The big law-abiding version

Protecting your privacy is really important to us. Accordingly, SadSquare Studio inc., developer of « Visage », (« SadSquare Studio », « us », « we », or « our ») is providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we process in the course of our business, including information we receive through our Services and other online or offline offerings. This Privacy Policy does’t apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized words used in this Privacy Policy have the same meanings as in our Terms of Use. This Privacy Policy is incorporated by reference into our Terms of Use. So, please make sure that you have read and understand our Terms of Use. All individuals whose responsibilities include the processing of any information relating to an identified or identifiable natural person (« Personal Information ») on behalf of SadSquare Studio are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

Personal Information we may collect from you

SadSquare Studio collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively « Individuals »). We may ask you to provide some or all of the following types of information:

Communications with Us

We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for SadSquare Studio’s newsletter or a program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.

Surveys

From time to time, we may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/ or Services and in any manner consistent with the policies provided herein.

Posting on the Site

SadSquare Studio may offer publicly accessible fun pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in SadSquare Studio’s fun pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered « public » and will not be subject to the privacy protections set forth herein.

Automatic Data Collection

We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, Game Center ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through the use of the Services such as preferences.

Information Submitted Via Services

You agree that SadSquare Studio is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Information from Other Sources

We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you create an Account using your login credentials from one of your SNS Accounts, we’ll be able to access and collect your name and other Personal Information that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered Personal Information because it cannot be used by itself to identify you. This supplemental information allows us to verify information that you have provided to SadSquare Studio and to enhance our ability to provide you with information about our business, products, and Services. Information Collected Using Cookies and other Web Technologies Like many website owners and operators, we, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (« Technologies ») to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a « device ») that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices. We use automated data collection tools such as Cookies and Web Beacons to collect certain information.

Cookies

« Cookies » are small text files that are placed on your device by a web server when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your device. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.

Pixels

« Pixels »/« Web Beacons » (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

Widgets

« Social Media Widgets » such as the Facebook « Like » button and LinkedIn (that might include widgets such as the share this button or other interactive miniprograms) may be on our Site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

Uses of Technologies

Operationally Necessary

We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions

Performance Related

We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools

Functionality Related

We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related

We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Social Media Platforms

SadSquare Studio’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

Third-Party Payment Processing

We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, « App Stores »), Social Networking Sites (« SNS ») such as Facebook, and other third-party payment processers, including Stripe. The third party application may collect certain financial information from you to process a payment on behalf of SadSquare Studio, including your name, email address, address and other billing information.

How We Use Your Information

We acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested

We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to: - Generally manage Individual information and Accounts - Respond to questions, comments, and other requests - Provide access to certain areas, functionalities, and features of SadSquare Studio’s Services - Contact you to answer requests for customer support or technical support = Allow you to register for events

Administrative Purposes

We may use Personal Information about you for administrative purposes, including to: - Measure interest in SadSquare Studio’s Services - Develop new products and Services - Ensure internal quality control - Verify Individual identity - Communicate about Individual Accounts and activities on our Services and systems, and, in SadSquare Studio’s discretion, changes to any SadSquare Studio policy - Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance - Process payment for products or services purchased - Process applications and transactions - Prevent potentially prohibited or illegal activities - Enforce our Terms

Marketing SadSquare Studio Products and Services

We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include: - To tailor content, advertisements, and offers - To notify you about offers, products, and services that may be of interest to you - To provide Services to you and our sponsors - For other purposes disclosed at the time that Individuals provide Personal Information, or - Otherwise with your consent You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in this Privacy Policy.

Research and Development

We may use Personal Information to create non identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, SadSquare Studio may perform research (online and offline) via surveys. We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes. Direct Mail, Email and Outbound Telemarketing Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in this Privacy Policy.

Services via Mobile Devices

From time to time, SadSquare Studio may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of our Services may require that users log in with an Account. In such cases, information about the use of mobile versions of the Services may be associated with Accounts. In addition, SadSquare Studio may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to SadSquare Studio to enable Individuals to access Accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to SadSquare Studio to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices SadSquare Studio provides.

Anonymous and Aggregated Information Use

We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access SadSquare Studio’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within SadSquare Studio and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. Information That We Share With Third Parties We will not share any Personal Information that we have collected from or regarding you except as described below,

Information Shared with Business Partners

We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with SadSquare Studio. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which SadSquare Studio provided them.

Information Shared with Other Third Parties

We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. Information Disclosed in Connection with Business Transactions Information that we collect from our users, including Personal Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction.

Your Choices & Opt-Out

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to SadSquare Studio’s processing of your Personal Information, you may withdraw that consent at any time and opt-out to further processing by contacting us at contact@sadsquarestudio.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/ or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements. We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to « opt-out » (either through your Account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing.

Modifying Your Information

You can access and modify the Personal Information associated with your Account through your Account settings or by contacting us at contact@sadsquarestudio.com. If you want us to delete your Personal Information and your Account, please contact us at contact@sadsquarestudio.com with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether SadSquare Studio is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may contact us at contact@sadsquarestudio.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by us. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. Although SadSquare Studio makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Data Retention

SadSquare Studio retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

The Security of Your Information

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We do not accept liability for unintentional disclosure. By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

Questions?

Please contact us at contact@sadsquarestudio.com if you have any questions about our practices or this Privacy Policy.