Airship Syndicate Entertainment, Inc.

Privacy Notice

Last Updated August 15, 2022

This Privacy Notice for Airship Syndicate Entertainment, Inc. and our affiliates and subsidiaries (collectively, “Airship,” “us,” or “we”) is governed by and part of our Terms of Use and describes how we treat information collected through airshipsyndicate.com, battlechasers.com, and other websites and online channels we own or operate (the “Site”). Please note that this Privacy Notice does not apply to our games or the third-party platforms that offer our games for purchase or play.

Here are a few general points about our privacy philosophy:

·       We collect your information when you provide it to us, and we only use it to fulfill your requests to us, like sending you information about our games, delivering your crowdfunding rewards, or giving you access to our online forums.

·       We never sell or share your Personal information for marketing purposes.

·       You can delete your Kickstarter or other backer account information, online forum account, or unsubscribe from our mailing list whenever you choose.

This Privacy Notice also provides information specific to residents of California, the European Union, and Canada.

We encourage you to read this Privacy Notice carefully to more fully understand how we collect and use your information. We may provide additional notices about our privacy practices, each of which will be considered to form part of this Privacy Notice. If we make material changes to how we treat your Personal Information, we will post the revised Privacy Notice on this page. Your continued use of the Site after we make changes is deemed to be your acceptance of those changes.

Your Consent

By visiting the Site, you consent to the collection and use of your information as described in this Privacy Notice. Your use of the Site is subject to this Privacy Notice and our Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. If you do not agree with this Privacy Notice, do not access the Site.

What Is Personal Information?

When we say, “Personal Information,” we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or device, such as:

·       Identifiers (e.g., name, address, telephone number, email address, username);

·       Sensitive Personal Information (e.g., birthdate, government ID, health information);

·       Protected classification information (e.g., race, citizenship, marital status, medical condition, sex, sexual orientation, veteran or military status);

·       Biometric information (e.g., fingerprint, voice print, keystrokes);

·       Internet or other similar activity (e.g., geolocation, browsing history);

·       Employment-related information (e.g., current or past employment);

·       Non-public educational information (e.g., information protected under FERPA); or

·       Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).

Personal Information does not include (i) publicly available information (ii) aggregated information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot be easily linked back to the individual.

How Does Airship Collect and Use My Personal Information?

For the most part, Airship collects Personal Information only when you give it to us, and sometimes from your interactions with the Site or from a third-party platform where you purchase or play our games. We only collect Personal Information as reasonable and necessary.

Categories. During the preceding 12 months, we have collected these categories of Personal Information:

·       Identifiers

·       Commercial information

·       Internet or other similar activity 

Sources. Airship collects Personal Information directly from you with your consent and indirectly from your use of the Site to achieve one or more legitimate interests.

We collect Personal Information directly from you, with your consent from:

·       Your opt-in to our mailing list. If you opt-in to the Airship Syndicate mailing list or a mailing list associated with Battle Chasers: Nightwar, then you provide us with your email address and name or other identifier so that we can send you updates and information about our games and other services. We will only use this information to send you mailing list messages via MailChimp or a similar mailing list service provider. You can unsubscribe from our future messages by clicking the Unsubscribe link found in any of the emails we send you.

·       Your participation in the Airship Community forum. If you register to participate in our Airship Community forum operated by Discourse, you must create a login and password through the Battel Chasers login page.  We collect your registration information with your consent and use it to provide you with access to the forum. Any Personal Information you include in your forum communications is provided by you voluntarily and with your consent.  Please be aware that your forum communications are publicly viewable by other forum participants, and may be collected, copied, or distributed by other forum participants. Airship does not control and is not responsible for any forum communications or interactions.

·       Your Kickstarter account. If you back Airship via Kickstarter, then Kickstarter collected your identifiers and other Personal Information as described in the Kickstarter Privacy Policy. We receive some of this Personal Information from Kickstarter to manage your reward fulfillment, such as identifiers like your name, address, and email, as well as commercial information like your contribution amount and rewards choices. We collect this information with your consent when you choose to back our project, and we use it to manage the campaign and fulfill your rewards. Please note that your financial contributions are processed through Kickstarter’s PCI-DSS compliance payment processor. Airship does not store nor have direct access to any payment information.

·       Your communications with Airship.  If you contact us to inquire about our games, request support, or for any other reason, we will collect your name, email, and other information as necessary to respond to your communication. If you choose to complete one of our surveys, we will also collect any information you include in your responses. We use this information for the purposes stated at the time of collection, to improve our games and other services, and to communicate with you according to your preferences.

We also collect Personal Information and non-personal information indirectly from:

·       Third Party Gaming Stores and Platforms. If you play one or our games on an online gaming platform, the third-party platform provider may provide Airship with data about your game play, some of which may contain Personal Information. We collect this information to achieve our legitimate interest of developing and improving our games, and we only use it for that purpose. Please contact the third-party platform provider if you have questions about your Personal Information being shared with us in this manner.

·       Cookie Information. Like most websites, the Site uses cookies to enable certain features and help us to improve our online presence. We collect information from these cookies to achieve our legitimate interest of administering and improving the Site and its features. The Site currently uses the following cookies:

 

Airship does not currently use cookies on the Site for marketing, security, or strictly necessary purposes. You can delete cookies that load to your device. You can also change the cookie settings on your device or install a third-party cookie plug-in to block certain cookies or alert when the Site attempts to install a cookie on your device. 

Other Uses. In addition to the specific uses above, Airship might also use your Personal Information to:

·       Monitor your compliance with any of your agreements with us.

·       Protect your privacy and enforce this Privacy Notice.

·       If we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Airship, or to others.

·       Comply with a law, regulation, legal process, or court order.

·       Fulfill any other purpose to which you consent.

Children’s Privacy. The Site is designed for users at least 16 years of age, and we do not knowingly collect Personal Information from children under 16. If we discover that a child under 16 has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information collected online from a child under 16, or if you become aware of any unauthorized submission of information to Airship, please contact us at support@airshipsyndicate.com.

How Long Does Airship Keep My Personal Information?

Airship retains the Personal Information we collect about you only as long as needed to fulfill the purpose for which it was collected. For example, if we collected your Personal Information as a Kickstarter backer or other rewards program, we keep your information until we have fully delivered your rewards. We will delete your Personal Information once your rewards are fulfilled, expired, or if you withdraw from a rewards program. When we no longer have a business need for your Personal Information, we will either delete, de-identify or anonymize it whenever feasible. Where not feasible (such as data in our backup archives) we will securely store it and keep it isolated from further processing until it can be permanently deleted.

Who Has Access to My Personal Information?

Airship discloses the Personal Information we collect to certain third parties for business purposes as described below.

Categories. In the preceding 12 months, all categories of Personal Information collected by Airship may have been disclosed for a business purpose to one or more of the recipients described in this section.

Recipients. Airship may disclose Personal Information to the following recipients:

·       Service Providers. Airship uses a variety of service providers such as data storage providers, analytics services, and email services. The type of information that we disclose to a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.

·       Law enforcement or other government agencies, as permitted or required by law.

·       Cookie information recipients, subject to their respective privacy notices.

·       Other Third Parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

Aggregated and Deidentified Information. We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.

Your Privacy Rights

Airship provides you with the ability to directly control much of the Personal Information we collect and hold about you. You can use the methods described below to control how we collect and use your Personal Information:.

Your Airship Community Forum Account. You can manage your Personal Information related to your participation in the Airship Community forum and your Battle Chasers registration information by logging into your Battle Chasers account and editing our information and settings. You can also manage your communications submitted to the Airship Community forum by contacting Discourse via community.airshipsyndicate.com.

·       Your Kickstarter Account. You can update your Personal Information on your Kickstarter account by logging into your Kickstarter account and editing your information and settings. To edit or delete this information with Airship, please contact us separately and we will make the necessary changes on our systems.

·       Our Mailing List and Other Airship Emails. If you opt-in to our mailing list, you may receive informational or marketing emails from Airship about our games and other services. You can unsubscribe from receiving future emails by clicking the Unsubscribe link found in any of the emails we send you, or by contacting us at support@airshipsyndicate.com to request to be removed from the mailing list.

·       No Player Accounts. Airship does not offer or support player accounts or an online store on the Site. Airship develops games that you can purchase and play through third-party platforms or on a gaming console. Your game purchases and game play are subject to the respective third-party platform’s privacy policy. If you have questions about your game purchase or player account, please contact platform on which you purchased or play the game.

·       Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Policy.

In addition to these general privacy rights, you may have additional privacy rights or be entitled to additional controls over your Personal Information depending on where you reside. Residents of California or the European Union can read more about their additional privacy rights below.

Exercising Your Privacy Rights. If you wish to exercise your rights under applicable privacy laws beyond the above-described methods, or if you want to express concerns, lodge a complaint or request information, please submit a verifiable request to us at support@airshipsyndicate.com or [phone].

We endeavor to respond to a verifiable Consumer Privacy Request within the period required by applicable law. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California Privacy Rights. This section provides residents of the State of California (“California Consumers”) with the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”). The following paragraphs apply solely to California Consumers and describe the specific rights afforded under the CCPA. California Consumers may exercise the rights over their Personal Information as described below, subject to our receipt of a verifiable request and any exceptions or limitations that may apply.

·       Right to Disclosure. You have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months, such as (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; and (iv) the categories of third parties with whom we disclose that Personal Information. Additionally, if a business sells or shares Personal Information, the consumer may request two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Airship is only required to respond to two disclosure requests within a 12-month period.

·       Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Airship is prohibited by law from disclosing copies of certain pieces of Personal Information because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Airship is only required by law to respond to two access requests within a 12-month period. 

·       Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. Airship may permanently delete, deidentify, or aggregate your Personal Information in response to a request for deletion. If you submit a deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.

·       No Selling or Sharing Personal Information. Airship does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out.

·       Limited Use and Disclosure of Sensitive Personal Information. Airship does not use or disclose sensitive Personal Information for the purpose of inferring characteristics about any consumer. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.

·       Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.

·       Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California Consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.

California Consumers may exercise these rights over their Personal Information by following the instructions under Exercising Your Privacy Rights, subject to any exceptions and limitations that may apply. We endeavor to respond to requests from California Consumers within 30 days of receipt. If we cannot comply with part or all of your request, we will explain the reasons in our response.

European Union Privacy Rights. Airship adopted this section to comply with the European Union’s General Data Protection Regulations (“GDPR”). This section applies solely to residents of the European Union (“EU Residents”). Airship operates the Site as a data controller. If you are an EU Resident, you have the following rights in relation to Personal Information we hold about you:

·       Right to know how we process your Personal Information. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.

·       Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals.

·       Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object.

·       Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.

·       Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.

·       Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.

·       Right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.

·       Right to not be subject to Automated Decision-Making (“ADM”). Airship does not use automated decision-making or profiling as part of the Site. If this changes in the future, we will update this Privacy Notice and provide you with an option to exercise your privacy rights related to Personal Information processed using ADM.

EU Residents may exercise these rights over their Personal Information by following the instructions under Exercising Your Privacy Rights, subject to any exceptions and limitations that may apply. We endeavor to respond to requests from EU Residents within 30 days of receipt. If we cannot comply with part or all of your request, we will explain the reasons in our response.

Canadian Privacy Rights. We adopted this section to provide supplemental information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). This section applies solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Information offering details on an identifiable person without the inclusion of name, title, telephone number and business address of an employee of a business or organization. The following paragraphs describe PIPEDA rights and explain how to exercise those rights.

·       Right to know why we collect, use, and distribute the Personal Information we process. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

·       Right to expect us to collect, use or disclose Personal Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Notice and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting support@airshipsyndicate.com.

·       Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. In most cases, we rely on you to ensure that your information is current, complete and accurate.  We provide methods for you to correct, update, and delete inaccurate Personal Information in your account, and we will provide you with reasonable assistance to ensure that your Personal Information is accurate in our systems and with our service providers.

·       Right to access your Personal Information. Upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Information you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.

Canadian Consumers may exercise the above rights over their Personal Information by submitting a verifiable request as instructed under Exercising Your Privacy Rights, subject to our receipt of a verifiable request, as well as any exceptions and limitations that may apply. Airship endeavors to respond to requests from Canadian Consumers within 30 days of receipt unless we have a valid reason for delay, in which case we may take an additional 30 days to respond.

How Does Airship Keep Data Secure?

We implement technical, organizational, and physical measures in place to help protect your information from unauthorized access, processing or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data. We use technical safeguards to protect information online and stored on our systems. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.

Your Account. When you register or create an account with us, you will have a login and password. We encourage you to take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.

Data Transfers. Airship is owned and operated in the United States and is intended for use by players present in the United States. If you access or use the Site from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.

Social Networking. If you access the Site from a social networking website, we may receive Personal Information about you from such social networking website, as governed by the terms of use and privacy policy of that website. We may retain this Personal Information with the information we collect from you by other means. Your use of social networks via a link from our is entirely optional and subject to the privacy policy and terms of use of the social networking website you choose to use.

What About Links on the Site?

This Privacy Notice applies only to information collected by Airship. We may provide links to third-party websites from the Site for your convenience, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. Any access to and use of linked websites is not governed by this Privacy Notice, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites. We encourage you to review and understand the privacy notices of such websites before providing them with any information.

Who Can I Contact with Issues or Complaints?

If you have questions about our privacy practices or would like to make a complaint, please contact us at support@airshipsyndicate.com by mail at 3310 W. Braker Ln STE 330-553, Austin, TX 78758.