PRIVACY POLICY

This Privacy Policy for Electronic Game Development Company, trading as Steer Studios (“Company”, “we”, “us” “our”) describes how we collect, use, hold and disclose information about users of the Company’s website (www.steerstudios.com), the related mobile applications and games (the “Games”), related services, tools and features (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. For the purposes of data protection laws, we are the data controller.

Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services or by sharing any of your information with us, you agree to the collection, use, storage, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access or download any of the Services.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy please do not access or continue to use the Services.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources.

Some features of the Services may require you to directly enter certain information about yourself. This information is processed in order to perform our contract with you (such as to provide you with our Services) or for our legitimate interests in order to be responsive to you, to provide effective services and to maintain our business relationship. You have the option of not identifying yourself or providing a pseudonym, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:

  • Basic contact details, such as your name and email. We collect basic contact details to communicate with you, provide you with products and services, and to market to you, etc..

  • Account information, such as your username, password, and security questions. We collect account information to maintain and secure your account with us. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.

  • Payment information, such as your credit or debit card information, and billing address. Our third party payment processor may collect payment information to process in-game payments, and to provide you with products or services you have requested. If you use one of our mobile Gaming, purchases are made via the relevant third party gaming platform (e.g. Apple App Store, Google Play Store). Please refer to the relevant gaming platform’s terms relating to your payment and the information processed by the third party.

  • Applicant details, such as information included in your resume or CV, references, and job history. We use applicant details to process your application for employment.

  • Any other information you choose to include in communications with us or other parties through the Services, for example, when sending a message through the chat or customer support features.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies and other tracking technologies (“Tracking Technologies”). Usage Data may include:

  • Unique device identifier
  • Device type, such as your phone, computer, or tablet
  • IP address
  • Browser type
  • Date and time stamps, such as the date and time you access the Services
  • Operating system
  • Location, language and settings
  • Log data and gameplay tracking
  • Advertising identifiers and the service or website you are vising from
  • Other information regarding your interaction with the Services, such as clickstream data and ad impressions

We use the information we collect automatically for our legitimate interests or with your consent, to recognize and count the users of our Services, tailor features and content to you, to market to you, to provide you with offers or promotions, to run analytics and better understand user interaction with the Services, and to improve our games and Services.

We may obtain information about you from outside sources. Such information may include:

  • Consumer marketing databases or other data enrichment companies, which is used for our legitimate interests to better customize advertising and marketing to you; and

  • Information from third parties that you choose to share with us, for example, when you choose to link any social media platforms to your account, such as Facebook or Twitter. This information is used to maintain your account and login information.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes. The Company will take reasonable steps to ensure that any information shared by the Company will be in accordance with this Privacy Policy and applicable laws. Such circumstances may include:

  • With vendors or other service providers, in our legitimate interests, such as:

    • Customer service providers, such as Helpshift
    • Payment processors
    • Data analytics vendors
    • Digital advertising partners, such as Facebook, Appsflyer, Firebase, Ajust, Amplitude and DevtoDev
    • Cloud storage providers
    • Email marketing services vendors

  • With our affiliates or otherwise within our corporate group, in our legitimate interests;

  • With third parties for marketing purposes, in our legitimate interests or where you provide consent;

  • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries;

  • In connection with an asset sale, merger, bankruptcy, or other business transaction, in our legitimate interests;

  • To enforce any applicable terms of service, to perform a contract with you;

  • To ensure the safety and security of the Company and/or its users, in our legitimate interests;

  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations, to perform a contract with you; and

  • With professional advisors, such as auditors, law firms, or accounting firms, in our legitimate interests.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

To opt out of tracking by Google Analytics, click here.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

5. RETENTION OF YOUR INFORMATION

We retain your information for as long as necessary to provide the Services to you. We will also retain and use your information for longer periods of time to the extent necessary based on our consideration of various criteria, including to comply with our legal obligations, resolve disputes, enforce our contractual agreements and our policies, prevent harm, promote safety, security and integrity, and to protect or defend the Services, our rights, the rights of our users, or others. If you stop using our Services, we will store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.

6. WHERE WE STORE YOUR INFORMATION

The information that we collect from you may be accessed from, transferred to, and stored and used in countries outside the country in which you are located, including in the United States and the Kingdom of Saudi Arabia, by us and by our third party service providers or partners.

Where legally required, transfers of personal data to other countries will take place to jurisdictions deemed to provide an adequate level of protection for personal data by the relevant regulator, or alternatively will take place on the basis of an appropriate safeguard or exception.

7. YOUR RIGHTS

Depending on where you are located, you may have certain rights in relation to your information, including the right to be informed whether information pertaining to you shall be processed, to access your information, to correct or delete your information, to port your information to another controller, to restrict or object to the processing of your information, and to withdraw your consent and to suspend or order the removal, blocking, or destruction of your information from our system. If you are a U.S. resident, see also the Jurisdiction Specific Terms, Your U.S. Privacy Rights. You may also have the right to make a complaint with your local data protection supervisory authority where you live or work, or where you think we have infringed data protection laws. Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, if fulfilling your request would adversely affect other individuals or if we are required by law to retain your information. To exercise any of these rights, you can contact us using the contact details below. We may ask you to provide suitable identification when you seek to make any of these requests, in order to verify your identity. You should allow us a reasonable time (for example 30 days) to respond to your complaint.

8. THIRD PARTY WEBSITES AND LINKS

We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

9. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

10. DATA SECURITY

Although we do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk.

11. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, or would like to make a complaint, please email us at customersupport@steerstudios.com.

APPENDIX A – JURISDICTION SPECIFIC SUPPLEMENTAL TERMS

These Jurisdiction-Specific Supplemental Terms (“Jurisdiction Specific Terms”) will apply and be deemed incorporated by reference into the Privacy Policy, but only if your use of the Services is within scope of the specific jurisdiction’s legal requirements outlined below. The Jurisdiction Specific Terms that are applicable to you (if any), will depend on the location from which you access the Services. The Jurisdiction Specific Terms applicable to you (if any) shall take precedence in the event of and solely to the extent of any conflict with the general Privacy Policy wording.

A. CALIFORNIA PRIVACY DISCLOSURES

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

Processing of Personal Information

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Category Categories of Recipients
Identifiers such as name, e-mail address, IP address With vendors or other service providers, such as customer service providers, payment processors, data analytics vendors, digital advertising partners, cloud storage provider, email marketing vendors, our affiliates and within our corporate group, third parties for marketing, and social media companies
Personal information categories listed in the California Customer Records statute such as name With our customer service providers when you reach out for customer service
Commercial information such as records of products purchased With vendors or other service providers, such as customer service providers, payment processors, data analytics vendors, digital advertising partners, cloud storage provider, email marketing vendors, our affiliates and within our corporate group, third parties for marketing, and social media companies
Internet or other similar network activity such as information regarding your interaction with the Services With vendors or other service providers, such as customer service providers, payment processors, data analytics vendors, digital advertising partners, cloud storage provider, email marketing vendors, our affiliates and within our corporate group, third parties for marketing, and social media companies
Imprecise geolocation data such as IP address With vendors or other service providers, such as customer service providers, payment processors, data analytics vendors, digital advertising partners, cloud storage provider, email marketing vendors, our affiliates and within our corporate group, third parties for marketing, and social media companies
Electronic information such as information you provide directly or through your interactions with our Service (device type, network data, internet service provider, operating system, date and time stamp of actions, log data and gameplay tracking), and interactions with our advertising and communication campaigns that are advertised on our third party business partner websites With vendors or other service providers, such as customer service providers, payment processors, data analytics vendors, digital advertising partners, cloud storage provider, email marketing vendors, our affiliates and within our corporate group, third parties for marketing, and social media companies
Professional or employment-related information such as title of profession, employer, professional background With vendors or other service providers, such as cloud storage provider and our affiliates and within our corporate group
Inferences drawn from other personal information such as profile reflecting your preferences With vendors or other service providers, such as customer service providers, payment processors, data analytics vendors, digital advertising partners, cloud storage provider, email marketing vendors, our affiliates and within our corporate group, third parties for marketing, and social media companies
Account access credentials* such as account log-in in combination with any required security or access code, password, or credentials allowing access to your account With vendors or other service providers, such as cloud storage provider and our affiliates and within our corporate group
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The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal information are described in the section above, Company’s Collection and Use of Information. We only use and disclose sensitive personal information for the purposes specified in the CCPA. The criteria we use to determine how long to retain your personal information is described in the section above, Retention of Your Information.

We disclosed personal information over the preceding 12 months for the following business or commercial purposes:

  • to communicate with you, provide you with our website, Games and Services, to market to you;
  • to maintain and secure your account with us;
  • to process your payment, to provide you with Games and Services you have requested;
  • to personalize your experience with our Games and Services, and to deliver content, offerings, or advertising relevant to your interests, including through targeted advertising, both on our Services and on third-party services;
  • to help maintain the safety, security, and integrity of our website, Games and Services, databases and other technology assets, and business;
  • for testing, research, analysis, and product development, including to develop and improve our website, Games, and Services; and
  • to evaluate your candidacy and process your application for employment.

Selling and/or Sharing of Personal Information

We do not “sell” (as such term is defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age. However, we do share certain categories of personal information and, in the preceding 12 months, we have shared the following categories of personal information about residents:

Category Sold and/or Shared? Categories of Recipients
Identifiers such as IP address Shared Digital advertising partners
Commercial information such as records of products purchased Shared Digital advertising partners
Internet or other similar network activity such as information regarding your interaction with the Services Shared Digital advertising partners
Imprecise geolocation data such as IP address Shared Digital advertising partners
Electronic information such as information you provide directly or through your interactions with our Service (device type, network data, internet service provider, operating system, date and time stamp of actions, log data and gameplay tracking), and interactions with our advertising and communication campaigns that are advertised on our third party business partner websites Shared Digital advertising partners
Inferences drawn from other personal information such as profile reflecting your preferences Shared Digital advertising partners

We shared personal information over the preceding 12 months for the following business purposes to personalize your experience on our Services and manage our advertising activities on the Service and on third-party platforms and channels.

B. YOUR U.S. PRIVACY RIGHTS

If you are a resident of a U.S. state, depending on the state you live in, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights.

• Right to Access. You may have a right to request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. In addition, if you are California resident, you have a right to request the following information about our collection, use and disclosure of your personal information:

  • categories of personal information we have collected, disclosed for a business purpose or shared;
  • categories of sources from which we collected personal information;
  • the business or commercial purposes for collecting and/or sharing personal information;
  • categories of third parties to whom the personal information was disclosed for a business purpose or shared; and
  • specific pieces of personal information we have collected.

• Right to Delete. You have a right to request that we delete personal information we maintain about you.

• Right to Correct. You have a right to request that we correct inaccurate personal information we maintain about you.

• Right to Opt out of Sharing/Targeted Advertising. You have a right to direct us not to share your personal information for cross-contextual behavioral advertising/opt-out of the processing of your information for the purposes of targeted advertising. To exercise this right, please use the following form: Do Not Sell or Share My Personal Information. For information on how we process opt-out preference signals, see the section above, Cookies and Other Tracking Technologies.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address before providing a substantive response to the request. Depending on your location, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

In addition, you may have the right to appeal our decision regarding a request related to these rights by contacting us using the information provided below. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

In addition, California law permits residents to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for their direct marketing purposes. We may from time to time elect to share certain personal information about you with third parties for those third parties’ direct marketing purposes. Residents may, under certain circumstances, obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year. To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per resident each year.

C. INDIA

If you reside in India, you may have additional rights under applicable data protection laws. You may access this Privacy Policy in English or any language specified in the Eighth Schedule of the Constitution of India. For the purposes of applicable data protection laws, we are the data fiduciary.

1. Your Responsibility to Ensure Completeness, Accuracy and Consistency By using the Services, you represent, warrant and undertake to ensure that the personal data you provide to us is complete, accurate and consistent.

2. Our Responsibility for Data Processors We are responsible for compliance with applicable data protection laws by our data processors.

3. Restricted Countries and Territories We will not transfer your personal data to any country or territory outside India, where such transfer is restricted as per applicable law.

4. Grievance Redressal If you have any questions, concerns, complaints or grievances regarding our privacy policies or our processing of personal data, please write to our Grievance Officer, at customersupport@steerstudios.com. In the event we do not address your grievances, you may approach the Data Protection Board of India to make a complaint.

5. Data Principal Rights

Access. You may access:

• A summary of your personal data being processed by us along with information on the processing activities undertaken by us with respect to your personal data.

• Subject to applicable law, the identities of the third-parties with whom we have shared your personal data along with a description of such personal data.

• Any other information relating to your personal data as we may be required to share in accordance with applicable law.

You may submit a request to access your personal data in the manner described above, through the procedure prescribed under applicable law.

Correct, complete or update. You may correct inaccurate or misleading personal data, complete incomplete personal data and update personal data by contacting us at customersupport@steerstudios.com.

Withdraw consent to processing of your personal data. Where consent is the basis of us processing of your personal data, when you log into your account, you may withdraw such consent and we will, within reasonable time and subject to applicable law, cease to process your personal data. However, you may no longer have access to the Services in the event you withdraw your consent to us processing your personal data. Upon withdrawal of your consent to us processing your personal data, we will also, unless we are required to retain your personal data for compliance with applicable law or to the extent necessary for us to enforce any legal right or claim, erase your personal data, but may retain your personal data in an aggregated and anonymized format.

Erase your personal data. You may submit a request to erase your personal data in our possession, through the procedure prescribed under applicable law. Upon receipt of such request, unless we are required to retain your personal data for compliance with applicable law, we will erase your personal data, but may retain your personal data in an aggregated and anonymized format.

Right to nominate. You may submit a request, through the procedure prescribed under applicable law, to nominate an individual who shall, in the event of your death or incapacity, exercise your rights with respect to us processing your personal data.

6. Data Retention We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, for as long as required by applicable law (e.g., for tax, legal, accounting, or other purposes) or to the extent necessary for us to enforce any legal right or claim, whichever is longer.

7. Personal Data of Minors Individuals under the age of 18 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about individuals under 18 years of age. If we become aware that we have unknowingly collected information about an individual under 18 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of an individual under 18 years of age who has provided us with their personal information, you may contact us at customersupport@steerstudios.com to request that it be deleted.

D. PHILIPPINES

If you reside in the Philippines:

• You shall have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your information; and

• Only information absolutely needed by third parties for the above-declared purposes (Section 3) will be shared.