Finger Food Studios Inc. Privacy Statement
Effective Date: March 13, 2020
We at Finger Food Studios Inc. (“us”, “our”, “we”, “Finger Food” or “Company”) consider the protection of your personal information to be a priority. The guidelines contained in this Privacy Statement apply to information collected, used and/or disclosed by us, and describe how we may collect, use and disclose information that we receive as a result of your use of our products and the Internet-based and mobile applications we may make available to you from time to time on various platforms and devices (collectively, the “Services”). By using the Services, you hereby acknowledge that we will collect, use and disclose your personal information as set out in this Privacy Statement. We comply with BC’s Personal Information Protection Act, Personal Information Protection and Electronic Documents Act (Canada) and EU’s General Data Protection Regulation, as applicable (collectively, the “Applicable Privacy Legislation”). Where we are processing data in a way that means that BC’s Personal Information Protection Act, Personal Information Protection and Electronic Documents Act (Canada) apply, you hereby consent to the collection, use and disclosure of your personal information as set out in this Privacy Statement. Where we are processing data in a way that means we must comply with EU’s General Data Protection Regulation, we are required to meet some additional obligations in relation to your information (the “Additional GDPR Requirements”). We have highlighted the Additional GDPR Requirements in boxes in this Privacy Statement.
We are registered in Canada and our registered address is at 2755 Lougheed Hwy #420, Port Coquitlam, BC V3B 5Y9, Canada.
We reserve the right to modify this Privacy Statement at any time without notice. We will revise our Effective Date to reflect any revisions to this Statement.
Some aspects of our Services may have additional information regarding privacy practices specific to that application, functionality, or service. Please review all information closely as that may change how this general Privacy Statement operates for that specific application, functionality, or service.
How We Define “Personal Information”
As you can see from the below list, not all information we collect is personally identifiable. We define “personal information” as information that is sufficient to identify you as an individual and contact you personally. This would include your full name, your full mailing address, your telephone number, your personal e-mail address, your user name(s) and password(s), and your financial information (e.g., bank accounts, credit card numbers, etc.). Information that does not enable someone to identify you as an individual and contact you personally is not “personal information” for the purposes of this Privacy Statement.
What Personal Information May We Collect About You?
- Personal Information that you provide to us:
- We may receive your name, email address, physical address, phone numbers, credit card numbers, and other such information as we may request or that you may provide to us from time to time.
- Personal Information we obtain from other sources:
- We and third parties also use certain technologies described below to collect information to deliver excellent experiences.
- Information we collect or generate about you:
- We may also collect information that is aggregated in a non-personally identifiable way for our quality assurance purposes and for making improvements to our Services.
- We may capture certain information automatically through the Services, including your Internet protocol address, mobile device identification number, browser type, page access history, linking information, click stream data, page visits, page views, and/or web site log files.
What About Children?
It is not our intention to offer the Services to anyone under the age of 13, and we do not actively market to such persons. As such, we do not intentionally collect or maintain information from persons we actually know are under the age of 13. If we learn and are able to confirm to our satisfaction that someone under the age of 13 has shared personal information with us through our Services, we will take steps to delete this information from our databases (if possible) or deploy other measures that are intended to prevent such persons from sharing information with us in the future.
How Might We Use Your Personal Information?
We might use the personal information we collect in the following ways:
- To contact you with relevant information about our Services.
- To contact you regarding new products, innovations, opportunities, and offers, whether originating from us or from a third party (subject to your express consent).
- To provide you with personalized offers, promotions, news, events, and other information relevant to your interests or needs (subject to your express consent).
- To establish and maintain customer accounts.
- To quickly process your requests for information.
- To allow us to respond efficiently to your questions.
- To monitor our customer service employees.
- To allow us to disclose your information to the extent permitted by law, in the situations described more fully below.
- To bill charges to those who use our Services that are subject to fees.
- To obtain legal or other professional advice.
- To prevent fraud, criminal activity, or harm to users of our Services.
- To take any other action as you may request from time to time (for example, certain aspects of our Service may allow you to request that we combine your information with information stored by a third party such as the iOS Game Center, digital distribution platforms like Steam and/or Origin, etc.).
Any information that is not “personal information” may be used for any reasonable business purpose, as we may engage in from time to time. This would include but is not limited to monitoring Service-related statistics, providing information to third parties in aggregated, non-personally identifiable form, performing analysis of our offerings and business activities, learning more about the demographics of our users, or personal information that has been stripped of all ability to identify you individually (e.g., personal information that has been “hashed” using cryptographic techniques or functionality).
We are entitled to use your personal information in these ways because:
- we have obtained your explicit consent to do so;
- we may need to in order to provide you with Services or to perform any obligation under a contract we have with you;
- we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
- the use of your personal information as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), as listed above.
How Do We Protect Your Personal Information?
Although we cannot guarantee the impenetrability of our systems, we have established and implemented reasonable physical, electronic, and administrative procedures to safeguard and secure the personal information we collect.
Security of your personal information is not only the responsibility of Finger Food, but also of you, the user. Do not share your personal information or other sensitive information (particularly your password(s), credit card numbers, and social security numbers) – except when absolutely necessary, and make sure you know to whom you are giving this information.
Do We Disclose the Information We Collect to Outside Parties?
The following is a list of situations where we may share your information, including (in some cases) your personal information. This list is not exhaustive, and is not meant to restrict the uses we may make of the information we collect unless we specifically state otherwise below.
We, generally, do not share personal information that directly identifies you (such as your name, e-mail or postal address) with third parties for their own use without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights.
- We may hire vendors to perform services on our behalf. These companies may require personal and non-personal information to fulfill their task, but are only allowed to obtain the personal information that is absolutely necessary for them to accomplish their purpose. Such third parties are prohibited from using the personal information for any other purpose. They have also agreed to keep your personal information confidential and secure. In the case of any network advertiser hired by us (see below), we require the network advertiser to refrain from sharing or using any personal information collected at our request for the benefit of anyone other than us unless we have your explicit consent for that type of use.
- We may share your information, including personal information, with our related companies, including our subsidiaries, parent company, and affiliated companies. This allows us to get a better understanding of who our consumers are worldwide, improve our Services based on global needs and interests, and market our Services using local resources and based on local interests.
- We may hire independent network advertisers to show you banner ads when you visit other, third party Services. To do this more efficiently, the network advertiser may use and place on your computer or connected device certain technologies, such as cookies and/or web beacons, to collect from you non-personal information (in most cases, certain technical and/or browsing data) while you utilize our Services or other applications, functionalities, websites, and services participating in the same network. This information is then used to display advertisements about goods and services (whether offered by us or other companies) more likely to be of interest to you when you visit those other services. If you would like to learn more about this practice or how you can opt out from allowing network advertisers to gather this information from you or use it to provide you with tailored ads on other sites, please visit the Network Advertising Initiative (NAI)’s Service. Please note that even if you use the mechanism above to opt-out from this type of information gathering, if, at any time, you disable or delete all cookies stored on your computer, you will have also disabled the same technology (namely, cookies) used by the NAI to help prevent you from receiving this type of advertising. If you do not want this to happen, please make sure not to disable/delete the NAI cookie, or add NAI to the approved list of sites from which you allow or accept cookies.
- We may wish to generally assess (with the help of a third party company) how our Services are performing in the marketplace, their popularity or use amongst certain consumer demographics or profiles, and other similar performance metrics. The information disclosed for these purposes will be in aggregate form and limited to demographic or other anonymous data; no personal or login information will be shared except as provided for above.
- We may partner with independent, carefully-selected third party companies as part of a jointly-sponsored activity or promotion, or to offer you the ability to receive special offers and discounts directly from third party companies. For example, we may team up with a third party company to offer a contest, giveaway, or other promotion that promotes both our products and theirs, and as part of such promotion, we may share the collected consumer data (including personal and login information). Similarly, when you sign-up to receive our marketing communications, we may allow you to simultaneously sign-up to receive email offers directly from third party companies who offer other products or services that might interest you. A limited amount of personal information may be shared as part of such third party email program.
- If we are bought or acquired by another company (either fully or partially), merged with another company, or experience a reorganization, bankruptcy, or other similar event, then the information we collect will likely be shared with our successor or assignee (i.e., the new company or the company that takes over), subject to the notification procedures set forth in this Privacy Statement.
Subject to the exclusions identified above, we will not actively share personal information with third party advertisers for their direct marketing purposes unless you give us your consent. Advertisers, however, may obtain public information about you from your profile or other public sources. As to the other kinds of information (i.e., non-personal information such as demographic information, business information, information collected passively, and information received from third party social networking sites), we may use and share this information with third parties consistent with the terms of this Privacy Statement.
Where we transfer your personal information outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal information will be protected by us in the EEA. This can be done in a number of ways, for instance:
- the country that we send the data to might be approved by the European Commission;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information; or
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.
In other circumstances, the law may permit us to otherwise transfer your personal information outside the EEA. In all cases, however, we will ensure that any transfer of your personal information is compliant with data protection law.
You can obtain more details of the protection given to your personal information when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal information) by contacting us in accordance with the “Contacting us” section below.
Transfers of Your Personal Information Outside of Canada
The personal information that we collect from you may be transferred to, and stored at, a destination outside of Canada. In the event that we transfer your personal information outside of Canada, we will ensure that it is protected in a manner that is consistent with how your personal information will be protected by us in Canada, either by contractual or other means to provide a comparable level of protection while the information is processed by a third party.
Note: For the avoidance of any doubt, where transfers of your personal information outside of Canada are subject to the GDPR requirements, the information provided in the above box (“Additional GDPR Requirements – Transfers of Your Personal Information Outside The European Economic Area”) will also apply.
Retention Of Personal Information
How long we hold your personal information for will vary. The retention period will be determined by various criteria including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
The Applicable Privacy Legislation offers you a number of legal rights in relation to the personal information that we hold about you. These rights include:
- Right of access: you have the right to obtain information regarding the processing of your personal information and access to the personal data which we hold about you.
- Right of rectification: you have the right to correct personal information that is inaccurate or incomplete.
- Right to be forgotten: in certain circumstances, you have the right to request that we erase your personal information. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it.
- Right to restrict processing: you have the right to object to, and the right to request that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to continue processing your personal information and / or to refuse that request.
- Right to complain: you have the right to lodge a complaint with the Applicable Privacy Legislation regulator if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contacting Us” section below.
You can find out more information about your rights by contacting your Applicable Privacy Legislation regulator.
How Can I Have My Personal Information Deleted?
You may request that we delete the personal information about you that we have collected and stored by sending your request to us in any of the following ways:
Attention: Privacy Officer
Suite 420 – 2755 Lougheed Hwy
Port Coquitlam, BC
Please note that your request to delete personal information is permanent, and we may not be able to recover all information should you wish to in the future. Without complete and accurate personal information, your ability to use our Services may be impacted.
Furthermore, please note that we may not delete personal information collected about you if such information: (a) is required by law to be stored for a certain period of time; (b) is stored as part of a back-up database or similar archive; or (c) is stored as part of a disaster recovery plan (e.g., on mirror databases that are not used except in cases of emergencies). We will not use the personal information stored for any of these reasons for any marketing purpose unless you instruct us otherwise through re-registration for the Services or other such instruction.
Notice to California Residents – Your California Privacy Rights
A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes.
If you are a California resident and would like to make such a request, please submit your request in writing to:
Suite 420 – 2755 Lougheed Hwy
Port Coquitlam, BC
Please note that under California law, businesses are only required to respond to a customer request once during any calendar year.
This Privacy Statement is effective as of the date identified above, and applies to all information we collect. We reserve the right to change the Privacy Statement at our sole discretion. Users of our Services will be informed of any such change by posting a new Privacy Statement on the Service and the effective date of any change of Privacy Statement will be clearly marked. Your continued use of our Services after such a change will be deemed consent to the collection, use and disclosure of information as set forth in the then-current Privacy Statement.
We welcome your questions, comments and concerns about privacy. Please contact our Privacy Officer at firstname.lastname@example.org with any questions or comments you may have regarding the privacy of your information.