COLD SAP GAMES

PRIVACY POLICY

Last Modified on 6/13/2024

  1. What’s in this Privacy Policy?

In this Privacy Policy, you’ll find:

  • What information we collect about you

  • How we might use that information

  • What information we might share with others

  • Your rights and choices about that information

  1. What does this Privacy Policy cover?

We are Cold Sap Games LLC. In this document, we will refer to ourselves as “Cold Sap Games,” “we,” or “us.” We will refer to you and any other users as “you.”

In this Privacy Policy, we will cover the products and services that we offer to you. These include:

  • The “Years of Division” video game.

  • The “Years of Division” website website located at: yearsofdivision.com.

Together, we’ll refer to these as the “Service.”

By using the Service, you agree to the terms of this Privacy Policy. Please read our Terms of Use, as well, for general guidance about your use of the Service. Except as otherwise expressly agreed, this Privacy Policy and our Terms of Use are the complete agreement between you and Cold Sap Games.

  1. What types of personal data do we collect?

Below you’ll find details about the types of personal data we collect from you and how we use it. We call this “processing” your data.

We’ll also tell you the reason for processing that data, which is known as our “legal basis.”

First, the personal data we collect from you:

Type of data

Examples of the data

How we use it

Our legal basis

Contact Information

  • Full name

  • Email address

  • Age/Birthdate

  • Information about your gaming history and other info



To contact you for playtesting opportunities, technical support and customer support purposes, marketing and promotional purposes, and to gather user feedback.


Based on your explicit consent, under GDPR Art. 6 (1) (a).


Technical Information

  • Device type

  • Operating system

  • Information on your input and display devices


To operate Service playtesting sessions and to analyze user activity and improve and operate the Service.

The collection is necessary for our legitimate interests, under GDPR Art. 6 (1) (f).

Analytic Information

  • Comments and suggestions

  • Gameplay data, including log files produced by the game which will detail gameplay times, activities, and device info

  • Bug reports and related feedback



To analyze user activity and improve the Service.

The collection is necessary for our legitimate interests, under GDPR Art. 6 (1) (f).


Next, the personal data that third parties share with us:

What is the name of the third party sharing information with you?

What type of information is being shared?

What purpose do you use this information for?

Steam and other third-party game platforms

Information about your Service-related purchases made on the third-party platform

To confirm Service-related purchases made on Steam and other third-party platforms


Finally, the personal data that we share with others:

Our reason for sharing

What data is being shared?

Who are we sharing it with?

Their privacy policy

Newsletters and Service-related Communications

Contact Information

Squarespace

https://www.squarespace.com/privacy

Email Hosting

Contact Information

Google

https://policies.google.com/privacy?hl=en

Data collection for improving the Service

Technical Information, Analytic Information

Unity

https://unity.com/legal/privacy-policy


We may also need to share your personal data in a few other situations:

  • To follow the law, a court order, or orders from government agencies

  • To detect and combat fraud or security issues

  • To protect the Service, our employees, and our business’s rights or safety

Other than that, we will not share your personal data with anyone else.

  1. How long do we keep your personal data?

We only keep your personal data as long as it’s required to provide you with the Service. Sometimes a longer period might be required by law.

After that, we will delete your personal data within a reasonable time.

Please note that we may retain some data, if necessary to:

  • resolve disputes,

  • enforce our user agreements,

  • follow any technical and legal requirements related to the Service.

  1. Children’s privacy rights

We don’t knowingly collect any personal data from children under the age of 13. We also don’t knowingly allow them to create accounts, sign up for newsletters, make purchases, or use the Service.

We may also limit our personal data processing for EU users between 13 and 16.

We take children’s privacy seriously and encourages parents to play an active role in their children’s online experience. If you have any concerns about your child’s personal data, please contact us at privacy@yearsofdivision.com.

  1. Transfers of your personal data

Our headquarters is in the United States.

No matter where you live, by using the Service you consent to the processing and transfer of your personal data in and to the United States. This processing will be under the privacy policies of third parties that we share personal data with.

The laws of the United States governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

If you would like more information, please contact us (see “How to contact us” below).

  1. EU residents’ rights

We are regulated under the General Data Protection Regulation (GDPR), which applies across the European Union (including in the United Kingdom). We are responsible as a controller of personal data for GDPR purposes.

Your rights as an EU resident:

Under the GDPR, EU residents have several important rights:

  • You can request a copy of your personal data

  • You can ask us to correct that personal data, delete it, or request that we use it only for certain purposes.

  • If you’ve consented to our processing, you can change your mind and ask us to stop using your personal data. For example, you can unsubscribe from our mailing list at any time – just click the link in each marketing email.

  • In some circumstances, you can ask us not to use automated processing or profiling about you.

If you would like to exercise any of those rights, please email us at privacy@yearsofdivision.com. We may ask for additional info to verify that you’re the owner of that data.

Also, in some cases where the law requires it, we may not be able to help with the above requests.

  1. Brazilian residents’ rights

We are regulated under the Lei Geral de Proteção de Dados (“LGPD”), which applies to Brazilian residents.

Under the LGPD, Brazilian residents have several important rights:

  • Know when we use your personal data

  • Access your personal data, correct any errors, or delete your personal data

  • Anonymize, block, or delete data that we don’t need or are not processing in compliance with the LGPD

  • Request we transfer your data to another provider

  • Be informed about who we share your data with

  • Be informed about your ability to deny consent and any consequences

  • To revoke your consent

These rights apply to any personal data collected or processed in Brazil, as well as any personal data processed for the purpose of providing goods or services in Brazil.

If you would like to exercise any of those rights, please email us at privacy@yearsofdivision.com. We may ask for additional info to verify that you’re the owner of that data.

  1. How do we protect personal data?

We have taken steps and put security measures in place to prevent the accidental loss or misuse of personal data.

For example, we limit access to those who have a genuine business need. Those processing your information will do so only in an authorized manner.

We also have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach when legally required.

  1. Resolving Disputes

We hope that we can resolve any questions or concerns you raise about our use of your personal data.

Please contact us at privacy@yearsofdivision.com to let us know if you have questions or concerns. We will do our best to resolve the issue.

For EU residents, the GDPR also gives you right to lodge a complaint with a supervisory authority. You may do this in the EEA state where you live, work, or where any alleged infringement occurred.

  1. How will we notify you of changes?

We last updated this Privacy Policy on 6/13/2024.

We may make further updates from time to time. If we have your email address on file, we will inform you via email. Otherwise, we will post a message on the Service about the change.

  1. How to contact us

Please contact us if you have any questions about this Privacy Policy or your personal data.

You can do so using the following contact info:

  • Email: privacy@yearsofdivision.com

  • Postal Mail: 440 N Barranca Ave #4589 Covina, CA 91723