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Privacy Policy

Snail Games collects, processes, and stores certain information about visitors and users of Dappervolk as outlined below.

I. The types of personal information that Dappervolk collects from users:
  1. Account registration information: user names, login names, email addresses, parent or legal guardian email addresses, and birth dates.
  2. Login information: IP addresses, cookies, and web analytics.
  3. Voluntary text-field submissions: site features where a user is able to enter text into a text-field may or may not contain voluntarily submitted personal information, which is collected as a part of many of our communication-based features (such as forum posts, profiles, support tickets, etc.).
  4. Payment information, as it relates to the purchase of official Dappervolk products, such as payment agent details.
  5. Job applications: submitted documents such as resumes, cover letters, and portfolios.

II. How Dappervolk collects personal information:
  1. We collect some personal information directly when users provide it to us, automatically as users navigate through Dappervolk.com.
  2. Personal information is actively collected when completing registration for an account, when a user updates their account details, when a user logs into their account, when users purchase official products from Dappervolk, when subscribing to our newsletter, when submitting a support ticket or direct communication to us, when entering contests, and when applying for a job or volunteer position on Dappervolk.
  3. Personal information may be passively collected when users voluntarily submit text to our site features that allow for text-field submissions, and when users buy or provide items or services on Dappervolk.

III. Personal information that Dappervolk collects about you from others:
A. Although we generally collect personal information directly from the player, on occasion, we also collect certain categories of personal information about players from other sources. In particular:
  1. Financial and/or transaction details from payment providers in order to process a transaction.

IV. How Dappervolk uses personal information:

A. We use personal information:
A1. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:Operating Dappervolk;
  1. Providing you with services described on Dappervolk;
  2. Verifying your identity when you sign in to Dappervolk;
  3. Responding to support tickets, and helping facilitate the resolution of any disputes;
  4. Updating you with operational news and information about Dappervolk e.g. to notify you about changes to Dappervolk, website disruptions or updates;
  5. Carrying out technical analysis to determine how to improve the Sites and services we provide;
  6. Monitoring activity on the Site, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to Dappervolk;
  7. Managing our relationship with the user, e.g. by responding to comments or queries submitted to us on Dappervolk or asking for user feedback;
  8. Managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
  9. Training Snail Games staff about how to best serve our user community;
  10. Improving our products and services;
  11. Providing general administrative and performance functions and activities; and
  12. Processing job or volunteer position applications to Snail Games.

A2. Where the user gives us consent:
  1. Providing the user with marketing information about products and services which we feel may interest you.

A3. For purposes which are required by law.
A4. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

V. When Dappervolk may disclose collected personal information:

A. We will only disclose personal information to the following recipients:
  1. Developers of Dappervolk, so they can facilitate support and license validation, who may be located in any of the countries Dappervolk is available in;
  2. Subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in US; payment processing services which are located in the US, Canada; Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations;
  3. Our professional advisers (lawyers, accountants, financial advisers etc.) which are located in Canada;
  4. Regulators and government authorities in connection with our compliance procedures and obligations;
  5. A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
  6. A third party, in order to enforce or defend our rights, or to address financial or reputational risks;
  7. A rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
  8. Other recipients where we are authorized or required by law to do so.

VI. Where Dappervolk transfers and/or stores personal information:
  1. As Dappervolk’s servers are based in the United States, your data will primarily be processed and stored in the United States.
  2. Some entities described in section 4.1.1 of this Privacy Policy, to whom collected personal information is disclosed, may be based internationally. We do this solely on the basis of your consent to this Terms of Service agreement. In order to protect your information, we take care to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

VII. How Dappervolk keeps personal information secure:
  1. We store personal information on secure servers that are managed by us and our service providers.
  2. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.

VIIII. Information about children:
  1. Dappervolk is not accessible for children under the age of 13 years. If any individual is under 13, we ask that they do not use Dappervolk or submit their personal information to us. If an individual is from 13 to 16 years, they can play Dappervolk but will need to provide the email address of a parent or legal guardian to become a registered User.
  2. It is the responsibility of parents or guardians to monitor their children’s use of Dappervolk.

X. Information you make public or give to others:
  1. If Users voluntarily make their personal information available to other Users on Dappervolk, we cannot control or accept responsibility for the way others will use or manage that data. It is the User’s responsibility to be mindful when making any amount of potentially personally identifiable information publicly available or giving such information to another User.
XI. How long does Dappervolk keep a User’s personal information:
  1. We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information, you can request that we erase your personal information and close your Dappervolk account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

XII. If you are a User or visitor in the European Economic Area, the following data rights apply to you:
  1. For the purposes of applicable EU data protection law, including the General Data Protection Regulation 2016/679 (GDPR), we are a ‘data controller’ of personal information submitted to us by users.
  2. Users that are protected under GDPR law are entitled to request their personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing.
  3. These rights are limited in some situations - for example, if we can reasonably demonstrate that we have a legal requirement to process a user’s personal information. In some instances, this means that we may retain some data even if a user withdraws their consent to the terms herein or requests removal of such information.
  4. Where we require a user’s personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us.
  5. If a user has unresolved concerns, they have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
  6. To make an access, correction, or removal request, submit a support ticket at the Ticket Desk. In accordance with GDPR laws, you will receive your requested info and/or assistance without undue delay.
Such requests are subject to some limitations, such as but not limited to:
  1. Time and resources required on the part of Snail Games staff to aggregate the associated data and/or process such requests; and
  2. Abuse of this provision, such as unnecessarily frequent or repeated requests.

XIII. For California Residents: CCPA Information
This Privacy Notice for California Residents supplements the information contained elsewhere in this Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California, USA (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Rights and Choices
The CCPA provides consumers located in the state of California with certain rights regarding their personal information and data. The following section describes those rights and explains how to exercise them:

Access to Specific Information and Data Portability Rights
You have the right to request that the company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described in the section “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:
  1. The categories of personal information we collected about you.
  2. The categories of sources for the personal information we collected about you.
  3. Our business or commercial purpose for collecting or selling that personal information.
  4. The categories of third parties with whom we share that personal information.
  5. The specific pieces of personal information we collected about you (also called data portability request)
  6. If we sold or disclose your personal information for a business purpose, two separate lists disclosing:
  7. Sales, identifying the personal information categories that each category of recipient purchased, and
  8. Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.
  5. Any CCPA-permitted financial incentive we offer will reasonably relate to your value and contain written terms that describe the program’s material aspects.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending in a ticket.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access of data portability twice within a 12-month period. The verifiable consumer request must:
  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request requires you to have an account on Dappervolk. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Information We Collect
Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our website may have collected the following categories of personal information from its consumers within the last twelve (12) months:
  1. Identifiers
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  3. Commercial information.
  4. Internet or other similar network activity.
  5. Geolocation data.
  6. Inferences drawn from other personal information.

Personal information does not include:
  1. Publicly available information from government records.
  2. Deidentified or aggregated consumer information.
  3. Information excluded from the CCPA’s scope, like:
    1. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    2. Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
  1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we or our third-party service providers will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders and requests.
  2. To provide, support, personalize, and develop our websites, emails, and other products, services and platforms.
  3. To create, maintain, customize, and secure your account with us.
  4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  5. To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
  6. To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website.
  7. To help maintain the safety, security, and integrity of our website and business.
  8. For testing, research, analysis, and product development, including to develop and improve our website.
  9. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  10. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  11. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
The Company may disclose your personal information to a third-party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see ‘Sales of Personal Information’ below). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales (see ‘Sales of Personal Information’ below).

We may share your personal information with the following categories of third parties:
  1. Subsidiaries and affiliates.
  2. Contractors and service providers.
  3. Data aggregators.
  4. Third parties with whom we partner to offer products and services to you.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
  • [Category A: Identifiers.]
  • [Category B: California Customer Records personal information categories.]
  • [Category F: Internet or other similar network activity.]
  • [Category G: Geolocation Data.]
  • [Category K: Inferences drawn from other personal information.]

Sales of Personal Information
In the preceding twelve (12) months, the company has sold the following categories of personal information collected through our ad-supported services:
  • [Category A: Identifiers.]
  • [Category F: Internet or other similar network activity.]
  • [Category G: Geolocation Data.]
  • [Category K: Inferences drawn from other personal information.]
The company and our advertising partners collect the personal information identified above (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you use our website. We, and our partners, use this information to tailor and deliver ads to you on our website, or to help tailor ads to you when you visit others’ sites (or use others’ apps). To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.

XIV. Regarding policy updates:
  1. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
  2. When we do change the policy, we’ll make sure to notify users about such changes, where required. A copy of the latest version of this policy will always be available on this page.
XV. How users can contact us:
  1. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us through the Ticket Desk onsite or email [email protected]
Both personal information and personal data have the same meaning in the context of this Privacy Policy.
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