Jam & Tea Studios Privacy Notice

Last Updated: September 4, 2024 

This Privacy Notice applies to the processing of personal information by Jam & Tea Studios, Inc. (“J&T,” “we,” “us,” or “our”) including on our website available at https://www.jamandtea.studio/, our games, and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, our “Services”).

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time at our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use our Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

Personal information that you provide to us may include:

• Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, username, email address, and other information you store with your account.

• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information, but we may receive information associated with your payment card information (e.g., your billing details).

• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email.

• Player Feedback. We may contact you to participate in surveys or other forms of player feedback. If you decide to participate, we may collect personal information from you in connection with the survey or other form of player feedback.

• Interactive Features. We may collect personal information that you submit or make available through our interactive features (e.g., messaging features, forums, blogs, and social media pages). Any information you provide using the public sharing features of our Services will be considered “public.”

• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• Device Information. We may collect personal information about your device, such as your Internet Protocol (IP) address, user settings, preference settings, cookie identifiers, other unique identifiers, browser or device information, details about the network and software you’re using, operating system name and version, processing capabilities, manufacturer and model, language and other regional settings, screen resolution and similar settings, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).

• Usage Information. We may collect personal information about your use of our Services, such as the in-game progress (such as game level, score(s), etc.), any inputs you enter in any free form fields during your use of our Services, pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, timestamps, clicks, scrolling, play/browsing times, browsing heatmaps, searches, referral/exit pages, activity and interactions on our Services, including chat logs, performance data about your use of our Services, including problems you may encounter (such as loading errors and response times), and other information about how you use our Services.

• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of our Services.

  • Cookies. Cookies are small text files stored in device browsers.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of embedded code that collects personal information about use of or engagement with our Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties.

For example, if you access our Services using a Third-Party Service (defined below) such as Xsolla, we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of our Services may upload or otherwise provide personal information about others.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide our Services, to improve our Services, to develop new products and services, to operate our business, and to provide you with marketing materials, as described below.

A. Provide Our Services

We use personal information to fulfill our contract with you and provide our Services, such as:

• Managing your information and account;

• Providing access to certain areas, functionalities, and features of our Services;

• Authenticating accounts;

• Answering requests for support;

• Communicating with you;

• Disclosing personal information to third parties as needed to provide our Services;

• Allowing you to register for events;

• Processing applications if you apply for a job we post on our Services;

• Ensuring internal quality control and safety; and

• Debugging to identify and repair errors with our Services.

B. Improve Our Services and Develop New Products and Services

We use personal information to improve our Services and to develop new products and services, such as:

• Improving, upgrading, or enhancing our Services (e.g., patching our games and releasing new features); and

• Developing new products and services.

C. Operate our Business

We use personal information to operate our business, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Carrying out analytics;

• Measuring interest and engagement in our Services;

• Creating de-identified and/or aggregated information;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;

• Auditing relating to interactions, transactions, and other compliance activities;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

D. Marketing

We may use personal information to tailor and provide you with marketing and other content we think may be of interest to you. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

E. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

F. Automated Decision Making

We may engage in automated decision making, including profiling. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

We may disclose any of the personal information we collect to the categories of third parties described below.

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of our Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

• Other Users You Share or Interact With. Our Services may allow J&T users to share personal information or interact with other users of our Services.

• Third-Party Services You Share or Interact With. Our Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
  
  For example, you may need to use a Third-Party Service such as Xsolla to register for an account with our Services.
  
  Any personal information that is collected by, or shared with, a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
  
  Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

• Affiliates. We may share your personal information with our corporate affiliates.

• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES

The privacy choices you may have about your personal information are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to this Privacy Notice).

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly.
  
  Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.
  
  The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
  
  Please note you must separately opt out in each browser and on each device.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

J&T’s processing of your personal information may be supported by one or more of the following lawful bases: