HEMPIRE PRIVACY & COOKIES POLICY
Effective Date: May 25, 2018
At LBC Studios Inc. (“LBC”), we know privacy is important to you.
The Services are intended for a mature audience and we encourage you to review the age rating standard applicable for your country of residence. If you are under 14 years of age, or otherwise have not reached the minimum age set out in standards applicable to your country of residence, you may not use the Services in any way.
LBC does not knowingly or intentionally collect information from children under 14. If we learn that we have received information directly from a child who is under the age of 14, we will delete the information.
COLLECTION AND USE OF PERSONAL INFORMATION
We collect and use your personal information (i) to enable us to perform the contract entered into between you and us when you signed up to use the Services, (ii) for the purposes of our legitimate business interests and/or (iii) where we have your consent to do so. Specifically, we may collect and use personal information on the Website or the App when you:
Connect a third-party account to the App and engage with us on social media;
Purchase Digital Currency;
Exchange Digital Goods in our in-App Marketplace;
Participate in our contests or competitions;
Make a purchase in the Hempire shop;
Contact us with a comment, question, or complaint;
Sign-up to receive promotional communications from us or ask to receive game notifications; and
Submit a post, comment, leave a reply, or upload content to the in-App community.
Connecting and Social Media: You do not have to register or sign in to visit the Website or use the App. However, to benefit from certain features of the App, such as saving your game progress, you may be required to connect a third-party account to the App, such as your Facebook account or the account tied to your mobile device’s operating system (“Sign-in Partner”). When you access the App with your Sign-In Partner account, we collect the name or username you provide, and make this name or username public within the App.
We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins, and applications, including Facebook and Instagram, you may allow us to have access to certain information associated with your social media account to deliver the content or as part of the operation of the website, plug-in, or application. For example, if you chose to connect your Facebook account to the App, you may authorize us to collect certain information from your Facebook profile (e.g., name, username, email address, profile picture, gender, friend list, geo-location, or other information you make public on your Facebook profile). You may be able to control what information you provide us with in the preferences or settings of your social media account. When you provide information from your social media account, we may use this information to personalize your experience on the App and on the third-party social networking websites, plug-ins, and applications and to provide you with other products or services you may request.
Purchasing Digital Currency: Using the App is completely free. We make in-App purchases available to our users who may choose to purchase virtual currency (“Digital Currency”) to unlock certain features or functionalities such as game levels, in-game progress, and certain game enhancements. Purchases of Digital Currency are paid for with real money. If you choose to purchase Digital Currency, we may collect certain personal information including your name, email address, billing address, and payment card information. We use this information to process your transaction. We may also collect this information when your transaction is processed by another party, such as your Sign-in Partner. The purchases you make through a Sign-in Partner account may be subject to additional policies and terms and we encourage you to review such policies and terms carefully before making an in-App purchase.
Marketplace: To provide richer and more interactive game-play, we make an in-App marketplace, the “Global Market”, available to App users who have achieved a certain game level. The Global Market allows users to exchange, trade, and sell certain virtual items (“Digital Goods”), which are useful in the App. When you post Digital Goods for sale in the Global Market, or communicate with sellers or buyers in the Global Market, you provide your username, and any additional comments or content you wish to provide or upload to your post or messages. We use this information to post your username publicly, the content of your post or message, as well as the date and time of your post or message in the Global Market. App users can purchase or sell Digital Goods in the Global Market using Digital Currency.
Contests, Quests and Competitions: When you enter a contest or participate in a quest or a competition, we may collect your name, username, email address, mailing address, phone number, and any additional information or content required for the contest, quest or competition, or that you otherwise provide. We use this information to administer the contest, quest or competition. As part of a contest, quest, or competition, we may also share or otherwise publish the content you submit.
Hempire Shop: When you purchase a product from the Hempire Shop through the Website, we collect certain personal information including your name, email address, phone number, and billing and shipping address. We use this information to process and deliver your order. You may purchase our products without creating an account. If you create an account for the Hempire Shop to take advantage of a faster checkout process, we collect your name, email address, billing and shipping address, and a password that you select.
Contact Us: When you contact us with a comment, question, or complaint, including when you contact us through the in-App forum described below, you may be asked for information that identifies you such as your name, username, email address, and additional information we may need to help us promptly answer your question or to respond to your request, comment, or complaint. We may retain this information to assist you in the future and to improve our customer service. We also use personal information to establish and manage our relationship with you and to provide quality service.
Email and Push Notifications: You can sign up on the Website to receive our newsletter and other emails about promotions and information about LBC products and services. We collect your name and email address for the purposes of sending you these communications. You can opt out of receiving these emails from LBC at any time by following the unsubscribe instructions included in our emails, or by contacting us at the contact information set out below. Please note that you may continue to receive certain transactional and account-related emails from us.
If you access the App, we may also send push notifications to your mobile device to provide you with game updates, offers, and other game-related information, with your consent. You can manage these notifications in the “Settings” of your mobile device.
When you submit a post, send a message, comment, or leave a reply in the Hempire Community, you provide your username and any additional comments or content you wish to provide or upload to the Hempire Community. This information is publicly accessible to other users of the App. With your consent, we may collect and use the content you provide or upload, including your username, to feature you as a user of the App, and highlight your ingame performance. For example, we may collect statistics, scores, or similar accomplishments on a “leader board” or other similar posting comparing your performance to that of other users of the App. From time to time, we may also offer you the opportunity to participate in a survey or ask you for your feedback in the Hempire Community. The information obtained through our surveys and user feedback is used in an aggregated, non-personally identifiable form. We use this information to help us understand our users, and to enhance the game, including to assist us in creating new features or functionalities in the game, or new contests or competitions. To the extent that you participate in the Hempire Community, you are solely responsible for the content you provide or upload, and its accuracy at all times, as well as for any information or content you choose to disclose to other users through the Hempire Community. To edit, change, or delete any content posted on your profile, you must follow the instructions provided in the Hempire Community. To create a respectful environment, we posted a few rules which we ask that you follow if you participate in the Hempire Community.
SHARING OF PERSONAL INFORMATION
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. For example, we may use service providers for certain functions such as hosting of the Website and the App. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes. We also use third party service providers to collect certain analytical information, such as the App features used and time spent on the App, to help us improve the quality of our Services, serve advertisements, and manage and analyze data about our users and our advertising effectiveness. These data are collected by our third-party service providers in an aggregate form that does not personally identify any individual App user.
Legal and Compliance: We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing, or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S., or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of LBC or the Hempire brand, or as part of a corporate reorganization, stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
SAFEGUARDING AND RETENTION OF PERSONAL INFORMATION
We have implemented administrative, technical, and physical measures designed to safeguard personal information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. We restrict access to information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
We have information retention processes designed to retain information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
COOKIES, ADS, AND ADDITIONAL INFORMATION ABOUT THE WEBSITE AND THE APP
Using the App and Visiting the Website: In general, you can visit our Website and use the App without telling us who you are or submitting any personal information. However, when you use the App, we collect information regarding your device type, operating system and version, carrier provider, unique device identifier, and the date and time that the App accesses our servers. We may also collect information through technologies to prevent and detect cheating such as monitoring user activity, and users’ auto-refreshing and auto-reloading methods, including any browser-plug-ins. When you visit our Website, we collect your IP (Internet protocol) addresses, internet service provider, and other related information such as page requests, browser type, operating system and average time spent on our Website. We also collect the website or advertisement that was linked to or from the Website or the App when you accessed our Services.
We use this information to help us understand the activity on our Services, to monitor and improve our Services, and to tailor your in-game experience.
Cookies, Tracer Tags, and Beacons: We and our third-party providers, including Google Analytics, collect, process, store, and analyze information obtained from your browser or mobile device through the use of “cookies” or other tools such as “tracer tags” and “web beacons”.
A cookie is a tiny element of data that the Website or App can send to your browser, which may then be stored on your computer or mobile device so that we can recognize you when you return. “Tracer tags” and “web beacons” allow us to understand your activity when you visit the Website or use the App.
For more information on cookies and how they can be managed and deleted please visit http://www.allaboutcookies.org/ or http://www.networkadvertising.org/choices/.
We use the following cookies and other tools on the Website or the App, as applicable:
Strictly necessary cookies: these are essential in order to enable you to use the Website and its features as well as maintaining site security. Without these cookies, you would not be able to access the Services securely or at all.
Functionality cookies: these cookies are necessary for the Website to operate and allow us to remember what choices you make and provide enhanced, more personal features. The information these cookies collect do not track your browsing activity on other websites.
Analytical cookies: These cookies allow us to recognize and count the number of visitors and to see how visitors move around the Website. For example, they allow us to understand which pages are visited most often, and if they get error messages from web pages. All information collected by these cookies is aggregated. These tools help us track, measure, and analyze the behaviours and usage patterns of visitors to the Website and users of the App. We use this information to help us understand how visitors engage with the Website and the App, and to improve and tailor our visitors’ and users’ experience.
Advertising cookies: these cookies are used to send you advertising and marketing-related material tailored to you and your interest, including where you log into the Website via a Sign-in Partner such as Facebook. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.
If you have connected a Sign-in Partner account to the Website and/or App, cookies may let us know who you are and provide us and our service providers with information that we will use to personalize your experience (for example by loading your Facebook profile image and name to the display in the game).
You may set your Web browser to notify you when you receive a cookie or not to accept certain cookies. However, if you decide not to accept cookies from the Website or App, you may not be able to take advantage of all of the features of our Services.
You can opt-out from being tracked by Google Analytics in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout. For more information about Google analytics, see www.google.com/policies/privacy/partners/.
We may also use services provided by third-party platforms (such as Facebook, Instagram, and other sites) to serve tailored ads about our products and services on such platforms to you or others. We may provide a hashed version of your email address, device ID, or other information to the platform provider for such purposes.
To opt-out of the use of your information for this type of advertising, contact us, using the details below or adjust your advertising settings on such third-party platforms.
Subject to applicable law, you may have certain rights with respect to our processing of your personal information. You may have the right to request access to the information we hold about you, obtain confirmation as to whether or not information concerning you exists, be informed of the content and source of such information, and check its accuracy. You may also have the right to correct, update, delete, block, cancel, or object to the use of your information held by us. If you are located within the EEA, you are afforded specific rights in respect of the personal information we hold about you. These are set out under a separate section below.
If you change your mind and no longer wish to receive marketing e-mails from us, or if you wish to stop seeing tailored ads and other electronic messages on social media, you can request that we cease sending such e-mails or serving such ads.
You may exercise your rights or the choices described above by contacting us at the contact information set out below, or by clicking the unsubscribe link displayed in any of our marketing e-mails. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
If you wish to stop receiving push notifications from us to your mobile device, you can turn off push notifications for the App in the settings of your mobile device.
CALIFORNIA PRIVACY RIGHTS
California law permits customers in California to request certain details about how their “personal information” (as defined by California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. Under the law, a business must either provide this information upon request or permit California customers to opt in to, or opt out of, this type of sharing. California customers may request information about our compliance with this law by contacting us at [firstname.lastname@example.org] or by postal mail at PO Box 921 Fort Langley BC V1M 2S3 Canada. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each
EEA PRIVACY RIGHTS
If you are located in the EEA, you have a number of rights in relation to how we process your personal information. These include:
the right access the personal information that we may hold about you;
the right to rectify any inaccurate personal information that we may hold about you;
the right to have your personal information erased in certain circumstances, for example, where it is no longer necessary for us to process your personal information to fulfil our processing purposes; or where you have exercised your right to object to the processing;
the right to restrict the processing of your personal information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
the right to object to the processing of your personal information which may be exercised in certain circumstances, for example, where we are processing your personal information for direct marketing purposes, or where your own legitimate interests outweigh ours; and
the right to have your data ported to a new service provider if you no longer wish to use the Services.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
Should you have cause to complain about how we handle your personal information, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the national data protection authority in the country in which you are located.
Please contact us if:
you wish to update information we have about you or your preferences; or if you would like to exercise your rights of access, rectification, blocking, or deletion or to object to the processing of your information;
you are a parent or guardian and wish to review information collected from your child or have that information deleted.
You may contact us by email at email@example.com or write to us at:
PO Box 921 Fort Langley BC V1M 2S3 Canada.