PRIVACY POLICY

Effective Date: April 1 2025

This Privacy Policy applies to Caldera Interactive Ltd. (“Caldera”, “we”, “our” or “us”) services, including but not limited to Caldera applications, our website available at calderainteractive.com, our game currently titled “Rabbit Haul” (“Game”) and any other product or service that we choose to apply this Privacy Policy to (collectively, “Service”), and details how we collect, use, and disclose data, including personal, anonymous and aggregated data, about you (“you” or “your”).

BY CLICKING “I AGREE” OR SIMILAR CONFIRMATION OR BY USING THE SERVICE OR BY AGREEING TO OUR TERMS & CONDITIONS AND/OR END USER LICENSE AGREEMENT, YOU ARE AGREEING TO BE BOUND BY THIS PRIVACY POLICY. 

IF YOU ARE AGREEING TO THIS PRIVACY POLICY ON BEHALF OF AN ORGANIZATION, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND THE ORGANIZATION TO THIS PRIVACY POLICY AND ARE AGREEING TO THIS PRIVACY POLICY FOR THAT ORGANIZATION. WHERE YOU ARE AGREEING TO THE SERVICE ON BEHALF OF AN ORGANIZATION, “YOU” AND “YOUR” REFERS TO THE ORGANIZATION.

1. DESCRIPTION OF THE SERVICE

To provide the Service and for other purposes related to the Service, Caldera may collect, use and disclose certain personal data (personal information). This Privacy Policy describes how we access, collect and use personal data regarding our users, including you.

2. HOW WE OBTAIN YOUR DATA

The Service involves accessing, collecting and processing personal data, which is information about you or that can be used to identify you, as well as anonymous and aggregated data, which does not identify you.

We obtain your personal data directly from you or when you use the Service. Your use of the Service is governed by our Terms and Conditions (“T&C”), which you must agree to in order to use the Service, an End-User License Agreement (“EULA”), as applicable, and this Privacy Policy. If you have any questions or concerns about the disclosure of your personal data, please contact us at your convenience using the contact information found below.

Subject to Caldera’s legal, contractual and technical requirements, you may choose not to provide Caldera with certain data or request the deletion of certain data, which may impact the Service features available to you or essential operations of the Service.

3. PERSONAL DATA WE COLLECT

We collect personal data about you when you access the Service and while you play the Game. The following is a description of the personal data that we collect, use and process in connection with the Service:

• all user IDs associated with your use of the Service, including but not limited to Steam IDs, PSN IDs, Nintendo IDs, Xbox Live IDs, Epic Games IDs, iOS IDs, GOG IDs, as well as any associated login credentials and data (“User ID Data”);

• your full name, email address, telephone number, contact preferences and contact or authentication data, if you choose to provide it when communicating with us, including by consenting to Caldera’s newsletter (“Contact Information”);

• details about your use of the Game and certain Game features, including but not limited to your Game progression and statistics, save state data, challenge and achievement progress, in-game interactions, and track times (“Game Data”);

• cookies and similar tracking technologies to track activities on the Service (“Tracking and Cookies Data”); and

• basic geolocation data, information about your gaming platform, computer, phone, mobile device, web-connected devices or other devices used to connect to the Service including but not limited to, operating system information, operations performed on the device, your computer’s Internet Protocol address (i.e. IP address), browser type and version, time and date of Service use, and unique identifiers and tokens that may identify you over time and across different websites including unique device identifiers (“Usage Data”).

We also collect anonymous data that does not identify you, including but not limited to responses to anonymous surveys and feedback requests, metrics and other types of statistical data, which could be derived from use of the Service and analytical data concerning the Service. Caldera may aggregate and/or de-identify the personal data it collects to share statistics about the Service, including but not limited to aggregated Game Data of users.  

4. PROCESSING AND SHARING OF YOUR PERSONAL DATA

We process your personal data primarily for our legitimate business purposes, such as providing the Service to you, to understand your needs and the needs of our users and to improve the quality of the Service and analyze the data we collect. Specifically, these uses include but are not limited to:

• displaying and delivering the Game and Game content through the Service;

• authenticating users, maintaining and analyzing functionality of the Service, backing up data or testing and researching new features of the Service;

• supporting the security and integrity of the Service and its users including but not limited to detecting and protecting Caldera and other third-parties against error, fraud, piracy, theft and other illegal activity or for contractual, legal, regulatory or audit obligations;

• understanding your needs to improve the quality and reliability of the Service, including providing customer support and feedback, analyzing functionality and technical issues, tracking use of the Service and generating reports and data models that we use to improve the Service;

• investigating improper or suspicious activity; and

• contacting you for various reasons including, but not limited to, user feedback requests or marketing purposes, if you previously consented to being contacted for such purposes and have not withdrawn your consent.

We may disclose your personal data to our parent companies, affiliates, subsidiaries, employees and contractors for the same purposes described above. If permitted by applicable law, we may also disclose your personal data to third-parties, who may be located in a foreign jurisdiction and subject to foreign laws. You may opt-out of your sharing of data with certain third-parties but exercising your opt-out right may impact your use of the Service or the Service features available to you. The situations where we disclose your personal data to third-parties include, but are not limited to:

• processing, storing and analyzing your information as described above as well as providing and enhancing the Service features;

• tracking certain events on the Service, such as user interactions, track times and Game progression and providing it to third-parties such as Steam or Epic to post on leaderboards and achievement listing linked with your User ID Data.

• providing customer support and feedback, analyzing functionality and technical issues, tracking use of the Service and generating reports and data models that we use to improve the service;

• responding to a request from law enforcement or a government that has asserted its lawful authority to obtain the data or where Caldera has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending our rights and the rights of others or providing information to our legal counsel.

5. THIRD-PARTY SERVICES

Except for those third-parties processing your data on behalf of Caldera, this Privacy Policy only applies to personal data that Caldera collects, processes and discloses and does not apply to the collection, processing and disclosure of data by third parties through third-party services, which may be broader than set forth in this Privacy Policy, and that may be embedded into the Service. In many cases, third-parties may collect personal data about a user’s online activities over time and across different websites and services. We strongly recommend that you read each third-party privacy policy carefully before using the Service. Third-parties that may be embedded into the Service include: Microsoft, Playfab, Unity, Steam, GOG, Ghost, Mailgun, Metricool, Epic Games, Sony, Nintendo, DigitalOcean and Google. Please contact us directly using the information found below if you would like to learn more about third-party data practices.

6. COOKIES AND DIGITAL TRACKING TECHNOLOGIES

The Service uses tracking technologies, such as cookies, web beacons and pixels, to collect data about you such as IP addresses and device information. Based on this data, third-parties may be able to resolve your identity across multiple devices, for example, by matching your IP address, in order to target you based on your online behavior. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies. Certain features of the Service may rely on tracking technologies and by declining to accept cookies or by changing certain settings on your device, you may not have access to these features. You have the right to opt-in and opt-out of certain cookies that are not necessary for the operations of the Service, including third-party cookies and may do so directly on the Caldera website or by emailing: admin@calderainteractive.com.

7. OBTAINING, RECTIFYING AND CONTROLLING YOUR PERSONAL DATA

You may contact Caldera to obtain a copy of any personal data we have collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact Caldera to correct inaccurate personal data or to complete incomplete personal data.

You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital:

• for the performance of contractual obligations, such as the T&C and/or EULA;

• to comply with our legal obligations;

• to protect your interests or those of another person; and

• for our legitimate interests or the legitimate interests of a third-party,

and may do so by removing personal data, if the Service permits such removal, or by contacting us using the contact information found below. Caldera has implemented policies and practices to address any requests, complaints or questions you may have about our privacy practices, including the right to appeal decisions Caldera has made regarding the privacy rights you request to exercise.

8. DATA STORAGE, RETENTION AND TRANSFERS

While Caldera is a Canadian company, the data you provide through the Service may be stored and processed by third parties in countries around the world. You authorize Caldera and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal and anonymous data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

Caldera complies with international personal data transfer laws in applicable jurisdictions. For EU residents, Caldera complies with Articles 44-49 of the European Union’s General Data Protection Regulation (the “GDPR”). Caldera also follows UK laws equivalent to what is required by the GDPR for all data collected from UK data subjects. Currently, all transfers of personal data to Canada from residents of the EU are covered by an adequacy decision as described in Article 45 of the GDPR.

Your personal data is retained until you request its deletion or until Caldera no longer requires such data for the purpose for which it was collected or until required to be deleted by laws applicable in your jurisdiction.

9. CHILDREN

Caldera complies with the U.S. Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. The Service is not directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. If we learn that we inadvertently collected personal information from a child under the age of 13, we will delete that information as quickly as possible. If you are a parent or guardian of a child who you believe provided Caldera with personal information without your consent, please contact us at admin@calderainteractive.com.

If you are a resident of the European Economic Area (“EEA”) below the age of consent in your country, Caldera shall comply with applicable consent gathering standards required in your jurisdiction.

10. DO NOT TRACK DISCLOSURE

Do Not Track (“DNT”) is a web or device setting that allows users to request that receivers of personal data stop their tracking activities. When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter to stop tracking your activity. Currently, there are no DNT technology standards and it is possible that there may never be any DNT technology standards. As a result, we do not respond to DNT requests.

11. CALIFORNIA “SHINE THE LIGHT” RIGHT

If you are a California resident, California Civil Code 1798.83 grants you the right to request our disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would like to make this request, please contact us using the contact information set forth below.

Please note that you may only make this request once per year.

12. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.120 permits you to opt-out of the sale or sharing of your personal information to third parties. Caldera does not currently sell your data to third parties without your consent. Although your data is not sold without consent, Caldera provides a general opt-out right to all of our users as described in this Privacy Policy. Note that certain features of the Service may rely on sharing your data with third-parties and by exercising your opt-out right you may not have access to these features. If you have any other questions about our privacy practices or your privacy rights, please email us at admin@calderainteractive.com.

13. LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GDPR

If you are a resident of the EEA, or other jurisdictions in which substantially similar laws apply, such as the UK, Caldera’s legal basis for collecting and using the personal data as described in this Privacy Policy depends on the type of personal data Caldera collects and the context in which it is collected.

Caldera has a legitimate interest, as described in Article 6(1)(f) of the EU GDPR, in collecting your personal data as described in section 3 of this Privacy Policy for the purposes described in in section 4 of this Privacy Policy. The categories of personal data Caldera collects and the legal basis for its processing are set out below:

Contact Information such as emails and other forms of digital communication may also be processed to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. Pursuant to GDPR Article 6(1)(a), Caldera will acquire your consent prior to processing Contact Information.

We may also process your personal data for additional reasons as they become apparent to comply with the law, or if it is in Caldera’s legitimate interests so long as that interest is not overridden by your rights. This can include but is not limited to protecting the Services and you against illegal activity, inappropriate behavior and actions that violate Caldera’s T&C or EULA.

14. EUROPEAN USERS AND RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are a resident of EEA, or if equivalent rights are applicable in your jurisdiction, including the UK, you have certain rights in regard to your personal data. These rights include:

• A Right of Access. You have the right to access your personal data that we hold about you free of charge in most circumstances;

• A Right to Rectification. If your personal data is inaccurate or incomplete, you can change the information you provided by contacting Caldera using the email listed below;

• A Right to Erasure. You have the right to obtain deletion of personal data concerning you in many cases. You may request the deletion by using the contact information found below. Please be careful as the deletion of your data in this manner is permanent and may never be restored;

• A Right to Object. If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to this processing in most cases. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the personal data is necessary for the establishment, exercise or defense of legal claims or in the case where the personal data is required for the provision of certain features of the Service, and you still wish to use such features of the Service;

• A Right to file a Complaint. You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction;

• A Right to Restriction of Processing of your Personal Data. You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR;

• A Right to Personal Data Portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR. Although the personal data collected by Caldera is not particularly useful to other companies as the data collected largely relates to your usage of the Service, Caldera will comply will all requests for the portability of your personal data;

• A Right to Post-Mortem Control of Your Personal Data. If data protection legislation and related regulations in France are applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death in accordance with Article 40-1 of the Act No. 78-17 of January 6, 1978 on Information, Technology, Data Files and Civil Liberties; and

• A Right to Opt-out of Marketing Communications. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link on any marketing e-mails Caldera sends you. To opt-out of other forms of marketing, please contact us using the contact details provided below.

If you are an EEA resident or are entitled to equivalent or similar rights to those listed above and wish to exercise a right, please contact Caldera at admin@calderainteractive.com with the subject line “Exercising Privacy Rights” and a description of the right you wish to exercise and the law under which you are requesting to exercise that right in the body of the email.

15. CHANGE OF OWNERSHIP OR BUSINESS TRANSITION

In the event of, or in preparation for, a change of ownership or control of Caldera or a business transition such as the sale of Caldera or the sale of some or all Caldera’s assets, we may disclose and/or transfer your personal and anonymous data to third-parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

16. SECURITY

We are committed to ensuring that your data is secure. To prevent unauthorized access, disclosure, or breach, we have put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process. Despite our security measures, no electronic transmission can be guaranteed to be fully secure, so we cannot guarantee that hackers, cybercriminals or unauthorized third parties will not be able to defeat our security measures to improperly collect, access, steal or modify your information. You acknowledge and agree that the transmission of personal data to and from our Service is at your own risk and that you should only access the Service from a secure environment.

17. CONTACT PREFERENCES

We communicate with our users primarily through the Service itself, our online forums or through social media, but we may sometimes collect the email address of some of our users in order to respond to support requests or comments. If you have provided us with your email address or signed up for our newsletters and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body or by modifying your email settings within the Service. On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service, including notices of updates to our policies.

18. UPDATES

Caldera reserves the right, in its sole discretion, to modify the Privacy Policy at any time (“Updates”) and shall make Updates available on Caldera’s website. You are deemed to accept Updates by continuing to use the Service. Unless Caldera states otherwise, Updates are automatically effective 30 days after posting on Caldera website.

19. CONTACT US

If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Data Protection Officer at admin@calderainteractive.com or at:

PO Box 68082

RPO Bonnie Doon Shoppers

Edmonton, Alberta, Canada

T6C 4N6