Introduction

This Privacy Policy describes how Foozle LLC (“Foozle”, “Company”, “we”, or “our”) collects, stores, uses and distributes information when you access and/or use our applications (“Software”). Foozle LLC is a gaming and entertainment service provider in addition to providing assets and tools to other game developers.

Foozle LLC respects your privacy and is committed to keeping personal information accurate, confidential, and secure. We collect, use, and disclose personal information only with your consent and only for the services that we provide you. We always ask for your permission before we share or use information for a purpose other than to what you have consented. This privacy policy is based on the principles set out in the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Canadian Standards Association Model Code for the Protection of Personal Information.

This Privacy Policy describes the principles Foozle will use to protect the privacy of personal information in its possession or control, in accordance with the law and Foozle LLC’s own policies.

Definitions

Privacy

Privacy is an individual’s right to retain control over the collection, use and disclosure of her/his personal information.

Personal Information

Personal information means identifying information about an individual in oral or recorded form. Any data that has been collected in which all personal identifiers have been removed, such that the information could not reasonably be used to identify the individual, is not considered personal information.

Privacy Principles

Accountability

Foozle LLC has a designated contact person who is accountable for our compliance. The contact person’s information is contained at the end of this page.

Identifying Purposes of Collecting Personal Information

Foozle LLC will identify the purposes for which personal information is collected at or before the time the information is collected. If Foozle LLC intends to use personal information for any other purpose, we will seek your consent.

How Foozle LLC Uses Personal Information

With your consent, Foozle LLC uses your personal information for the purposes of providing you access to, and enabling your participation in, the Application (Software) via your account. When you voluntarily give us first name, last name, and other names that identify you, your email address, and other data or information that has been requested by Foozle LLC and that you voluntarily provide, we use this information solely for providing you access to, and enabling your participation in, the Software.

If you have opted-in to receive marketing communications from us, we will send you promotional offers from time to time. You may unsubscribe at any time by clicking the unsubscribe link at the bottom of the message. This prevents any promotional emails from being sent to you unless you explicitly request that we re-add you to a promotional list.

Obtaining Consent

Foozle LLC will obtain consent before or when we collect, use, or disclose personal information about you, except where otherwise required by law. You can provide consent to the collection, use, and disclosure of personal information about you expressly, implicitly, or through an authorized representative. You can withdraw consent at any time, with certain exceptions.

Limiting Collection

Foozle LLC collects personal information only by fair and lawful means. This information may include your first name, last name, other names that identify you, email address, and other personal information that has been requested by Foozle LLC and that you voluntarily provide. Upon accessing or requesting access to Foozle LLC’s Software or other services, you agree and understand that the collection of personal information is only for providing you access to, and enabling your participation in, the Software or other services and for record-keeping purposes.

Limiting Use, Disclosure, and Retention

Foozle LLC will use personal information only for the reasons it was collected, unless an individual gives consent to use or disclose it for another reason. Foozle LLC will keep personal information only as long as necessary for the identified purposes or as otherwise permitted or required by applicable law or pursuant to the Foozle LLC Terms of Use. Personal information may be retained for longer periods of time if required for legal or security purposes. For example, Foozle LLC may retain some account information, device identifiers, and limited log information, including chat messages, for accounts that have been banned or that violate the Foozle LLC Terms of Use. In some circumstances, Foozle LLC may also log and retain chat messages used for investigating behavior that may not meet our community standards or that may otherwise violate applicable law or the Foozle LLC Terms of Use. Foozle LLC does not actively monitor chat messages and will not view your chat messages unless we have a reasonable suspicion that you have engaged or are engaging in behaviour that violates our community standards or that may otherwise violate applicable law or the Foozle LLC Terms of Use.

Foozle LLC may share personal information with our affiliates and service providers who may be involved in delivering Foozle LLC’s services, providing customer support, and conducting customer research or satisfaction surveys. These service providers are obligated to protect personal information, and they are only given the information necessary to perform their designated functions. Foozle LLC does not authorize any service providers to use or disclose personal information for their own marketing or other purposes; however, they may collect information that they do not share with us in accordance with their own privacy policies. These service providers include:

• Xsolla, a payment services company, providing game developers and publishers with payment, billing, distribution, and marketing tools, owned by Xsolla (USA), Inc., whose terms can be found here or at https://xsolla.com/terms-of-service;

• Discord, a Voice over Internet Protocol (VoIP), instant messaging, and digital distribution platform, owned by Discord Inc., whose privacy policy can be found here or at https://discord.com/privacy;

• Colyseus Cloud, a multiplayer hosted solution built on Node.js, whose privacy policy can be found at https://cloud-prod.colyseus.io/privacy-policy;

• Playfab, is a LiveOps back-end platform for building and operating live games which is owned by Microsoft Corporation, whose privacy policy can be found at https://playfab.com/privacy-terms/;

We may also share personal information with our financial, insurance, legal, accounting or other advisors that provide such professional services to us.

Personal information may be processed and/or stored outside of the United States. While we undertake measures to protect personal information, when it is stored and/or processed in other jurisdictions, the laws of other countries may not provide the degree of protection for personal information that is available in the United States. If personal information is transferred outside of the United States, it may be available to the foreign government of the country in which the information or entity controlling it is situated under a lawful order made in that country and used for purposes other than those described herein. By providing us with your information, you are allowing this personal information to be transferred outside of the United States.

Maintaining Accuracy

Foozle LLC will keep the personal information in its possession or control accurate, complete, current and relevant, based on the most recent information available to Foozle LLC. You are responsible for notifying Foozle LLC about the accuracy and completeness of your personal information and may have it amended as appropriate.

Safeguards

The safety and privacy of personal information is our top priority. Personal information will be protected by security safeguards appropriate to the nature and format of the information being stored. We strive to protect personal information from theft, loss, and unauthorized access, copying, modification, use, disclosure and disposal. We ensure that all of our officers, employees and agents protect your privacy and only use personal information for the purposes to which you have consented.

Openness about Policies and Procedures

We will readily make available specific information about our policies and practices related to the management of personal information. Individuals will have access to this information through this Privacy Policy or by contacting us. The information will be available in a format that is easy to understand.

Providing Individual Access

Except as restricted by law, upon written request by the individual or substitute decision maker, an individual will be informed of the existence, use and disclosure of her or his personal information and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and may request to have it amended.

Questions and Compliance

We would be happy to answer any questions that you may have about your personal information, our privacy protection practices, or this Privacy Policy. You may contact us as follows:

support@foozle.io

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Amendments to this Privacy Policy

In order to ensure that this Privacy Policy is kept up to date, we reserve the right to change this Privacy Policy from time to time. Any changes will be effective 30 days following the update. Notice of changes to the Privacy Policy may be distributed through Foozle LLC newsletters or posted on the Foozle LLC website or Software. Your continued use of the Software after the effective date signifies your acceptance of and agreement to any changes. Please check this page regularly. The date last updated will be posted at the top or bottom of this page.

 

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Last Updated: January 6, 2024

Effective Date: January 6, 2024