Joey Drew Studios Inc. (“Joey Drew Studios”, “We”, “Us”) is the creator and owner of the Bendy and the Ink Machine (“BATIM”) video game franchise, and other related products and services. We created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through the Joey Drew Studios websites located at https://www.joeydrewstudios.com/  (collectively, the “Website”), in the course of providing our BATIM online video game, mobile applications, including the Bendy in Nightmare Run and BATIM mobile games (the “Apps”), and through our sales of merchandise products and services, as more particularly described in our Terms of Use (collectively, the “Services”).

The privacy of our users is of great importance to us. By visiting our Website, or using the Apps or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

1.      WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information that is linked to identifiable individuals (“Personal Information”), including those who visit our Website, download our App(s) and use our Services (“Users”). This Privacy Policy does not apply to the practices of companies that we do not own or control, including video game distribution sites (e.g. Steam), online stores that are not affiliated with Joey Drew Studios, and other service providers (“Service Providers”) who market and distribute our Services. Service Providers are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Personal Information.

2.       COLLECTION AND USE OF PERSONAL INFORMATION

2.1   Login and Account Information                                                

When you register for an account to play an online video game or the mobile game, Joey Drew Studios collects your account username and password in order to authenticate your account access and provide you with access to certain Services.  You are not required to register for an account in order to play the game on the App; however, if you do not register for an Account you will be unable to use certain aspects of the Services, such as in-game purchases.

Joey Drew Studios will use the contact information provided to notify users of important information that is relevant to the Services. You may opt out of receiving marketing communications; however, despite your indicated e-mail preferences, we may send you relevant notices where permitted by law.

When you download the the App(s), with or without an Account, we collect your age to allow us to meet our obligations to protect children’s privacy. We do not intentionally collect and Personal Information from individuals under the age of 13 and may require a user to provide credit card details or other Personal Information to confirm that the user is at least 13 years old or has parental consent.

 2.2 In-App Purchases

Purchases made in the App or fees to purchase the BATIM mobile game will be processed by (i) either Apple of Google based on your app store account; or (ii) Shopify if you utilize the Shopify cart feature in the App. We do not collect any credit card or other billing information. Instead purchases will be charged to the credit card or banking account information you have provided to the app store provider or Online Store Provider.

 2.3   Usage Data

Joey Drew Studios may also collect certain information from users of the Website, App and Services, such as Internet addresses, time spent logged into the Services and other usage data (“Usage Data”). This Usage Data is logged to help diagnose technical problems, and to administer our Website, App and Services in order to constantly improve the quality of the Services. If you have an Account, this Usage Data is linked to your Account. If you do not have an Account, this Usage Data may be linked to your device ID; however, we only use your device ID if necessary to help us diagnosis and/or respond to any issues with the Apps or Services.

If there are any technical issues with the Apps, we will collect a “crash report” from your device which includes the type of device and information about your game play to allow us to diagnose and correct any issues with the game.

2.4   Cookies

Technologies such as cookies, beacons, scripts and tags are used by us and our third-party partners. These technologies are used in analyzing trends, administering the Website, tracking users’ movements around the Website, gathering demographic information about our user base as a whole and providing advertising. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers and third-party service providers may offer their own management tools for removing these types of tracking technologies.

Standing alone, cookies do not identify you personally. They merely recognize your browser. However, Joey Drew Studios uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in to the online store or website. This information allows Joey Drew Studios to process online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the Service. Cookies are not used in our mobile Apps.

Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive Personal Information from the Websites and elsewhere on the internet and use that information to provide measurement services and targeted ads. Note that we do not provide any interest-based advertising to individuals under 16 years old. All users can update their advertising preferences through the settings in the App and limit cookies used by their browsers and third parties by updating settings at: http://www.aboutads.info/choices and http://www.youronlinechoices.eu. 

2.5    Mailing List

If you choose to subscribe to our mailing list, Joey Drew Studios will collect your email address in order to send you updates on our products and services. You can unsubscribe from the mailing list at any time.

3.      SECURITY AND STORAGE

3.1 Storage Location

Joey Drew Studios stores its data, including Personal Information, on servers located in Canada and the United States. By submitting any Personal Information or using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and the U.S (including by the service providers and sub-processors listed below). You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those countries under lawful access regimes or court order. 

3.2 Security

The security of your Personal Information is important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information.  For instance, never give out your email account information or password for the Services.

4.      DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

4.1         Disclosure of Statistical Data

Joey Drew Studios may disclose aggregate statistical data to its business partners, who may use the data for to better understand the demographics of our users. This information does not include any Personal Information or otherwise identify any individuals.

4.2     Service Providers and Business Partners

We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third-party companies and individuals employed by us to facilitate our products and services, including the provision of our BATIM App, online store, maintenance services, database management, customer relationship management, web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above). In particular, if you sign up for an Account your App Account Information is shared with Karman Interactive, the company that makes available the BATIM App in order to administer your account and provide you with access to the App. In addition, We use the following service providers: Unity (for user analytics); Shopify (for purchasing items in the game); Tapdaq (to mediate our ad providers); AppLovin, Chartboost, Facebook Audience Network and Vungle (advertising providers); and Playfab and Amazon Web Serivces (data hosting providers).

4.3       Business Transfers

If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

4.4        With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.

5.      RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

6.      ACCESS, CORRECTION AND ACCURACY  

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service.

7.      CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.

8. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”):  

Joey Drew Studios generally processes Personal Information in order to fulfill contracts we have with our customers and to pursue our legitimate business interests listed above. Otherwise, we will obtain consent from an individual in respect of processing of Personal Information. 

Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals who are located in to the EEA and who wish to exercise these rights, should contact Joey Drew Studios using the contact information below. If the inquiry relates to Personal Information collected by one of our Online Store providers or other third parties, you should contact such third party.  Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.

9.      ADDITIONAL INFORMATION

You can help by keeping us informed of any updates to your contact information or other Personal Information.  If you would like to access your Personal Information, if you have any questions, comments or suggestions about our Privacy Policy or practice, or if you find any errors in our Personal Information about you, please contact us at: joey@joeydrewstudios.com

Last Updated: November 1, 2018