Privacy Policy
Last updated: January 18, 2024
Welcome to Reflection Games!
This Privacy Policy for Reflection Games (also referred to as “we” or “us” or “our”) describes how and why we might collect, store, use, and share your information when you use our Services (described below). The data controller is Reflection Games, Inc. with a registered address at 5001 25th Avenue, NE, Suite 200, Seattle, WA 98105.
If you apply for a job with us, this Privacy Policy does not apply to you. You will be given an applicant privacy policy during your application process.
Please read this entire Privacy Policy. You should also carefully review any other agreements that apply to the Services that you use, including our Terms and Conditions, and confirm that you understand and agree to them, before using our Services.
In this Privacy Policy you will find:
1) Our Services
2) Ways We Collect Your Information
3) How We Use Your Information
4) Disclosure of Your Information
5) Security of Your Personal Data
6) Retention of Your Personal Data
7) Transfer of your Personal Data
8) Your Rights and Choices
9) Children’s Privacy
10) Links to Other Websites
11) Changes to this Privacy Policy
12) Contact Us
13) Supplemental Information for Certain Jurisdictions
1) Our Services.
We use the term “Services” to describe any products and services that directly link to this Privacy Policy, such as when you:
· visit our website www,reflection.games, or any website of ours that links to this Privacy Policy, whether on your computer, tablet, or mobile device;
· download, access, or use our mobile applications (such as Mutant Forge);
· interact with us in other ways, such as through our customer service, marketing and advertising activities, social media, other platforms or third parties, events, community channels, or chat rooms;
· purchase our physical or virtual goods and merchandise; or
· access any other services that we will provide to you from time to time.
2) Ways We Collect Your Information
When you access our Services, the information we collect depends on how you interact with us, the choices you make, and the products and features you use. The main ways we collect information are through: A) information you provide to us, B) information we automatically collect, C) information from third party; and D) information collected to prevent fraud and cheating. “Your information” as used in this Privacy Policy refers to any information that we have about you, including your Personal Data and non-identifying information. “Personal Data” means any information that relates to an identified or identifiable individual. Please note that we combine some or all of the information that we have about you.
A) Information You Provide to Us
You provide us with information when you use the Services, such as when you:
· create an account
· subscribe to marketing and communications
· communicate with us directly or through third parties
· comment on our message boards, forums, chat rooms, feeds, sites, or other mediums
· purchase or redeem one of our Services, including physical items, virtual items, virtual currency, or add-ons
· download, install, or access demos, programs, or other software
· contact us or our third party providers for support or other purposes
· use our email or share features
· participate in events, contests, promotions, surveys, or playtesting
· participate in an activity where you provide your information
· provide access to your pictures, contact list, social media profiles, etc.
When you provide us with your information, including any Personal Data, we collect and use this information as set forth in this Privacy Policy. Depending on the Services you access and your activities, the information you provide to us may include:
· your name
· player name
· user ID
· player profile
· profile picture
· email address
· phone number
· user profile
· photo
· mailing address / zip code
· payment or purchase information
· age
· gender
· password
· platform ID
· user ID
· preferences
· interests
· survey data
· product data
· location
· responses, requests, or comments
· contacts or friend list
· the systems or platforms you play on
· any other information you provide to us
In some instances, when you make purchases on or through our website or applications, we will collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by us. Unless otherwise stated we do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful. When you purchase items in our mobile apps through for example, the App Store, Facebook, or Google Play or you purchase and redeem gift vouchers for our games, we do not collect or store any payment information from you.
B) Information We Automatically Collect
We collect some information automatically when you visit, access, or use the Services. This collection may be done by us or through our third party providers and partners. While the specific types of information that we automatically collect may vary, they generally include:
Usage information and statistics about how you interact with the Services, including the application you used or the game you played, how long you used or played it and when, gameplay attempts, progression and results, rewards, saved preferences, crash reports, the URLs of websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, and other diagnostic data;
Technical information about your computer, device, hardware, or software you use to access our services, such as IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and
The general location of your device, which we typically derive from your device’s IP address.
This information is automatically collected in a variety of ways, including through the use of software applications and programs and through tracking technologies.
We and our third party providers and partners use tracking technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above (generally referred to as “Cookies”). This information is used to personalize and enhance our Services and your experience with us, conduct data analytics, provide you with targeted advertisements, promote our Services, measure the effectiveness of our marketing or other campaigns, facilitate payments, detect fraud or cheating, and collect information about how you use our Services and the services of our third party providers and partners. Some of these technologies may create small files or record-keeping tools that may be stored on your device. Some of these technologies can synchronize behavior across different mobile applications, devices and websites so that advertisements can be tailored to you. For additional information about our use of Cookies, go to HERE.
You may be able to control the information we automatically collect about you through your device browser by changing the settings to refuse or disable Cookies. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your choice to disable Cookies is specific to the particular browser or device that you are using when you disable Cookies, so you may need to separately disable Cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Services may no longer be available to you.
Please note that, while your browser settings may allow you to transmit a “Do Not Track” signal when you visit the Services, our Services (including apps and websites) are not configured to respond to “Do Not Track” signals received from browsers.
C) Information from Third Parties
Our Services offer you the ability to register and log in using third parties. When you interact with us this way, we may receive information about you from those providers. Examples of these third party sources include: Google Play, Apple Game Center, Facebook, Instagram, Twitter, and LinkedIn. If you decide to register through or otherwise grant us access through a third party service, we may collect information that is already associated with your account such as your user ID, profile picture, display name, device and region information, name, email address, user activities, your contact or friend list, or other information you choose to make public or provide these platforms. You may also have the option of sharing additional information with us through these or other third parties. If you choose to provide such information during registration or otherwise, you are giving us permission to process, share, and store it in a manner consistent with this Privacy Policy. For additional information about these third parties refer to HERE.
D) Information to Prevent Fraud and Cheating
We use a variety of technologies, programs, and services to collect information designed to detect, prevent, or respond to fraud or cheating. This includes the collection of information about you, your computer, the software on your computer, and any other information available to us or our third parties that may serve this purpose. This information collection may be done by us or by third party service providers such as BattlEye.
3) How We Process Your Information
We process your information to:
· provide and administer the use of our Services
· improve and customize our Services and other offerings, including through third parties
· create, manage and maintain your account
· contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications
· contact you or interact with you through third parties
· provide you with news, special offers and general information about goods, services and events which we offer
· respond to your requests
· advertise and promote our Services and to measure the effectiveness of those advertisements and promotions
· identify usage trends
· determine the effectiveness of our promotional and marketing campaigns
· evaluate and improve our Services, marketing and advertisements and your experience
· send you information, such as updates, security alerts, and support messages
· enable you to communicate with other players
· run contests, events, and community forums
· manage alpha, beta or early access tests
· prevent cheating, crime, hostile or abusive behavior, or fraud
· evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information about our users is among the assets transferred
· comply with legal or contractual obligations
· comply with privacy regulations, including the use of your age to comply with applicable local regulations
We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this Privacy Policy. Please note that this Privacy Policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.
4) Disclosure of Your Information
We describe the ways in which we share information below.
· Service providers and business partners. We may share your personal information with service providers and business partners to monitor and analyze the use of our Services, to show advertisements to you, to market us or other products to you, to offer promotions or other services, to advertise to you on third party websites, for payment processing, or to contact you. Click here for additional information about our third parties.
· Business transfers. We may share or transfer your information, including your Personal Data, in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
· Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
· Third Party Game Developers. We may work with third party game developers and may share your technical data and other data with such third party game developers to, for example, facilitate the provision of the Services.
· Other users. When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third party service, your contacts on that service may see your name, profile, pictures, description of your activity, game statistics, rewards, or other information you share. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
· Public. Your gaming information may be shared publicly. For example, your display name, content you create or share, game statistics and other similar information may be generally accessible to others.
· Authorities: we may be required to disclose your information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
· Your consent: We may disclose your personal information for any other purpose with your consent.
· Other Third Parties. We may share information that does not identify you with third parties
Additionally, we may disclose your information in the good faith belief that such action is necessary to:
· Comply with a legal obligation
· Protect and defend our rights or property
· Prevent or investigate possible wrongdoing in connection with the Service
· Protect the personal safety of users of the Service or the public
· Protect against legal liability
We will occasionally include links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check these policies before submitting any information to these sites.
5) Security of Your Personal Data
The security of your Personal Data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. Therefore, be sure to consult the security measures adopted by third parties in their respective privacy policies.
6) Retention of Your Personal Data
Unless the law specifies a different retention period, we will retain your information for as long as is necessary for the purposes set out in this Privacy Policy. We will also retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We aggregate or anonymize your Personal Data and use it in a way that is designed to be unable to identify you, for research or other purposes, to the extent allowed by applicable law.
7) Transfer of Your Personal Data
Your information, including Personal Data, is processed at our operating offices and in any other places where the parties involved in the processing are located. This means that your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data.
8) Your Rights and Choices
Subject to the applicable laws and regulations, you may have the following data protection rights. To exercise any applicable rights below or to exercise any other statutory data subject rights you may enjoy under applicable laws and regulations, you may contact us using the contact details under the “Contact Us Information” section below.
To protect the security of your account and your Personal Data, we may ask you to provide certain additional information before we respond to your requests. Under some circumstances, we may refuse to comply with your request, as permitted by law.
A) Right to Access. You may have the right to access your Personal Data that we hold about you, i.e. (i) information whether your Personal Data is collected or disclosed, (ii) categories of your Personal Data which has been collected or disclosed, (iii) categories of sources from which your Personal Data is collected, (iv) business or commercial purpose for collecting or disclosing your Personal Data (if any); and you have the right to require us to provide a duplicate of your Personal Data undergoing processing, subject to submitting a verifiable request to us using the contact information in section “Contact Us” below.
B) Right to Rectify. If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up to date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you may have the right to request for rectification of your inaccurate Personal Data according to applicable laws and regulations and you can modify the information through in-game settings or contact customer service.
C) Right to Request Deletion of Personal Data. You may have the right to request the deletion of your Personal Data, if the reason as stated in this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request to the contact details under the “Contact Us” section below. You acknowledge and agree that as a result of deleting your account, you will lose access to game-related services, including the account information, subscriptions and game-related information linked to such account and lose the possibility to access other services through the account.
D) Right to Opt-out of Marketing Communications. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing messages we send you.
E) Right to Complain. You may have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority where applicable.
F) Right to Withdraw Your Consent. If we have collected and processed your Personal Data with your consent, you can withdraw your consent in accordance with applicable laws. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent. In many circumstances, we need to use your Personal Data in order for us to provide you with our Services, which you require. If you do not provide us with the required Personal Data, or if you withdraw your consent to our use and/or disclosure of your Personal Data for these purposes, it may not be possible for us to continue to serve you or provide you with the Services that you request or require.
Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.
9) Children's Privacy
Generally, our Services are not directed to children under 13 (or older, if applicable law provides for different protections, “Minor(s)”), and we do not knowingly collect personal information from Minors. By using the Services, you represent that you are not a Minor or that you are the parent or guardian of such a Minor and consent to such Minor’s use of the Services. If we become aware that a Minor has provided us with Personal Data without a parent’s permission, we will promptly delete such information from our records. If you become aware of any Personal Data we may have collected from a Minor please Contact Us.
Certain services may be accessed by audiences of all ages—including Minors. For these Services, we may:
· restrict the collection of personal information
· limit the processing of Personal Data to only what is necessary to support the internal operations of our Services
· limit the Minor’s access to certain features, such as social media, chat features, or certain notification alerts,
· apply an age gate allowing children to use the Services
· get a parent’s permission to collect personal information from Minor
We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet
10) Links to Other Websites
Our Service may contain links to other third party websites, online services or mobile applications and may contain advertisements from third parties that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
11) Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
12) Contact Us
If you have any questions about this Privacy Policy, you can contact us:
By email: Privacy@reflection.games
By visiting this page on our website: www.reflection.games/privacy
By phone number: 206.420.2386
By mail: 5001 25th Ave NE, suite 200, Seattle, WA 98105
13) Supplemental Information for Certain Jurisdictions
Residents of the European Economic Area, The United Kingdom, and Switzerland please click HERE for additional information regarding your privacy.
If you are a resident of California, please click HERE for additional information regarding your privacy.