Privacy Policy

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY.

WELCOME TO A & S ENTERTAINMENT INC.

WHEN YOU USE ANY ONLINE GAME, SERVICE or WEBSITE FROM A & S ENTERTAINMENT, ITS SUBSIDIARIES OR AFFILIATES (“ASE”, “us”, “our” or “we”) YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.

THIS PRIVACY POLICY IS PART OF THE ASE TERMS OF SERVICE, ACCESSIBLE AT www.aliceandsmith.com/terms-of-service/.

ASE respects your privacy and understands the importance of protecting your personal data. We have adopted this global Privacy Policy, which explains our privacy commitment to our players and users (“User(s)” or “you”). We collect personal data from our Users to support your use of our online games or our games online functionalities, our websites and any other online ASE products and related services (“Services”). We will only collect information we need to fulfill your requests and our legitimate business objectives, while respecting all applicable laws and regulations.

By using any of the ASE Services, including registering for an account, using the game client, any forum or any third party provider allowing you to access our Services, you authorize and agree that ASE may process your personal data according to this Privacy Policy and that you will abide by our Terms of Service. IF YOU DO NOT ACCEPT THE TERMS OF THIS PRIVACY POLICY, PLEASE REFRAIN FROM USING ANY ASE SERVICES.
AES reserves its right to modify this Privacy Policy at any time, so we invite you to review it frequently. If we change our Privacy Policy, we will post those changes to this Privacy Policy or the home page so that you continue to be informed of what data we collect, how we use it, and under what circumstances, if any, we disclose it. Changes or revisions made to our Privacy Policy or to any terms affecting existing ASE Services shall be effective thirty (30) days after posting. Your continued use of our Services will mean your acceptance of the changes to our Privacy Policy.

I. WHEN DOES ASE COLLECT YOUR PERSONAL DATA?

ASE collects and processes your personal data at different times and depending on the Services used. We generally collect personal data when:

• you use a Service,
• you create an account (“Account”),
• you make a purchase within our Services,
• you create user generated content,
• you watch advertisements within our Services,
• you sign up for a newsletter,
• you contact ASE customer service and during technical support sessions,
• you enter into a contest or sweepstakes,
• you chat with other users of the Services,
• you participate in a beta or otherwise download a patch or a demo, or
• you share or otherwise contribute to our social media channels or other community websites.

Whatever the use may be, we will only collect personal data to the extent necessary to provide you with the Services you seek and to fulfil your requests.

II. WHAT IS PERSONAL DATA AND WHAT PERSONAL DATA DOES ASE COLLECT?

As defined in regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May 25th, 2018 (hereinafter, “General Data Protection Regulation”, or “GDPR”), “personal data” means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Any mention of the expression “personal data” or “personal information” in this Privacy Policy refers to this definition.

A. PERSONAL [AND NON-PERSONAL] DATA COLLECTED BY ASE

ASE collects the following data:

• When browsing ASE websites
  Cookies: ASE uses cookies on the Services. A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Cookies are not intended to include people’s names, or other information that is directly identifiable; rather, they are typically used to quickly identify a user’s device and to “remember” things about the user’s visit.ASE may set cookies for your web browser as you visit our websites, use our products, or visit a website where AES provides ads, content or analytics. For example, ASE uses cookies to remember your Account identifier.You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to access certain features of our Services. Each browser is different, so check the “Help” resources for your web browser to learn how to change your cookie preferences. In addition to AES using cookies on our network of websites, AES may allow certain partners to set and access their cookies on your computer.These companies’ use of cookies is subject to their own privacy policies, not the AES Privacy Policy. Please review them carefully. For more information about cookies, please see http://www.allaboutcookies.org. You can see how to opt-out to such cookies (where available) at http://www.allaboutcookies.org/manage-cookies/opt-out-cookies.html.
  IP addresses: ASE may also maintain log files, which contain Internet Protocol (IP) addresses. An IP address is a numeric address that may be assigned to your computer by your Internet Service Provider. In general, we use log files to monitor traffic on our websites and to troubleshoot technical problems. In the event of user abuse of our websites, however, we may block certain IP addresses. If available, IP addresses and console IDs may be used to personally identify you in order to enforce our Terms of Service.
  Other passively collected information: While browsing our sites, ASE may, on its own, or with the help of third party tools, collect non-personally identifiable information concerning your gaming hardware, habits, behaviours and use of our Services. ASE collects such information to better adapt our Services to users’ interests, and for a better quality of our Services.The information collected may contain the following, without limitation: device unique identity, including MAC address, console, mobile, tablet and console unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.We may also receive other personal data from third parties in connection with the operation and distribution of our sites and online products as well as market and demographic studies that we use to supplement personal information provided directly by you. As with all other data, we use this data only for purposes consistent with this policy.When you use ASE’s website, online products or our games, we may collect certain non-personal demographic information including gender, zip code, information about your computer, hardware, software, platform, media, mobile device. We also collect other non-personal information such as feature usage, game play statistics and scores, user rankings and click paths as well as other data that you may provide in surveys, via your account preferences and online profiles or through purchases, for instance. We may also receive either non-personal or public information from third parties in connection with market and demographic studies that we use to supplement personal information provided directly by you.If, at any time, you chose to remove your personal data from our database, you may do so from within the game client, or by emailing info@aliceandsmith.com
• When registering for an ASE Service
  To access certain Services, you will need an ASE Account. During the creation of your Account, we will ask you to provide your user name, password, email address, date of birth (or age) and country of origin. This information is mandatory to create an Account. On other Services, ASE may ask you additional personal information relevant to the Service such as your phone number, home address, or geo-location information (for example, you will be asked your home address when purchasing a product within our online shop, in order for AES to deliver the product to your home address).
• When contacting ASE ASE may ask for your first name, family name, e-mail address and your date of birth to answer your demands to confirm any information related to or transaction made on your ASE account, and to give you information regarding the Services (for instance, if you lose your password or if we make changes to the Terms of Service).
• By participating in contests and sweepstakes
  ASE may offer you the opportunity to participate in online surveys, questionnaires, contests and sweepstakes. To participate, you may need to provide your first name, your family name, e-mail address, date of birth, your address and country of residence. If you choose to participate in contests, sweepstakes, surveys and questionnaires, your personal data may be processed to allow you to participate, and for internal statistical use.
• By interacting on forums
  Whenever you participate or interact with other users on a forum, ASE collects the content of your communications, the time and the location of your activities, as well as your online ID and your IP address.
• Advertisements, analytic metrics tools and other technologies
  ASE uses third party ad-serving technologies that may collect information to provide behavioural and non-behavioral advertisements within our Services. The information collected and used for the targeted advertising may contain the following, without limitation: age and gender, number of views of an advertisement, device unique identifier or other device identifiers and settings, information about your use of the products and Services, other sites (including third party web pages and mobile Internet sites) you have viewed (as well as date and time viewed), advertisement(s) served, the advertisement(s)’ in-game location and length, and your response to the advertisement(s) (if any). The analytics tools and ad serving technologies may use server log files, web beacons, cookies, tracking pixels and other technologies to collect this information, and may combine the information collected on other ASE Services with information collected from other third party websites, products and services and with demographic, advertisement, market and other analytics surveys. Standing alone, this information is not personal data; however, if ASE combines any of this information with personal data, ASE will treat this information as personal data pursuant to this Privacy Policy.ASE makes its best efforts to provide you with the links to our partners’ privacy policies, and when available, instructions regarding how to opt-out from their services.
• When using other third parties’ platforms
  ASE may also collect personal information on third party platforms or services. By playing an ASE game through other third party platforms, or by connecting to such a third party network, platform or service via one of our products and/or Services, you authorize ASE to (1) collect, store, and use, in accordance with this Privacy Policy, any and all personal information that you agreed the third party platform could provide to ASE based on your settings on the platform, and (2) share any and all of your personal information with the other third party platform, through the third party platform’s Application Programming Interface (API). You agree to this sharing when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) one of our applications through an other third party platform or service.
• When you register for, activate and play ASE games
  If you play ASE games on a third-party console, your ID for this console will be disclosed to ASE, in order to let ASE create your ASE Account. You must have an ASE Account in order to access certain online features. From your console, ASE receives your username and your password, your e-mail address, your date of birth, and your country of residence.
• Creation of user generated content
  Some Services give you access to tools in order to allow you to create and/or share unique content. This User-Generated Content may be collected by ASE; this content may also contain your personal information or the personal information of others (for instance, your name, or a picture of you). PLEASE NOTE THAT ASE IS NOT LIABLE FOR ANY NEGATIVE CONSEQUENCES LINKED TO YOUR DISCLOSURE OF USER-GENERATED CONTENT.
• In-game data collection
  Whenever you use the Services, ASE may collect, store and process your in-game data, including but not limited to: your game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.ASE will use this information to improve the Services, to personalize them to your interests, and otherwise upgrade your gaming experience. Any information collected by ASE in accordance with this Privacy Policy may also be used in an aggregated form to identify specific patterns regarding the use of our Services.
• Online payment
  For some Services, you may make purchases, whether you shop on ASE websites or directly in-game. When you do this, you agree that ASE may share your personal data with third parties, companies, or organizations, which may collect and process your personal data in order to make online credit card transactions, deliveries, discounts, and promotional gifts.To make a purchase on ASE store and process your online payment, you may be asked to provide the following information to a payment provider: your first name, your family name, your address, your e-mail address, your country of residence and your banking details, i.e. your credit card number, the name of the credit card owner, the expiration date and security code. This information may be stored in ASE’s premises, or, when pertinent, in the third parties’ premises.Such storage is necessary to allow ASE to manage internal accounts, checking, accounting, compliance, and for legal purposes, in accordance with this Privacy Policy. You may be asked to give your telecommunications provider’s name, your cell phone model, and a valid phone number in order for us to provide you with purchasing instructions directly via your cell phone. For the payment of your in-game purchases, you may find supplementary information in our Terms of Sale, accessible at https://www.aliceandsmith.com/.

IV. WHAT HAPPENS TO THE DATA ASE COLLECTS?

A. HOW ASE USES YOUR DATA

The information you submit through our Services is collected and used by ASE as set out in this Privacy Policy. ASE may also use the submitted information to answer your demands, to send your order confirmations and other information regarding your ASE Account, to send you advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on your preferences. We also use your personal information for our internal marketing and demographic studies, so we can constantly improve the Services we provide you and to better meet your needs.

B. WILL ASE SHARE MY DATA WITH THIRD PARTIES?

ASE does not share your personal information with third parties without your prior consent or as described below:

We may, however, share non-personal data in the aggregate (in a form that does not personally identify you/anonymous information) with advertisers, publishers, sponsors and other third parties.

You may also opt in to allow ASE to share your personal data with companies and organizations that provide products or services that we believe may be of interest to you. In addition, within some of the ASE games, third parties may be given your personal data only for narrative based interactions, such as automated phone calls or sending out email.

ASE may employ third party contractors to collect personal information on our behalf to provide email delivery, product, or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites. When requesting these services, you may be asked to supply your name, mailing address, telephone number and email address to our contractors. We ask some third party contractors, such as credit agencies or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and to better meet our visitors’ needs and preferences.

When our third party contractors collect and/or have access to the personal information you provide to ASE, we require that they adhere to our stated privacy policies and protect the confidentiality of personal information they collect or have access to in the course of their engagement by ASE. These third parties are prohibited from using your personal information for any other purpose without your specific consent.

ASE may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our Site of any change in ownership or users of your personal information.

We may also disclose personal information to law enforcement, or the appropriate civil authorities to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on ASE.

Please note that we may also transfer information that we collect about you to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

V. WHERE IS THE DATA HELD?

ASE utilizes data storage facilities located in Canada and the United States.

VI. HOW DOES ASE PROTECT YOUR PERSONAL DATA?

We take your privacy and the security of your personal information very seriously. To protect your personal information, ASE maintains appropriate safeguards and takes reasonable measures to protect your personal information. However, please note that no existing data transmission method on the web, or electronic storage, can guarantee the absolute security of your personal data.

DESPITE OUR REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA. ASE MAKES NO REPRESENTATIONS THAT YOUR INFORMATION WILL BE PROTECTED AGAINST LOSS, MISUSE OR ALTERATION BY THIRD PARTIES.

Our website may contain advertising or services which link to other websites such as Twitter, Facebook and YouTube. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third party site, including on an advertisement, you will leave the ASE site you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as ASE. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to an ASE site, you should consult that site’s privacy policy before providing any personal information.

VII. FOR HOW LONG DOES ASE RETAIN MY PERSONAL DATA?

ASE will retain your information for as long as needed to provide you the Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

VIII. MINORS

Unless stated specifically to the contrary in a given Service, our Services are not intended for minors. ASE does not knowingly collect or solicit personal information from minors or knowingly allow such persons to use our Services.

IF YOU ARE A PARENT OR LEGAL GUARDIAN AND YOU GIVE YOUR MINOR CHILD PERMISSION TO REGISTER FOR ANY OF THE SERVICES, YOU THEREBY AGREE TO THE TERMS RELATING TO THE USE OF THE SERVICES BY YOUR CHILD.

IX. WHAT ARE MY RIGHTS?

You can access and update the contact information you provided us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by logging in and clicking the Edit Profile section.

Additionally, You have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by ASE, as well as the right of data portability.

You can exercise these rights or terminate your [or any] ASE account by writing to ASE customer support, via the following website : https://www.aliceandsmith.com. ASE will answer your request within a month following the receipt of your demand.

ASE reserves the right to extend this delay up to three months if it deems it necessary depending on the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand.

For any data processing activity requiring your consent (cookies, behavioral advertising…etc), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing.

Finally, you may also address any legitimate complaint regarding our handling of your personal data to the national supervisory authority of your country.

X. CONTACT INFORMATION

If you have any questions or concerns about our data privacy practices, or if you have any requests for resolving issues with your personal information, please contact us at:

A & S Entertainment Inc.
4E-780 Brewster avenue
Montreal, Quebec H4C 2K1
Canada

Email : info@aliceandsmith.com.