4341571 Canada Inc. d/b/a Clever Endeavour Games (“CLEVER ENDEAVOUR”) makes games for consumers which are made available on various platforms and sold by numerous publishers and other entities.
Application and Scope
Definition of Personal information
Collection and Use of Personal Information
We collect most of our information about you directly from you, with your consent, as well as from Steam™, Stripe™ Gamesparks™ ,Sony™, Microsoft™, Nintendo™ Google™ and other game platforms. We may also obtain personal information about you from other third parties, with your consent. The GameSparks™ service has access to profile information such as friends’ lists, age, etc. However, this functionality is not used by CLEVER ENDEAVOUR so that information is not collected by us.
CLEVER ENDEAVOUR generally collects personal information from or about its customers and other individuals with whom it deals for the following purposes:
- to provide the products or services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented;
- to authenticate the identity of users and allow them to play online via social networks such as Steam, PlayStation Network, Xbox Live, Nintendo NEX etc. by using their unique platform ID to identify them on those platforms;
- to manage its businesses and ensure the efficiency, reliability and security of its systems and networks;
- to meet legal and regulatory requirements and to allow CLEVER ENDEAVOUR to meet contractual requirements relating to the products and services provided to customers; and
- via analytics, to understand and assess the interests, wants and changing needs of customers with a view to improving its products and services and developing new ones.
If you have applied for employment with CLEVER ENDEAVOUR, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within CLEVER ENDEAVOUR as well as other career development resources.
CLEVER ENDEAVOUR obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means: orally or through written documents, including agreements, forms, and printed or electronic communications. The form of consent sought by CLEVER ENDEAVOUR will vary according to the sensitivity of the personal information, the reasonable expectations of the individuals and any requirements or standards established by law. However, we do not sign users up for newsletters, blogs etc. without their express consent to opt in.
In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
- where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
- when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information;
- to collect a debt; and
- to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.
Right to Withdraw Consent
Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, CLEVER ENDEAVOUR may limit the services or products it is able to provide customers. You may also withdraw your consent as follows:
Commercial Electronic Communications. You can always limit the communications that CLEVER ENDEAVOUR sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account. If you have any questions about your choices or if you need any assistance with opting-out, please contact us via our Contact page.
Sharing of Personal Information
- Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by CLEVER ENDEAVOUR to perform work on its behalf, including for the analysis of analytics and quality control assessment. CLEVER ENDEAVOUR will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by CLEVER ENDEAVOUR itself.
As permitted or required by law. From time to time, CLEVER ENDEAVOUR may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. In these circumstances, CLEVER ENDEAVOUR will protect the interests of its customers by making reasonable efforts to ensure that orders or demands comply with the laws under which they were issued, that it discloses only the personal information that is legally required and nothing more, and that it does not comply with casual requests for personal information from government or law enforcement authorities. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
Only those employees of CLEVER ENDEAVOUR or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about customers.
CLEVER ENDEAVOUR generally collects and uses personal information from or about its website visitors and users as follows:
Information you provide. In many cases, we collect personal information directly from you when you visit or use our website. For instance, we may collect the following type of information:
Inquiries. We may collect your name, contact information, e-mail address and any information you provide us when you make an inquiry or contact us through our website. We will only use this information to provide you with the information requested or to contact you in order to answer your questions and/or requests.
Request for Product and/or Service. We may collect your name, contact information, e-mail address and any other information provided to us when you sign up to receive our newsletter or when you participate in a contest or promotion run by CLEVER ENDEAVOUR or when you submit a request or an order for a CLEVER ENDEAVOUR product and/or service. We will only use this information to process and answer your request or to manage our everyday business needs in connection with such participation or request.
Satisfaction Survey. When you visit our website, you may, from time to time, be invited to participate to a satisfaction survey. In such case and if you decide to participate to our survey, we may collect your postal code, email address and other information deemed important to complete such survey.
Technical information. When you visit our website, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our customers. For instance, it may be used to ensure that the products advertised on our website are available in your area or that we are not showing you the same ads repeatedly. We treat this information as personal information when it is associated with your account or contact information. For instance, we may collect and use the following type of information when you visit and/or interact with us on our websites:
Google Analytics: We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
Mobile Apps. In the event that you download and/or use any of our applications, we may require and collect, directly from you, information necessary to authenticate you. We may also record your IP geolocation, allowing us to block the access when the user is outside of Canada.
Personal Information Outside of Canada
While CLEVER ENDEAVOUR is using reasonable measures, when possible, to favor Canadian communication routing as well as Canadian providers, your personal information may in some situations be routed through foreign jurisdictions, such as the United States. In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there. CLEVER ENDEAVOUR will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by CLEVER ENDEAVOUR itself.
Security of Personal Information
We will use reasonable security measures to protect your personal information against unauthorized access. CLEVER ENDEAVOUR generally has no access to your credit card information, and the entities which sell our games have implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information.
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous.
Access and Correction
CLEVER ENDEAVOUR complies with all laws regarding access and correction. If you need assistance updating your personal information, please contact us using the contact information detailed in How to Contact Us section below.
How to Contact Us
Richard Atlas, Chief Executive Officer
CLEVER ENDEAVOUR GAMES
1435 Rue St-Alexandre, Suite 140
Montréal, Québec H3A 2G4
By e-mail: email@example.com