We take your privacy seriously at Butterscotch Shenanigans, Inc. ("Bscotch"). We'll do our best to be open and transparent with what information we collect and how we use it.

This website and our products, customer accounts (Rumpus™ and BscotchID®), mobile applications, console or PC applications, and any additional services (collectively "Services") controlled by Bscotch and its affiliates ("we", "our", or "us") are governed by this Privacy Policy ("Policy"). This Policy will explain what information we collect, why we collect it, and how we use it. Additionally, this Policy explains the choices we offer, including how to access and update your information.

If you have any questions about this Policy, please contact us at https://www.bscotch.net/contact/topics/privacy.

By using the Services, you are consenting to this Policy and the processing and storage of your data, including your personal information, in the manner provided in this Policy. If you do not agree with these terms you may not use the Services.

See the Terms of Service for definitions.

Changes

Our Privacy Policy may change from time to time to reflect changes in the law, in our Services, and in our business. We will post any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain Services, email notification of Policy changes).

• Version 2.4.0 (Jan 17, 2019). Updates for Privacy Shield participation.
• Version 2.3.0 (Dec 11, 2018). Tweaks to GDPR-related disclosures.
• Version 2.2.0 (May 25, 2018). Tweaks to GDPR-related disclosures.
• Version 2.1.0 (May 24, 2018). Additional disclosures made to comply with EU General Data Protection Regulation. Pending details for our Privacy Shield application.
• Version 2.0.0 (December 27, 2017). Major overhaul. Many updates in preparation for the launch of the Rumpus service. Updates include language clarification throughout, restructuring of the document, and more information about the kinds of data we collect and what we do with it.
• Version 1.1.0 (November 10, 2016). This Policy, written by real lawyers, entirely replaced our prior privacy policy.

Information we collect

We collect information to provide better Services to you and to improve our business. We collect information in the following ways:

Information you give us

We have access to and may store any information you directly provide when using our Services. Examples include when you use our Services to synchronize data across your devices, or to share content you have created with other users of our Services, or voluntarily submit surveys, and when you provide information while signing up for accounts, newsletters, beta tests, or promotions.

Information provided through a social network.

We may obtain and store information through 3rd party social networking services (such as Discord and Google) when you use them to log into our Services or connect them to your Accounts. We will explicitly inform you about what data we will collect from your social network accounts when you use them in conjunction with our Services.

Information given to us by others

Other users may make information about you available to us. For example, other users might post messages in forums or in messaging services that contain information about you, or send such information directly to us.

Unsolicited information you give us.

While you use our services, or during your interactions with us, you might reveal information to us without us first asking for it. For example, you might share information with other users of our Services (which might then end up being stored by our Services), or an email you send us might include your phone number in the signature.

Information we get from your use of our Services.

We may collect information about the Services that you use and how you use them, like when you visit different parts of our site, when you accomplish feats within our video games, and what selections you make within the Services. We may also automatically collect certain technical information such as:

Device information

We may collect device-specific information (such as your hardware model and operating system version of devices used to access the Services). We will only collect general, high-level device information and will not use that information to identify specific users.

Personal Information

We may collect the following personal information when you use our Services:

• Username. Usernames are often used in our Services to identify you. Usernames and related identifiers may originate from our own Services or from third party services that you opt into connecting to our Services.
• Email Address. Email is the primary way that we contact you, and is the means by which you prove your identity in our Services.
• Password. Some of our Services use passwords as a security mechanism. We store your passwords after using one-way hashing algorithms so that not even we can discover your plaintext passwords.
• Name. Sometimes your real name may be either required (e.g. for certain kinds of customer support) or inadvertently revealed to us (e.g. during correspondence). We will only intentionally store your name if doing so is necessary for our Services, and will inform you in that case.
• Physical Address. We only store your address when doing so is required for our Services or for delivery of our products (e.g. when you buy physical merchandise from our online store). We do not intentionally obtain or store your address without explicit permission.
• Phone Number. We only store your phone number when doing so is required for our Services or for delivery of our products (e.g. when you buy physical merchandise from our online store). We do not intentionally obtain or store your phone number without explicit permission.
• IP Address. Your IP Address is what allows our Services to send information to you. We may store the IP Addresses you use to access our Services to help us identify security issues and bugs in our Services.
• Approximate Geographic Location. We may use your IP addresses to estimate your approximate geographic location. This is only to help us understand where our Services are being used, and we will not attempt to identify your location at any more precision than the level of "country" without your explicit permission.
• Preferred Language. We may ask you for your preferred language, or guess your preferred language based on your device settings or Approximate Geographic Location. We use this information to help guide our business decisions (e.g. into which languages we should translate our Services) and to serve you with content in your preferred language where possible.

Log information

When you use our Services or view content provided by us, we may automatically collect and store certain information in server logs. We use this information to identify issues with and fraudulent or malicious use of our Services. Logs are deleted after 30 days. Log information may include:

• Details of how you used our service, such as your navigation paths and search queries.
• Information about your device, such as hardware and operating system information.
• The IP Address originating requests to our servers.
• Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

User-Generated Content

Some of our Services may include the ability for you to create, store, and sync various kinds of data. Examples include messages and posts sent using our Services, support requests, fan art submitted to us on our website, game save data, and custom game content created in level editors.

Cookies and other Tracking Technologies

To provide full functionality for some of our Services we may use cookies and related technologies (collectively "Cookies").

We collect Cookies for the following purposes:

• Authentication and Security. Cookies store your Account credentials and other information needed to provide functionality to our Services.
• Preferences & Site Features. When you make choices that customize your experience on our Services, we may store those choices in Cookies.
• Analytics & Research. To help us understand how our Services are being used and where there might be technical or other problems.

By using our Services you agree to our use of Cookies. You may opt out of cookies using software-specific settings in your browser, though this may make certain aspects of our Services non-functional.

Email Engagement

We may collect data about your interactions with our email messages, such as if and when you opened those messages and which links you followed from those messages. We use this information to help use decide when to send our emails to you, and to automatically stop sending you emails if you don't engage with them. This lets our Services automatically figure out what email content you want from us.

Other

The Services we offer change rapidly as we add new functionality or change existing functionality. These changes may require changes to what information we need to collect and what that information will be used for. If such changes result in collection of materially different information, we will notify you if appropriate and may also update this Policy.

How we use information we collect

The primary purpose of the information we collect is to provide our Services to you, since the Services' use of your data is synonymous with the function and value that they provide to you.

We use the information we collect from all of our Services to provide, maintain, protect and improve our Services, to develop new Services, and to protect us and our users. We also use this information to offer you tailored content, such as emails containing gameplay advice.

We may use your email address to inform you about our products and Services, such as letting you know about upcoming products or major changes to our Services. You will be able to opt out of receiving such information, either by unsubscribing from a particular type of content or by deleting your Service accounts.

When you contact us, we may keep a record of your communication as well as the other information described in this Privacy Policy to help solve any issues you might be facing.

Please keep in mind that comment sections, forums, shared user-generated content, and other similar areas of our Services are public or partly public. Any information posted in those areas is viewable and usable by anyone that has access, and we cannot control what others do with such information.

Your data we have from your use of our Services is retained for up to 3 years since the last time you logged in unless we are required to hold onto it for legal reasons.

Third Party Operators and Services

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you on the Services, except as required by Privacy Shield and applicable laws. For example, you might use Google to sign into our Services, but our Privacy Policy does not apply to your Google account. Similarly, you might purchase one of our games on the App Store, but our Privacy Policy does not apply to that transaction. We also do not control the privacy policies or your privacy settings on third-party sites, including social networks and the stores selling our digital and physical products.

For further information, please see the relevant privacy policies for each Third Party Operator. For convenience, we have included links to our major Third Party Operators below (this is not an exhaustive list):

• Apple: https://www.apple.com/legal/privacy/
• Google: https://www.google.com/policies/privacy/
• Steam: http://store.steampowered.com/privacy_agreement
• gog: https://www.gog.com/support/policies/gog_privacy_policy
• Amazon: https://aws.amazon.com/privacy
• Humble: https://www.humblebundle.com/privacy
• Facebook: https://www.facebook.com/about/privacy
• Discord: https://discordapp.com/privacy
• Shopify: https://www.shopify.com/legal/privacy

Choice

If we provide you with any mailings or other communication, you can always opt out of that communication. For any communications that are required to manage accounts you have with our Services you may only opt out by deleting the relevant accounts.

You have the right to remove your personal information from our databases. Some data, such as server logs and database backups, may not be directly deletable because of how they are stored, but will expire after a short time (our backups and logs are only stored for up to 30 days). Other information, such as content you have created by using our Services (e.g. a custom level you have created and shared with other users) might not be removed at all but will be anonymized so that the content can no longer be associated with your personal information.

Removal of certain data may require deletion of your accounts. To manage your Rumpus or BscotchID data, including account deletion, visit https://www.bscotch.net/account. For questions related to removal of your personal data you may contact us at https://www.bscotch.net/contact/topics/privacy.

Like many other companies, we do not honor "Do Not Track" flags but instead offer other choices with respect to third parties. Many third parties participate in self-regulation to offer you a choice regarding receiving targeted ads. Please note that you’ll still see generic ads after opting out, but they won’t be based on your activities online. On the web, you can opt out of participating companies by visiting the following sites:

• http://optout.networkadvertising.org/
• http://optout.aboutads.info/
• http://youronlinechoices.eu/ (EU users)

If you wish to similarly opt out of cross-app advertising on mobile devices, you can enable the Limit Ad Tracking flag on the device. Enabling Limit Ad Tracking sends a flag to third parties that you wish to opt out of targeted advertising on that device, and major mobile platforms require companies to honor this flag. Screenshots on how to find these options on various devices are available here:

• http://www.networkadvertising.org/mobile-choices

Accessing and updating your personal information

Whenever you use our Services, we aim to provide you with access to your personal information in your account. You may download your account data at bscotch.net/account. If your personal information is wrong, we strive to give you ways to update it quickly or to delete it unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity (usually via email) before we can act on your request.

To update your Rumpus or BscotchID accounts, visit bscotch.net/account. For any other updates you may contact us at https://www.bscotch.net/contact/topics/privacy. Users subject to the General Data Protection Regulation (GDPR) also have the right to access their data, rectify mistakes, erase their data, restrict certain processing (i.e., opt out), move their data, withdraw consent, and lodge a complaint with a supervisory authority. You will need to prove your identity to exercise these rights. Details on how to exercise these rights can be found at https://www.bscotch.net/support/privacy.

Information we share

We do not share personal information with companies, outside organizations or individuals unless one of the following circumstances apply:

With your consent

We will share personal information with companies, outside organizations or individuals if we have your consent to do so.

For external processing

We may provide personal information to our affiliates or other trusted businesses or persons to process it on our behalf, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. Those trusted affiliates or persons will not be allowed to use that personal information for any other purposes.

For legal reasons

We will share personal information with companies, outside organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, to detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public as required or permitted by law.

In case of a sale or asset transfer

If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, through email and/or a prominent notice provided through the Services.

In aggregated form for business purposes

We may share aggregated, non-personally identifiable information publicly and with our partners such as businesses we have a relationship with, advertisers, or connected sites. For example, we may share information to show trends about the general use of our services.

Bases for Processing

The data we process may qualify for multiple legal bases for processing under the General Data Protection Regulation (GDPR) and similar laws. Below are the primary legal bases for each type of data that we process:

• We obtain consent when you link your social media data, login to our services, join our forums or otherwise create user-generated content, and make purchases (including shipping data).
• We have a legitimate interest to conduct direct marketing, for our HR data, customer service, and for in-game analytics or telemetrics.
• It is contractually necessary for us to collect basic login information (email, user id, password), gameplay data (your progress and achievements), IP addresses, cookies, and similar data to provide you access to ad full functionality of our games and services.

Privacy Shield

Our Services are hosted in the United States. If you are outside of the United States, your information will be processed and stored in the United States and you are consenting to such processing and storage.

When we transfer personal information from the European Union to the United States, we comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

For any questions or complaints regarding our compliance with either the EU-U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework, please contact us at https://www.bscotch.net/contact/topics/privacy. If we do not resolve your complaint, you may submit your complaint free of charge to the panel established by the EU Data Protection Authorities or to the Swiss Federal Data Protection and Information Commissioner, our designated independent dispute resolution providers. Under certain conditions specified by the principles of the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks, respectively, you may also be able to invoke binding arbitration to resolve your complaint. We are also subject to the investigatory and enforcement powers of the FTC. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, the UK, and Switzerland to the US, including the accountability provisions regarding the actions of our data processors. We may be legally obligated to disclose personal information to authorities to meet national security, law enforcement, or other legal requirements.

Information security

We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In addition to our own security, we’ve vetted our data processors to ensure that your data is protected by strong security measures. However no website or storage system is entirely secure, and as such we make no guarantee for the safety of your information stored in associated with the Services. Learn more about our security practices as bscotch.net/security.

Enforcement

We regularly review our compliance with our Privacy Policy and will take complaints and concerns seriously. If we find that we or an affiliate is not acting in accordance with this policy, we will make a good faith effort to fix the problem as quickly as we can. If you believe you have found an issue, submit a report to bscotch.net/contact/topics/privacy with all information pertinent to the issue.

Children Under 13 to 16

This Service is offered and made available only to users meeting the minimum legal age to provide their own consent (e.g., at least 13 years of age in the US and at least 13 to 16 years of age in the EU, depending on the country). If you do not meet the minimum legal age please discontinue using the Service immediately, or if for any reason you do not agree with all of the terms and conditions contained in this Agreement please discontinue using the Service immediately. By using or attempting to use the Service, you certify that you are at least the minimum age and meet any other eligibility requirements of the Service. If you are found to be under the minimum age, your account may be terminated without notice. Please contact us at bscotch.net/contact/topics/privacy if you believe your child has information stored on our Services.