Finite Reflection Studios LLC – Privacy Policy

Effective as of July 7, 2019

To provide our players with the best experience possible, we need information about you. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect,  and how we use it and what choices you have when you play any of our games.

Please note that in addition to the general information below, specific information about how certain of our Services use your information is provided at the end of this Privacy Policy in the "Game Specific Disclosures".

You should also read our Terms of Service which outlines the contract between you and Finite Reflection Studios LLC.

1. Who decides how your information is used?

Finite Reflection Studios LLC. is the data controller responsible for making decisions about how we use your personal information.

If you have any questions or comments on this policy, you can:

Email us at support@finitereflection.com

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

We need to collect and use certain Personal Data to provide certain services such as global leaderboards, platform integration such as Steam, Kartridge, Itch.io, Discord, Xbox One, PS4, Nintendo Switch, or any other platform games are distributed (“Platforms”), and PlayFab integration (“Services”) to you:

When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you open one of our games on verified Platforms. We collect and use that information in order to authenticate you and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. That information includes the in-game username you choose to use on our Services, and internal account IDs that we assign to your account.

You must have an account with a supported Platform to use our Services. As such, the Personal Data we collect also depends on which third party accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Finite Reflection Studios LLC Services.

Some third-party providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.

We collect and use your in-game actions and achievements, as well as certain information about your device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device) and Platform, to operate the Services for you and to ensure that we provide a fair gaming experience to all players in accordance with our Terms of Service (which includes anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of Service).

We further use the information above in order to provide technical and customer support to you.

You also give us Personal Data when you make a purchase through us, subscribe to our publications, register for a live event, enter a competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, date of birth (as needed to verify eligibility), and email address. We use that information to fulfill those Services to you and to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device and advertising identifiers, as well as actions you take during gameplay, your in-game user settings and preferences and your in-app purchases to understand who is using our Services and how.

Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.

Using your internal account ID in order to attribute to your account any user content that you elect to submit to Finite Reflection Studios through the Services.

To offer new or additional features for our Services.

To run leaderboards within our games. Note that when you participate in these leaderboards your in-game actions and achievements, in-game username, and other components of your in-game profile will be visible to the public (for example on leaderboards displayed online).

To carry out anti-fraud and anti-cheating measures and to ensure that you and other users are complying with our Terms of Service.

To make legal or regulatory disclosures.

3. Who we share information with

We will not share any Personal Data that we have collected from or regarding you except as described below:

Some third party service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third Party Service in accordance with their own privacy policy. Such third party service provider does not share your financial information, like credit card number, with Finite Reflection Studios LLC, but it may share limited information with us related to your purchase, like your zip or postal code. An example of one third party service found in many of our games is PlayFab. We use PlayFab as a backend to log you in and provide services for you so that you may have the best experience possible and access certain tools we use to make our game run, such as leaderboards. You may read about PlayFab’s Privacy Policy to learn more about what they collect.

Information Shared with Other Players. When you use the Services, and in particular when you play our games, we will share certain Personal Data with other players. This Personal Data includes your in-game profile (such as your username) and your in-game actions and achievements.For more details please read the Game-Specific Disclosures at the end of this Privacy Policy.

Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

4. How your Personal Data is transferred

Finite Reflection Studios LLC operates its Services across the globe. Where we engage with service providers in the USA, they are part of the EU-US Privacy Shield, which requires them to provide the same protection of your Personal Data as it has in the EEA.

5. How we keep your Personal Data safe

We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. How long we will keep your Personal Data

We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.

7. Your rights and choices

You have certain rights in relation to your Personal Data. In order to exercise these rights, please contact us at support@finitereflection.com

You can:

Request access to the Personal Data we hold on you.

Delete your Personal Data. 

Object to us processing your Personal Data. Some of the Personal Data we hold is necessary for us to provide the Services to you and fulfill the promises we make to you in the Terms of Service.

Ask us to stop using your Personal Data (but be aware that sometimes we need to use your Personal Data in order for you to use the Services).

Have your Personal Data transferred to another organization (where it is technically feasible).

Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd prefer you to contact us first

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

We aim to provide the information or complete the outcome you request within 30 days.

8. Children

Unless stated otherwise for a particular Service , children are not allowed to use the Services, and we do not collect Personal Data from them. We define "children" as follows:

Anyone under 13 years old

If we learn that we have collected Personal Data of a child, and we do not have parental consent, we will take steps to delete such information from our files as soon as possible.

9. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.

10. Third Parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a "Third Party Service"). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.

11. Game Specific Disclosures

Additional Privacy Information for Containment

Information shared publicly. When you play Containment, as part of the gameplay the following information about you will be shared through the game when a score is uploaded for a level to PlayFab, and will therefore become publicly available: your in-game username.

Additional Privacy Information for TwinCop

Information shared publicly. When you play TwinCop, as part of the gameplay the following information about you will be shared through the game when a score is uploaded for an arcade level to PlayFab, and will therefore become publicly available: your in-game username.