PRIVACY POLICY

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- Crows Crows Crows Privacy Policy Last updated: July 14, 2022 -

This Privacy Policy explains to you how your personal data is collected and what happens to it regarding the Crows Crows Crows Services.

You must be at least 13 to play our games (this includes our experiments).

Legally, we cannot and will not knowingly collect personal data about children below 13 without parental/guardian involvement.

If you do not understand this page, please ask your parent or guardian to explain it to you.

We collect information about you in different ways, for example, when you play a game or use this website.

When you register to play our games we’ll ask you for information about you.

We will need to use information we have about you to allow you to play our games or use this website. This means we might need to share your information with people and companies who help us run our games and our website, and who might be based around the world. People around the world might also see the username you use when you play a game.

You (or your parent or guardian) can tell us if information we store about you is wrong or if you think we should delete some of your information or stop using it in a certain way. You can also ask to see your information at any time and can see your profile information via your account.

If you are worried about how we handle your information, you or your parent (or guardian) can also email us at hello@crowscrowscrows.com and speak to your national data protection authority.

Because we know legal wording is not much fun, we have included a short and informal summary of each section. If you have any queries you can contact us at hello@crowscrowscrows.com.

WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS

This Privacy Policy explains the different kinds of information Crows Crows Crows can collect from you when you're using the Crows Crows Crows Services. We recommend that you use display names that do not identify you.

About Us. We are Roberts & Co Bunsen Outlet Limited (incorporated and registered in the United Kingdom with company number 08787812) of Preston Park House, South Road, Brighton, East Sussex, United Kingdom, BN1 6SB (“Crows Crows Crows”).

We are a controller in connection with personal data we hold about you. This means that we are responsible for the security of the personal data and the decisions we make regarding the personal data.

Which services does this Privacy Policy cover? This Privacy Policy provides information about how we handle the personal data we collect to via the following:

  • our video games, including The Stanley Parable: Ultra Deluxe and Accounting+
  • our free games and experiments (when we refer to games in this policy, we are referring to games and experiments)
  • our websites
  • our official forums, blogs, social media accounts and other products and services such as our newsletters
  • other ways in which we interact with you/have access to your personal data

- “Crows Crows Crows Services” for short.

What information does this Privacy Policy apply to? Specifically, this Privacy Policy governs personal data (or, in the USA, personally identifiable information), which we collect from you when you are using the Crows Crows Crows Services ("personal data" means information which, on its own or in combination with other information, can be used to identify you).

What about children? We recognise we have a special obligation to protect personal data obtained from children. Legally you must be at least 13 years old to use the Crows Crows Crows Services (but this might be older depending on whether or not a particular Crows Crows Crows Service has a required minimum age rating) as per our User Agreement. We do not knowingly collect personal data from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal data about your child, please contact hello@crowscrowscrows.com.

WHAT INFORMATION IS COVERED?

We may collect certain information when you use the Crows Crows Crows Services such as your name and email address (more information below). We do not receive or store your payment details.

What information might we collect from you? When you sign up for, download, use or play the Crows Crows Crows Services then we will collect certain information from you. The personal data that we collect varies depending on the particular Crows Crows Crows Services used, but this may include:

  • Technical Details. When you use, play or access the Crows Crows Crows Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any console device identifier; your operating system, browser type or other software; and your hardware or other technical details.
  • Your Activities. When you use, play or access the Crows Crows Crows Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences; achievements; gameplay statistics; time spent playing; choices you make about any characters you use, progress you make in our games and your geographical location data. We may attach a unique reference ID to you as a player. This unique reference ID will be different to your console or platform ID.
  • Your Communications. If you contact us (e.g. via email or direct message) or post in chat sessions, forums or other areas of the Crows Crows Crows Services, we may collect and maintain a record of your contact details and the content of your communications. We will not ask you to provide us with any special category (sensitive) personal data. Any such personal data we receive about you will be data you have shared with us or data someone else has provided to us about you.
  • User Accounts. To access certain Crows Crows Crows Services (e.g. games or chat server) you may need to create a user account. When you log in to play our games we collect basic log in information such as your account username and, where relevant, your username for your accounts with the consoles or platforms you are playing our games on (for example, your Steam ID and username or information related to your account with Xbox, PlayStation or Nintendo Switch such as your username or console ID). If you make purchases, we might receive some payment confirmation information about you from payment service providers, but we will not receive payment details.
  • Newsletters. If you sign up to a newsletter, you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable Crows Crows Crows Services (e.g. when you sign up for a newsletter) and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.
  • Advertising. We may receive personal data about you as part of our marketing and advertising efforts.

Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.

How do we collect personal data?

We collect personal data directly from you. You will provide us with your personal data when you use the Crows Crows Crows Services.

You can play our games on various platforms such as via Steam, on Xbox, PlayStation, Nintendo Switch, Oculus and Vive. When you play our games on these platforms we will receive your personal data from these platforms and the companies that run these platforms.

You will provide us with your personal data when you register for an account and when you use your account to play any of our games.

We may also receive personal data about you as part of our advertising campaigns, for example, via social media platforms such as Facebook and any services we receive to understand and improve our advertising campaigns.

We may also receive your personal data through social media and other online platforms such as Twitter, YouTube and Discord when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, and when you otherwise provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Twitter.

We may also collect your personal data through any platforms you use to contact us, for example, when you communicate with us via a Steam or Discord forum. We may also collect your personal data from other individuals who may, for example, mention you in any communications they send to us.

We may also receive personal data about you from Crows Crows Crows GmbH which is our wholly owned German based subsidiary.

We may also receive personal data about you from any other types of organisations listed in the section titled ‘Will we ever share any of your personal data with other parties?’ below.

What about the storage of payment details? The processing and storage of payment details is a matter for the relevant platform and the applicable payment methods/payment service providers. Crows Crows Crows will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g. Steam, Apple’s App Store or Google Play) via the user account you have associated with that platform account. If you make in-game purchases within a Crows Crows Crows game or product, we are notified by the payment service provider once a transaction takes place but we will not receive any of your actual payment details.

HOW IS YOUR PERSONAL DATA USED?

We will use your personal data to run, maintain and improve the Crows Crows Crows Services as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may share information with partners in order to run our services.

How might your information be used? In accordance with data protection laws, we will only process your personal data if we have a lawful basis for doing so.

In respect of your personal data, these bases are:

  • if it is necessary to provide services to you under the performance of a contract we have with you
  • if we are required to do so in accordance with legal obligations
  • if you have given your consent
  • if it is in our legitimate interests to process your personal data, provided that none of these
    • prejudice your own rights, freedoms and interests.

The following is a list of the purposes for which we process your personal data, and the lawful bases on which we carry out such processing.

Perform our agreement with you:

  • provide the Crows Crows Crows Services to you:
    • to carry out our obligations arising from any contracts between you and us
    • to facilitate logging in and playing our games
    • to allow you to participate in interactive features of the Crows Crows Crows Services when you choose to do so
    • receiving and responding to correspondence
    • for account verification purposes
    • to display in-game profiles or display names and leader boards
    • to make event/content related information available to you and to make information about changes to the Crows Crows Crows Services available to you.

For our legitimate interests:

  • advertising:
    • to engage with players and potential players including providing advertising on third-party websites and platforms (legitimate interests of promoting our offerings, including commercial interests in expanding our business)
    • to understand when players have interacted with advertising and been directed to the Crows Crows Services, especially our websites (legitimate interests of understanding the success of advertising campaigns)
    • to carry out surveys (when these surveys do not contain any direct marketing or when we have obtained soft opt-in) (legitimate interests of improving the Crows Crows Crows Services)
    • to analyse statistics that provide us with an understanding of the level of success of our marketing campaigns (legitimate interests of better understanding our marketing campaigns).
  • administering and monitoring the performance of the Crows Crows Crows Services:
    • to prepare and analyse statistics relating to the use of games by you and other users, testing, to investigate complaints, to seek and analyse feedback and to further develop the game (legitimate interests of ensuring our games are as enjoyable as possible)
    • to ensure that the Crows Crows Crows Services are presented in the most effective manner for you and your device(s)(legitimate interests of ensuring Crows Crows Crows Services are as enjoyable as possible)
    • disclosure of gameplay results to third-party services to consolidate and publish (legitimate interests in assisting the administration of our games)
    • to administer, maintain, protect and improve the Crows Crows Crows Services and to protect Crows Crows Crows and Crows Crows Crows Services users, including carrying out activities involving development, analytics, traffic patterns, addressing hacking, cheating and other harmful activities (legitimate interests of running our business, provision of administration and IT services, including network security).
  • to run our everyday operations: to allow communications between members of staff and the transfer of personal data between members of our corporate group in connection with the provision of the Crows Crows Crows Services and to engage with third party suppliers and business contacts (legitimate interests of running our business
  • receiving and responding to correspondence (legitimate interests of ensuring a good user experience (when outside the performance of a contract with you).
  • to administer a corporate change: to administer a sale or possible sale of the whole of or part of our business or the restructuring of our business (legitimate interests of facilitating any such possible or actual transaction or restructuring).
  • Comply with our legal obligations: where we are required to do so by law, for example, to comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
  • Based on consent: provide you with marketing information about products or services that you request from us or which we feel may interest you where you have asked us to do so or have opted-in for.

We may also process your personal data for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.

In certain circumstances, you may be obliged to provide us with your personal data under a statutory or contractual requirement. This might include, but is not limited to, personal data we require to enter into an agreement with you; for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation. Failure to provide us with personal data required under a statutory or contractual requirement may prevent us from entering into or performing our obligations under a contract with you.

Will we ever share any of your personal data with other parties?

We will never share your information with third parties for their own marketing purposes without first obtaining your consent.

We may share your personal data with other parties. We describe the circumstances in which we share your personal data with other parties below:

  • third party service providers in the course of providing the Crows Crows Crows Services to you and operating our business, for example, organisations that provide us with technology related services such as data storage, server hosting, customer and technical support as well as game analytics, advertising, etc. which may require them to access your information on our behalf. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers, etc.) and activities carried out for their own purposes will be covered by their own privacy policies
  • third party service providers providing us with marketing campaign related services (e.g. ad network and measurement services) to display advertising on the Crows Crows Crows Services and to manage our ads on third party sites and social media platforms. You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device and you may be able to opt-out from the collection of information by some of our advertising partners
  • platforms or consoles you play our games on such as Steam, Xbox, Oculus, Vive, PlayStation and Nintendo Switch
  • we may share your personal data within the Crows Crows Crows company group for the purpose of providing the Crows Crows Crows Services
  • organisations we have a professional relationship, where you have provided your consent for us to share your data with them for marketing purposes
  • social media and other online platforms such as Twitter, Discord and YouTube which we use to communicate with you or to share photos and text that you share via your profiles on these sites, for example, when we reshare a post that you are mentioned in via our profile on a social media site
  • external professional advisors who need to access such information for the purpose of advising us
  • law enforcement bodies which may have any reasonable requirement to access your personal data, for example, in order to assist with any investigations, when we bring a claim or defend ourselves against a claim that requires the disclosure of personal data
  • potential purchasers of our business or investors in it (including in the event of insolvency).

International transfers: Some of the parties we share your personal data with might be based abroad. When your data is transferred internationally, we are required to ensure you are afforded equivalent protection in respect of your personal data to that provided in the UK and the EU.

Generally, we will put in place appropriate safeguards when making international transfers, for example, by using specific contractual clauses which have been approved by the European Commission and/or the UK government together with supplementary measures if we deem it necessary in the circumstances, for example, further contractual commitments, enhanced security and assessments of transfer risk.

INFORMATION YOU MAKE PUBLICLY AVAILABLE

Please remember that any communications you have via the Crows Crows Crows Services may reveal details about you. Also, any information you post publicly will be publicly available to other people.

We have no control over your use of any otherwise private personal data which you make available, or the activities of other users or other third parties to whom you give or make available your information or content.

PLEASE DO NOT SHARE ANY SENSITIVE INFORMATION (FOR EXAMPLE, INFORMATION ABOUT MEDICAL CONDITIONS) ON ONLINE FORUMS OR OTHERWISE MAKE IT AVAILABLE TO US OR OTHER PARTIES VIA ANY POSTS OR COMMUNICATIONS.

The Crows Crows Crows Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.

DATA RETENTION

We retain your information for as long as needed to provide the Crows Crows Crows Services to you or longer where permitted by law.

How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected.

We will retain your personal data only for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any contractual requirements or other legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the purposes for which we process the personal data, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.

As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all Crows Crows Crows Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.

YOUR RIGHTS

You have rights about how your personal data is used, which can vary depending on where you live. If you have any questions, please contact us at hello@crowscrowscrows.com.

Can you ask us to stop processing your personal data? You have the right to ask us not to process your personal data for marketing purposes. You can change your email settings to unsubscribe from email communications.

What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU and the UK you have the following rights. If you have any questions about your rights, or you wish to exercise any of these rights, please email hello@crowscrowscrows.com.

We may require you to provide forms of identity should you wish to exercise one of your rights below.

Access: to access and obtain a copy of your personal data we possess.

Rectification: if the personal data we hold about you is incorrect, you have the legal right to ask us to rectify/correct your personal data.

Erasure: you may have the legal right to contact us to request that we delete your personal data from our system if there is no compelling reason to continue processing.

Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below).

Objection: You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.

You may object to receiving direct marketing at any time.

Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.

Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email hello@crowscrowscrows.com to withdraw consent for the processing of your personal data.

Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the Information Commissioner’s Office. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.

Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data

We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain Crows Crows Crows Services may no longer function properly or be completely unavailable to you.

Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal data we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Roberts & Co Bunsen Outlet Limited at Preston Park House, South Road, Brighton, East Sussex, United Kingdom, BN1 6SB. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.

Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact: hello@crowscrowscrows.com.

OTHER

We can change this Privacy Policy, but if we do we will put the changed version online. Please feel free to contact us if you have any questions with regards to the changes at hello@crowscrowscrows.com.

Will we ever change this Privacy Policy? Possibly, but if we do we will make the changed Privacy Policy available online. You are welcome to contact us if you have specific questions about the changes at hello@crowscrowscrows.com. If you do not agree to those changes, regardless of whether you email us then unfortunately you must cease using all Crows Crows Crows Services.

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