, or to limit the Personal Information that you provide us or allow us to access, but you understand that any such restriction or limitation may affect your ability to take advantage of all of the Services that we offer. 

We may also allow you to connect with certain third-party platforms and social media services (such as Twitch, Twitter, Facebook, Google+ and other similar services), or to link your Spiritwalk account to your account on those third-party services. If you do use the Services to connect to a third-party service, please make sure you are familiar with and in agreement with the ways in which that third-party service will share your personal information. Similarly, if you use the Services to provide information to those third-party services, the information will no longer be under our control, and will instead be subject to the privacy policies and other terms of use of those third-party services. It is your responsibility to control whether your activities and information from our Services are provided to third-party services.

If you do elect to provide Personal Information to us, the Personal Information we collect and store will be used for one or more of the purposes specified below:

Account Creation: You can use the Services to create an account with us, and we may require you to create an account if you want to have access to and play any of our video game software. To create an account, we require your email address, your user name and a password, and then we provide you with instructions for completing the creation of your account. We may also request or require that you provide us with your first and last name, or you may be required to do so in connection with any purchases you wish to make using the Services. After you create an account, you can use your account information to log into any Services that have a login feature.

Depending on your settings, some of your account information (e.g., your chosen username, display name or email address) may be available to other users of the Services, and may be searchable from within some of the Services. We have no control over any Personal Information that you may choose to share with other users via the Services (such as via chat or other functions), and so cannot commit to keeping that information private once you have chosen to share it and make it publicly available.

It is your responsibility to protect your account and make sure that no one else has access to your password or uses your Spiritwalk account. You are responsible for all activity that occurs using your account, even if done by someone other than you, and even if done without your permission or knowledge, unless we determine that you were the victim of fraud, hacking or other criminal activity that goes beyond mere unauthorized use of your account.

Newsletter Subscriptions and Surveys. If you want to be on our mailing list and receive electronic newsletters or other regular informational communications from us, you will need to give us an email address to which we can send those communications. From time to time we may ask you to participate in optional surveys, which may ask for other personal information such as your age, gender, occupation or location, but you will always have the option not to provide us with that information.

Password Recovery. Our password recovery feature requires us to have a valid email address for you, and if you click on a “Forgot Password” or similar link, we will use your email address in order to send you a link that you can use to reset your account password.

Contact Us. We provide our users with a number of ways to contact us, so that they can reach us with their comments and questions. Our website includes a contact email address, and our apps and games may allow users to message us from within the app or game, and/or they may provide users with an email address at which we can be reached. We also expect to maintain a presence on Twitch, Facebook, Twitter, Instagram and other social media and gaming platforms. If you communicate with us by email, even if you have not previously provided us with your email address, we will use your email address if necessary in order to respond to you, and we may retain your email address in our files during and for a period after the time that we are in communication. We do not control the terms of use or privacy policies for any social media platforms in which we participate, and it will be solely your responsibility to familiarize yourself with their information collection practices and only communicate with us and/or disclose personal information via social media (which will be collected by the third-party social media platform operators, and not by us) if you are in agreement with those information collection practices.

Credit Card or Other Payment Information: If any of our Services require you to pay for access or use, or for in-game purchases or other game-related payments, then you will be required to provide credit card information (name, credit card number, expiration date, and CVV code) or allow the Services to process payment via PayPal (or other payment options that we may make available from time to time). Your credit card or other payment information will be used only to process the particular purchase that you are trying to make; however, while we do not store or retain your credit card or other payment information, we do store any addresses that you provide in your account. See below under “Changes to Your Stored Information” for information on how you can review, modify and/or delete any information that has been stored to your account.

Other Notices: If you create an account or otherwise provide us with an email address, we may use that address to let you know about changes to this policy or to our terms of use, or to contact you about specific game-related issues or your use of the Services generally, or to reply to any support issues or other questions. Any time we send you an email, it will include an unsubscribe link, so that you can request that we do not send you any more emails. If you enable notifications via any Service that allows for notifications, then you will receive those notifications (which may take the form of badges, banners, alerts or any other notice format available on the applicable computing device) that you have authorized the device to provide.

Anonymous Information. “Anonymous Information” is any information or data that is anonymous, aggregated, de-identified, or that otherwise does not reveal your identity. We may collect and use Anonymous Information about our users in any of the following ways:

Automatic Collection and Analytics: Our servers can automatically recognize visitors’ domain names and IP addresses and may also identify a user’s computer/mobile device type and connection information, as well as information about browser type and browser settings and (where possible) geographic location. We also may use Google analytics to track user traffic to our website. No Personal Information about you is revealed in this data collection and tracking process. We may also use clear gifs (also known as web beacons) and other methods to gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving our website or other Services we offer. Clear gifs may also be used in email messages that we send, so that we can track whether recipients have opened those messages.

Cookies. From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our website. We do not set any Personal Information or personally identifiable information in cookies, nor do we employ any data capture mechanisms in the Services other than cookies. Cookies can help us remember items that you have placed in a shopping cart or tried to purchase if you leave a website or application before completing your purchase of those items. Cookies also help us learn which of the Services are useful and which Services need improvement. You can choose whether to accept cookies by changing the settings on your browser and/or in your computing device. However, if you choose to disable this function, your experience at with the Services may be diminished and some features may not work as they were intended. Promotions or advertisements displayed via the Services may also contain cookies, and we do not have access to or control over information collected by outside advertisers when you click on any such promotions or advertisements.

Security and Bug Tracking. We expect the Services to include features that will help us track down bugs and crashes; some of these features will include reports that are generated by our users’ devices, and these reports include information about device type, capabilities, and other software running at the time of the crash. You will have the option whether or not to provide this information to us, and it will always be provided to us anonymously. This information will never include Personal Information and never be identifiable by use, and we will use this information for our development, debugging and other quality improvement efforts.

Additional Use and Disclosure of Personal Information

In addition to the uses and disclosures described above, we may disclose Personal Information if we determine that we are required to do so:

• To comply with applicable laws, or with legal process served on us;

• To protect or defend our rights or the rights of any of our users or business partners;

• To enforce our terms of use or other agreements; or

• To protect anyone’s rights, property or safety (including our own).

In addition, in order to accommodate changes in our business, we may sell our company or portions of our company or sell or buy portions of other companies or assets, including information we collect through the Services. If Spiritwalk or its assets should ever be acquired a third party, then we expect that our database of user information (including Personal Information) would be one of the assets sold in such a transaction, and we would ask that the buyer notify you of any changes to this policy after the sale closes.

We may revise this policy from time to time – e.g., to keep up with changes in the law, or to reflect changes in how we are doing business. All Services that are governed by this policy will always include our most up-to-date privacy policy, and we include an effective date at the top of the policy, so you can quickly see when we last updated the policy. Any updates or modifications to this privacy policy will be effective as soon as we post the updated privacy policy to the Services, and it is your responsibility to review this privacy policy periodically to make sure you continue to be in agreement with all of its terms.

Security of Your Information

We have a variety of security measures in place to maintain the safety of your Personal Information. Your Personal Information is securely stored and is accessible only by our employees and agents who have a need to access that information, who are aware of and required maintain the confidential nature of that information. When you place an order using the Services, all credit card and other sensitive information you supply is encrypted and transmitted via Secure Socket Layer (SSL) technology, and is never stored by us for any longer than is necessary to complete your purchase transaction.

Changes to Your Stored Information  

You can notify us at any time that you want to terminate your account with us, or terminate our storage of your Personal Information, and upon receipt of that notice, we will remove all information about you from our database, at which point you will no longer receive email notices and updates from us. Please note that, due to email production schedules and lead times, your account may not be disabled immediately, and you may receive emails that were already in production or scheduled for delivery at the time that you made changes to your email subscriptions or other information. In addition, we will retain information provided to us in connection with any purchase made using the Services in order to complete and deliver the purchase, and for our record keeping purposes.

Additional Information

We understand that some users may have enabled a “do not track” feature in their web browsers; however, consistent with and to the maximum extent permitted by applicable law, we currently do not honor any "do not track" requests sent from a web browser. This is our online privacy policy and applies only to information that we collect through our Services, and not to any information that may be collected offline. Any time you have any questions about this policy, or about our privacy practices in general, please email us at contact@spiritwalkgames.com and we will get back to you as quickly as possible. By using our Services and the content and features that we offer, you are providing us with your consent to this privacy policy, and if at any time you are not in agreement with this privacy policy, you must immediately end your use of our Services and of any content or features we offer.