OUR COMMITMENT TO PRIVACY
SCOPE OF POLICY
We own and operate the kleientertainment.com website and various computer games. This Policy applies to our collection, use and disclosure of your personal information in connection with our operation of our website and games. This Policy does not impose any limits on our collection, use or disclosure of the following information:
- business contact information; and
- certain publicly available information.
We have designated a Privacy Officer who is responsible for our compliance with this Policy. The Privacy Officer may be contacted as described below.
When collecting personal information, we will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.
We collect, use and disclose your personal information for the following purposes:
- to provide and administer requested products and services, and to disclose the information for any purpose related to operation of accounts and provision of requested products and services;
- to communicate with you through our website and email;
- to authenticate your identity;
- to monitor your compliance with any of your agreements with us;
- to provide personal information to third party suppliers of products and services;
- to manage or transfer our assets or liabilities, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products;
- to protect us, yourself and others from fraud and error and to safeguard our business interests;
- to collect debts owed to us;
- to comply with legal and regulatory requirements; and
- to distribute to third parties including financial institutions, payment processors, lawyers, financial institutions and government licensing bodies for any of the above purposes.
The above collections, uses and disclosures are a reasonably necessary part of your relationship with us. We may also collect, use and disclose your personal information as follows:
- we may use your personal information to offer additional or alternate products and services to you and may add your personal information to customer lists for this purpose; and
- we may share your personal information with suppliers and third parties so that they may offer their products or services to you.
You may instruct we to refrain from using or sharing your personal information in either or both of the two ways described above at any time by providing written notification to our Privacy Officer. We acknowledge that the sharing of your personal information in either or both of the two ways described above is at your option and we will not refuse you access to any product or service merely because you have told us to stop using or sharing your personal information in either or both of the two ways shown.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you before to such use, and we will seek your consent unless the use is authorized or required by law.
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:
- the information is publicly available, as defined by statute or regulation;
- we are obtaining legal advice; or
- we reasonably expect that obtaining consent would compromise an investigation or proceeding.
Other exceptions may apply.
Your consent can be express, implied or given through an authorized representative. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice. When we receive notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.
LIMITS ON COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION
Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.
We will take due care when destroying personal information so as to prevent unauthorized access to the information.
We may collect non-personally identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. We collect this non-personally identifying information to better understand how our visitors use our site and our games. We may release aggregate non-personally identifying information from time to time, e.g., by publishing reports on trends in the usage of our site or games.
If you are registered user of our site or one of our games and have supplied your e-mail address, we may occasionally send you e-mails to tell you about new games, features or other Klei products or services, or to solicit your feedback. If you send us a request (e.g., through a support e-mail or one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.
If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
SAFEGUARDING PERSONAL INFORMATION
We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us.
Note that confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Please notify Klei’s Privacy Officer in writing if you do not want Klei to communicate with you through these means.
You have a right to access your personal information held by Klei.
Upon written request and authentication of your identity, we will provide you your personal information under our control. We will also give you 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 may charge you a reasonable fee for doing so.
We will make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request.
In some situations, Klei may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of Klei). Klei may also be prevented by law from providing access to certain personal information.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
We will, on request, provide information regarding our complaint procedure.