Osler, Hoskin & Harcourt LLP (February 3, 2021)
Last revised on: Feb 8, 2021
We understand that privacy is an important issue to you and we respect the privacy of our users and aim to protect the security and confidentiality of information about you that we acquire. Under applicable law you may have the right to limit some, but not all, sharing of the information we collect about you. The law may also require us to disclose to you how we collect, share and protect that information.
What We Collect
We collect information about you when you provide it to us and when you visit our Sites, sign up for and use our Services, request information or otherwise interact with us or our Services.
The personal information we may collect includes:
- Username and avatar;
- Email address;
- Country (provided by you);
- Any Ethereum network addresses (publicly available on the blockchain) you provide to us;
- Any blockchain network address associated with your digital assets or gaming tokens (your “Wallet”);
- Any information you provide in response to a survey or questionnaire; Osler, Hoskin & Harcourt LLP (February 3, 2021)
- Feedback and correspondence, such as any emails, chat messages, or other communications you send to us via email or third-party social media websites;
- Information which may be received from other sources with your consent;
- Information about the device you use to access the Services and Sites, including device model, device ID, IP address, browser type, operating system, platform (Android, iOS, web), referring website; and
- Information about your use of the Services including the pages of our Services which you browsed or the features you used, the time spent on those pages or features, the links on our Services that you click on, as well as actions you take during gameplay, your in-game user settings and preferences and your in-app purchases.
Information from Third-Party Sources
When linking to a third-party service, we may retrieve your email. Such linkage may include interactions with our social media sites. We use this information for marketing and communications purposes. Third-party sites are governed by their own privacy policies, and you should review those privacy policies before using those sites.
How We Use Personal Information
We use, collect and process your personal information in connection with our provision of Services and, where applicable, to meet our legitimate interests, as set out below:
- We use your username for identification purposes within the game, for example, to announce your standing in Conquests, or on the Leaderboard ranking.
- We use your email address to authenticate you, communicate with you to provide technical and customer support and to send updates regarding your participation in any waitlists, Contests and Surveys. We may use your email address to send promotional and other information to you with your permission. With your permission, we may also send you push notifications with game updates and promotions through our App. To learn how to opt-out of the use of your information for such purposes, please see “Your Choices” below.
- If you sign-up to receive our marketing emails, we may also use your email address to display targeted advertisements to you on third-party social media platforms such as Facebook, Twitter, Google or LinkedIn and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To learn how to opt-out of the use of your information for such purposes, please see “Your Choices” below. Osler, Hoskin & Harcourt LLP (February 3, 2021)
- We use the information regarding your country (if provided) to update the flag icon by your username. You can remove this information at any time.
- We use information about your device and your use of the Services to better understand who is using our Services and how, and to improve our Services.
- We use your IP address to provide you with appropriate content and to block access to the Services from locations where we do not provide Services.
- We use your network address associated with your Wallet to allow you to make transactions on the platform, including buying and receiving digital assets such as gaming tokens.
- We use your feedback and correspondence to respond to your requests, feedback, or inquiries, and to continuously improve our products and services.
- We use your payment information to process payments for the digital assets you buy and sell on the platform.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.
What Personal Information We Share
We do not sell, license, lease or otherwise disclose personal information (including personal information relating to current or former customers) to any third party without consent for any reason other than the purposes described below:
- We may transfer or make available personal information to our service providers who require access to the data in order to perform their tasks and duties in the course of providing services on our behalf (such as payment processing, hosting data, providing advertising, marketing and analytics services). We may also share personal information with third parties who have a legitimate purpose for accessing it (where permitted by applicable law). Our service providers may have access to or store personal information outside of the jurisdiction in which you reside, including in the United States.
- We may share your information with customer data and behavioral analytic platforms who help us to understand how you use and interact with our Services.
- We may share your information with payment processing services with which we partner to process payments for digital assets, at your request.
- We may disclose information to third parties about your account or the transactions you make if you give us your written permission. Osler, Hoskin & Harcourt LLP (February 3, 2021)
- We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Horizon Blockchain Games Inc., or as part of a corporate reorganization or other change in corporate control.
- We may disclose personal information to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities.
We may have links to third-party websites on our website. Third-party websites have their own privacy policies, which are not under our control; we encourage you to review the privacy policies of all third-party websites you visit.
We collect the IP addresses of all visitors to our Sites and other related information such as page requests, browser type, operating system and average time spent on our Sites. We use this information to help us understand our website activity and to monitor and improve our Sites and Services.
Horizon also uses analytics providers such as Google Analytics to help us gather and analyze information about the areas visited on the Sites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Sites The following link explains how Google uses data when you use its partners’ websites and applications: www.google.com/policies/privacy/partners/ . To prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en . You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
Your use of Horizon’s website is evidence of your consent to Horizon storing and accessing cookies and other information on your computer or phone and Horizon’s use of Google Analytics in connection with such activities. Please read the information at the link provided so you understand what you are consenting to.
App Usage Information & Analytics
As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our Osler, Hoskin & Harcourt LLP (February 3, 2021) App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
Horizon strives to ensure that our systems are secure and that they meet industry standards. We seek to protect the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure by implementing physical, administrative and electronic safeguards. Horizon restricts access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. Horizon endeavors to engage third-party service providers that have security and confidentiality policies, if such third-party service providers have access to our customer’s personal information and such service providers are not authorized to use the personal information for their own purposes.
Despite our efforts to protect the security of your information, no security system is always effective and we cannot guarantee that our systems will be completely secure.
Subject to applicable law, you may have the following data protection rights:
- In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by emailing [email protected]
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent where permitted under applicable law. Osler, Hoskin & Harcourt LLP (February 3, 2021)
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. To find contact details for authorities in the European Union, click here. To find contact details for privacy regulatory authorities in Canada, click here .
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below or adjusting your preferences in your account settings. Please note that you may continue to receive transactional or account-related communications from us.
You can turn off push notifications for the App within the notifications settings of the App or in the settings of your mobile device.
To opt-out of the use of your information for such targeted advertising on social media platforms, please contact us at [email protected] You can also manage your privacy settings directly through your account on these third-party platforms, including to opt-out of such targeted advertising.
You may also contact us by emailing [email protected]
Legal Basis for Processing Personal Information (EU Residents)
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our Platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. Osler, Hoskin & Harcourt LLP (February 3, 2021)
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Retention of Personal Information
Minors Under 13
Individuals under the age of 13 (“ Children”) are not allowed to use the Services, and we do not knowingly collect personal information from Children in violation of the Children's Online Privacy Protection Act. If you believe that your child under 13 has gained access to the Services without your permission, you may request the deletion of their personal information by contacting us at [email protected] If we learn that we have collected personal information about a child under age 13, we will delete that data as quickly as possible. We have taken commercially reasonable steps to restrict use of the Services to those who are at least 13 years old. We do not market products or services for purchase by Children.
“Do Not Track” Policy
California law requires us to inform you how we respond to web browser Do Not Track (“ DNT”) signals. Because no industry or legal standard exists for recognizing or honoring DNT signals, we do not respond to them at this time. This policy is subject to change as the privacy community and industry develop best practices for responding to DNT signals.
NOTICE TO CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR Osler, Hoskin & Harcourt LLP (February 3, 2021) PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING [email protected] PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
International Data Transfers
Changes to This Policy
If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. Osler, Hoskin & Harcourt LLP (February 3, 2021)