September 9, 2022
As an Alberta registered corporation, Swordmonkey Studios Inc. is bound by the Personal Information Protection Act (PIPA); which is substantially similar to the federal Personal Information Protection and Electronic Documents Act (PIPEDA). Personal data is protected under these acts and is considered a human right under Canadian law; and offers a level of protection in alignment with the European Union’s GDPR.
Swordmonkey Studios operates websites, video games, mobile applications and other products (collectively hereby referred to as “Games”, “Service” or “Services”) and may collect information that can be linked to you as an individual.
This document informs you of our policies regarding the collection, use and disclosure of personal data when you use our Services and the rights you have with regards to that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Information Collection and Use
Swordmonkey Studios can be both a data processor and a data controller.
Swordmonkey Studios is a data controller when you interact with any software published directly by Swordmonkey Studios.
Swordmonkey Studios may be a data processor when you interact with any software that is published by a Swordmonkey Studios client or partner company.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”).
Swordmonkey Studios maintains a Newsletter service (“SMS Mercury”) that is used by Swordmonkey Studios and other partnered companies. Each Newsletter Mailing List is properly scoped to the organization responsible for that list and is not shared. If you want a newsletter with relevant information, your name and email address are stored in our SMS Mercury database. This information is stored after the consent of the individual user, in accordance with Article 6 of the GDPR. The newsletter is sent as long as you agree to it. You can unsubscribe by letting us know, or you may withdraw your consent by using the Unsubscribe button at the bottom of the newsletter.
We may process your personal data to analyze user statistics. We do this to determine how many users are actively using our Services and to optimize functionality and user experience. Data is collected and analyzed on the number of visitors in different time periods, total page views, rejection frequencies, duration of the visit, country of origin, referring sources, visitor device types, etc. This data is anonymized. This collection is based on our legitimate interest in understanding how our Services are used.
We may process your personal data to analyze operational statistics in the service. We do this so that Swordmonkey Studios services will be stable in operation. For example, if there is a lot of activity, we need to know when to increase the capacity of our servers. Data is collected and analyzed on current use, the number of users and on users grouped by place of residence, age, etc. This data is anonymized. This data is collected based on our legitimate interest in understanding how the Service is used and in order to be able to improve it
We may have an established presence on social media, such as LinkedIn, Facebook, Instagram, YouTube or Twitter. We only have access to the information that individuals themselves register as public on social media. Communicating with us on social media is voluntary. This collection happens after a justified interest in communicating with our users.
Your name, contact information, organization and content of your messages will be stored in our email for up to 1-year as a result of you contacting us for assistance.
Use of Data
Swordmonkey Studios uses the collected personal data for the following purposes:
- To provide and maintain our Services
- To notify you about changes to our Services
- To allow you to participate in interactive features of our services
- To provide customer support
- To improve our services
- To monitor the usage of our services
- To detect and address technical issues within our Services.
Retention of Data
Disclosure of Data
In certain circumstances, Swordmonkey Studios may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities.
Swordmonkey Studios may disclose your personal data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- To protect and defend the rights of Swordmonkey Studios Inc and affiliates
- To prevent or investigate possible wrongdoing in connection with the service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Information Security at Swordmonkey Studios
Swordmonkey Studios believes that you should have full control over your Personal Data. We work systemically to ensure that our Services are in accordance with PIPA/PIPEDA at all times. Swordmonkey Studios has introduced the following organizational and technical information security measures:
Data is stored on cloud-based servers with the Canadian company WolfPaw Data Centres Inc. The data is stored at data centers located in Edmonton, Alberta. WolfPaw Data Centres Inc. is SOC2 Type 2 Certified.
Access management is role-based and the principle of least privilege is used when defining access rights. User access is reviewed regularly. All staff and authorized contractors use multi-factor authentication (“MFA”) and follow password routines according to Swordmonkey Studios Acceptable Use Policies.
A background check is carried out on all relevant candidates before they start working at Swordmonkey Studios. New employees will be informed about, and must sign, Swordmonkey Studios Acceptable User Policy.
All devices in the infrastructure are updated regularly. Servers controlled by Swordmonkey Studios are continuously monitored and error rates are tracked and logged.
Stored data is regularly backed up. The backup copies are encrypted and are only accessible via secure private networks. Databases containing personal data are only accessible through secure private networks. All data transfer takes place with TLSv1.2.
Swordmonkey Studios has separated its test, production and development environments. Only dummy data is used for testing. To ensure code quality and that policies for secure development are followed, automated tests are carried out in addition to code reviews.
All access to Swordmonkey Studios servers, from both employees, authorized contractors or professional businesses is logged and monitored. Multi-factor authentication and “as-needed” access have been established. Employees only receive access when necessary and strictly scoped to their immediate need.
A cookie is a small piece of data that a website - when visited by a user - asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Cookies sent by Swordmonkey Studios are called first-party cookies.
Example of cookies we use:
- Session Cookies. We use session cookies to operate our services.
- Preference Cookies. We use preference cookies to remember your preferences and various settings for future visits.
- Security Cookies. We use security cookies to ensure the safety of our services and your personal information
You can exercise your rights by contacting us through the contact details set out below. We will respond to your inquiry within 30-days. We will ask you to confirm your identity or to provide additional information so we can process your request. We do this to ensure that we only give access to your personal data to you and not to someone pretending to be you.
Access to Information
You have the right to access your personal data. You have the right to access, among other things:
- What personal data is registered about you
- Information about how or where the personal data was obtained
- What the personal data will be used for
- To whom the personal data is disclosed
- How long your personal data is stored
Correction of Personal Data
You can ask us to correct or supplement personal data that is incorrect or misleading for personal data we are responsible for processing. To correct or supplement personal data where we are the data processor, you must contact the person responsible for processing.
Deletion of Personal Data
In certain situations, you can ask us to delete personal data about you. For deletion of personal data where we are the data processor, you must contact the person responsible. If there is a legal basis for further processing, we may be unable to delete certain personal data.
Limitation of processing of personal data
In certain situations, you can ask us to limit the processing of your personal data. This applies if:
- You believe that the personal data is incorrect
- You object to the processing of the data
If you want limited processing of your personal data related to the services where we are data processors, you must contact the company that controls your personal data.
Protest against the processing of personal data
If we process personal data about you on the basis of our services or with a legitimate interest, you have the right to object to our processing of personal data. To object to the processing of personal data where we are the data processor, you must contact the data controller.
For those services where we process personal data about you based on consent, you can ask us to transfer your personal data to you or to another supplier. For data portability where we are the data processor, you must contact the data controller.
Links to Third-Party Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party website, application or service.
If you have questions about the processing of your personal data, or have general questions about our privacy and security policies, you will find our contact information below.
Swordmonkey Studios Inc.
435 Dunluce Road NW
Edmonton, Alberta, Canada T5X 4Y5
Email: [email protected]