PRIVACY POLICY
Effective Date: 2024.02.29
Greensky Games, Inc. Privacy Policy
Greensky Games, Inc. (“Greensky,” “we,” “us,” and “our”) provides virtual reality (“VR”) gaming experiences on the Meta Quest, Steam, and other platforms through games such as SWARM. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights. Greensky is the data controller for the personal information we process. For information on how to contact us, please refer to Section XIV below.
SCOPE
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR INFORMATION
WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION
HOW WE SHARE YOUR INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
SECURITY OF YOUR INFORMATION
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
OTHER PROVISIONS
CONTACT US
PRIVACY NOTICE FOR KOREAN RESIDENTS
I. SCOPE
This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, games, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, games, and other offerings are collectively called “Services”.
II. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us on our websites and through our mobile applications and games, information we obtain automatically when you use our Services, and information from other sources such as third-party services, organizations and platforms, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
Account Creation. We may collect information from Meta Quest, Steam or other platforms when you create an account to play our games via such platforms, such as your profile picture, display name, Game Platform User ID, or other information that you have made available via your privacy settings on such platforms.
Beta User Information. If you sign up to join a Beta on our Services, we will collect your email address, first name, age, gender, type/model of VR headset, platform type, platform username and Discord username. We will also collect additional information you provide, including via surveys, such as hours playing the games, comfort and estimated motion sickness levels while playing the game and a net promoter score and we will add your email to our mailing list for beta testers. For more information about how to unsubscribe from our email list, please see Section III.C below.
Purchases. We may collect aggregate information from Meta Quest or Steam (e.g., what has been purchased and refund metrics). Any payments made for our Services are processed through Meta Quest or Steam. We do not collect or store any payment card information for purchases on our Services.
Your Communications with Us. We may collect personal information, such as your name and email address, when you complete the “Contact Us” form on our main website or register for our mailing list, User IDs and headset used, details of your request and any attachments you provide when you request customer or technical support and other information you may provide when you apply for a job or otherwise communicate with us.
Content. We may collect content you create on our Services such as content you create and publish using the map editor tool. We may collect information about this content, such as the date and time you created it. We may also collect information related to how you interact with features that allow you to create content, such as how you interact with the map editor tool.
Interactive Features. We and others who use our Services may have access to personal information that you submit or make available through our interactive features (e.g., the games themselves, in-game voice communication, forums, blogs, and social media pages). Any information you provide on these features will be considered “public”, unless otherwise required by applicable law. Please exercise caution before revealing personal information to strangers via our Services. For more information about third party websites, please see Section XIII below.
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners and in such circumstances, we shall only do so in accordance with applicable law.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services. If you refuse to store cookies, you may experience difficulties in using customized services.
Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, cookie identifiers and platform identifiers, in game analytics, player event data, information on bugs and crashes, browser or device information, general location information (including approximate location derived from IP address), and hardware information such as your GPU (type and clock speed), CPU (type and clock speed), system memory, OS locale, and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may, in accordance with your cookie preferences, use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. For more information see our Cookies Policy. You can change your preferences here.
C. Information Collected from Other Sources
We may obtain information about you from other sources, including from other users and through third-party services and organizations. For example, if users choose to send us extracts of gameplay.
III. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to provide you with our Services, such as:
Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services, including game play
Answering requests for customer or technical support; and
Communicating with you about your account, activities on our Services, and policy changes.
B. Administrative Purposes
We use your information for various administrative purposes listed below where we have a legal basis to do so, such as:
Product research and development (including marketing research);
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies;
To create aggregated analytics information, such as information about the device from which you access our Services; and
Processing applications if you apply for a job we post on our Services.
C. Marketing and Advertising our Products and Services
Subject to your preferences and applicable law, we may use your personal information to tailor and provide you with content and advertisements.
We market to you in the following ways: via email campaigns, targeted on-line advertisements on social media and at trade shows and other events.
If you have any questions about our marketing practices or if you would like to withdraw consent of the use of your personal information for marketing purposes, you may contact us at any time as set forth in Section XIV below.
D. Other Purposes
We may also use your information for other purposes as requested by you or as permitted by applicable law as set out below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
To promote safety, integrity and security. We use the information we collect to verify accounts and activity, combat harmful conduct, detect and prevent bad experiences, maintain the integrity of our services, and promote safety and security.
Share Content with Friends. Our Services may offer various tools and functionalities which allow you to share certain content and invite friends to the Services. For example, our referral services may allow you to forward or share certain content with a friend, such as an invite code to invite your friend to use our Services.
Complying with our legal obligations. We may process personal information as needed to comply with our legal obligations, including if we have a good faith belief that the law requires us to do so or when we have a good-faith belief it is necessary as described in Section “V.B. To Protect Us or Others” below.
IV. WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION
Under the GDPR and some other data protection laws, we may rely on the following legal bases to process your personal information:
as necessary to fulfill our Terms of Service and provide the Services (contractual performance);
consistent with your consent, which you may revoke at any time;
as necessary to comply with our legal obligations;
occasionally to protect your vital interests or those of others;
as necessary in the public interest; and
as necessary for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
V. HOW WE SHARE YOUR INFORMATION
We share your information to third parties for the following business purposes: to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. To Provide our Services
The categories of third parties with whom we may share your information are described below.
Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, marketing and related services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in Section XIV below.
Public information. As stated above, other users who use our Services may have access to personal information that you submit or make available through our interactive features (e.g., usernames in the games themselves or features within the games such as the map editor tool). Any information you choose to make public may be visible to people on and off the Services.
B. To Protect Us or Others
We may access, preserve, and disclose information associated with you to external parties if doing so is required to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. In the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and contract.
VI. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are described below.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those necessary service-related communications without terminating your agreement with us and ceasing use of our Services.
We process requests to be removed from email marketing lists.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Your Privacy Rights. In accordance with applicable law, in certain circumstances you may have the right to:
Access personal information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
Request correction of your personal information where it is inaccurate, incomplete or outdated;
Request deletion or anonymization of your personal information;
Request restriction of our processing of your personal information;
Right to object to our processing of your personal information for direct marketing purposes or where we are processing data based on our legitimate interests;
Withdraw your consent to our processing of your personal information without affecting the lawfulness of processing based on consent before its withdrawal. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
Request data portability and receive an electronic copy of personal information that you have provided to us; and
Be informed about third parties with which your personal information has been shared.
Supervisory Authority. You may have the right to lodge a complaint with your local supervisory authority if you believe our processing of your personal information violates applicable law, including in the EU or UK. If you reside in the United Kingdom you may lodge a complaint with the UK Information Commissioner and if you are based in Ireland you may lodge a complaint with the Irish Data Protection Commissioner, or if you are based in Australia you may lodge a complaint with the Office of the Australian Information Commissioner. We would appreciate the chance to understand your concerns in the first instance before you contact your local supervisory authority, and in some cases, contacting us first will be required by the authority before they will consider the matter. We will deal with complaints within a reasonable time and will keep you informed of the progress of our investigations. Typically, we will reply to you in writing within 30 days.
If you would like to exercise any of these rights, please contact us as set forth in Section XIV below.
VII. SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.
VIII. INTERNATIONAL DATA TRANSFERS
As we are a United States company, it is necessary to transfer your personal information to the US and other third countries outside of the UK/EEA in order for us to provide the Services to you and such third countries may have data protection laws that are different and less protective from the laws where you live. Where we transfer UK/EEA personal data to third parties in third countries, we utilize Standard Contractual Clauses approved by the European Commission, and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for such transfers.
IX. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
X. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Greensky has collected about them and whether Greensky disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Greensky Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers.
An alias, online identifier, Internet Protocol address, or other similar identifiers.
Service providers
Game platforms
Dependent services used to operate the games
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name or other similar identifiers as listed above.
Service providers
Game platforms
Dependent services used to operate the games
Internet or other electronic network activity
Information on a consumer’s interaction with an internet website or application.
Service providers
Sensory data
Audio, electronic, visual, or similar information.
Service providers
Game platforms
Dependent services used to operate the games
Professional or employment-related information (job applicants only)
Current or past job history or performance evaluations.
Service providers
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above in “Personal Information We Collect” and “How We Use Your Information” above.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, Greensky does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
If you are a California resident, subject to certain exceptions and applicable law, you may have certain rights in relation to information we process about you
Right to Know. In relation to your right to access described above, you may request that we disclose to you the categories and specific pieces of personal information that we have collected about you in the preceding 12 months, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose in the preceding 12 months, the categories of third parties with whom we have shared your personal information, and the business or commercial purpose for each disclosure.
Right to Delete. In relation to your right to delete as described above, you may request that we delete any personal information that we have collected from you.
Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you would like to appoint an authorized agent to make a request on your behalf, you must provide the agent with written, signed permission to submit privacy right requests on your behalf, or provide a letter from your attorney. The agent or attorney must provide this authorization at the time of request. We may require you to verify your identity with us directly before we provide any requested information to your authorized agent.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, or Game Platform User ID. We will match this information against information we have previously collected about you to verify your identity and your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in Section XIV below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.
XI. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Section XIV below.
XII. OTHER PROVISIONS
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Changes to our Privacy Policy. If there are any material changes to this Privacy Policy, we will notify you and take any other steps as required by applicable law.
XIII. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Greensky Games, Inc.
340 S LEMON AVE NUM 4062, WALNUT, CA 91789
privacy@greenskygamesstudio.com
XIV. PRIVACY NOTICE FOR KOREAN RESIDENTS
A. Measures to Ensure the Security of Your Information
We make our best efforts to ensure the security of your information, by implementing managerial and technical measures, including:
We have established and implemented internal policies for our management of personal information, including appointment of executives responsible for privacy and training requirements for employees and contractors responsible for processing personal information.
We take measures to control and restrict access to personal information, including implementation of access controls and logging access to personal information.
We use other appropriate measures to help protect your information from loss, theft, misuse, and unauthorized access. These measures include computer safeguards, such as intrusion prevention and detection systems, anti-virus software and firewalls, as well as physical access controls to our buildings and files.
