PRIVACY POLICY

This privacy policy explains what personal data we collect through our website, why we collect it, and the choices available to you.

This privacy policy (the “Policy”) describes the data protection practices of Spearhead Games Inc. (“Spearhead Games,” “we,” “our,” or “us”) in connection with our website at https://www.spearheadgames.ca/ (the “Site”), and our related social media and community channels (collectively, the “Services”). This Policy does not cover the in-game data practices of the games we develop, which are distributed and operated through third-party platforms (such as Steam, PlayStation, Xbox, and the Epic Games Store); those platforms’ own privacy policies govern data collected during gameplay.

This Policy is made available prior to your use of the Services. By using the Services, you acknowledge that you have had the opportunity to read this Policy and understand that we will process your data as described. If you do not agree with this Policy, please do not use the Services.

Your privacy is not a tradeable asset to us. We do not sell your personal data, and we are not in the business of data monetization. Certain routine operations, such as responding to inquiries, sending newsletters, and improving our Site, do require some data from you and from the third-party service providers we work with.

We act as a Data Controller for the personal data collected through the Site: we determine the purposes and means of processing your data and are responsible for complying with applicable privacy laws in doing so. Where we use a third-party tool (e.g., an email newsletter provider) to process data on our behalf, we remain responsible for that data as Controller; that third party acts only as our Data Processor under its own applicable agreement.

The personal data we collect depends on how you interact with our Site. This may include:

• Identifiers / Contact Data – name, email address, and any other contact details you provide when you sign up for our newsletter, contact us, or apply for a job.

• Career / Employment Data – if you apply for a position with us, we collect the information you submit, such as your résumé/CV, portfolio, cover letter, employment history, and qualifications.

• Communications Data – the content of messages you send us through our contact channels (e.g., info@spearheadgames.ca, press@spearheadgames.ca), and any information you share when engaging with our Discord community or social media pages.

• Commercial Data – we do not currently sell merchandise or other products directly through the Site. If we begin doing so in the future, we (or our payment processor) would collect order and billing information necessary to complete the transaction; payment card details would be handled directly by a third-party payment processor and would not be stored by us.

• Device & Usage Data – automatically collected data such as IP address, browser type, device type, operating system, referring/exit pages, and browsing activity on the Site, collected through cookies and similar tracking technologies.

We do not knowingly collect personal data from children. See Section VIII (Children’s Privacy) below.

A. Information You Provide Directly

• Newsletter Sign-Up: When you subscribe to receive news and updates, we collect your email address.

• Contact & Press Inquiries: When you email us for general information or media/review inquiries, we collect your name, email address, and the content of your message.

• Job Applications: When you apply for a role via our Careers page, we collect your résumé, portfolio, cover letter, and related application materials.

• Community Engagement: When you join our Discord server or interact with our social media pages, we may collect information associated with your account and activity there, subject to that platform’s own privacy policy.

• Purchases: We do not currently sell merchandise or other items through the Site. If this changes, we will collect order and billing details necessary to process the transaction and will update this Policy accordingly.

B. Information Collected Automatically

• Cookies & Similar Technologies: Our website platform may use essential cookies and comparable technologies to operate the Site and remember preferences (see Section VI, Cookies).

• Analytics: We do not currently use third-party analytics or tracking tools (such as Google Analytics) on our Site. If this changes in the future, we will update this Policy.

C. Information From Third Parties

• Social Media & Community Platforms: If you interact with us via Facebook, Instagram, X (Twitter), YouTube, Twitch, LinkedIn, or Discord, we may receive limited information made available by those platforms, subject to your settings and their privacy policies.

• Service Providers: Our website hosting and email providers may share aggregated or technical data with us to help operate and improve the Site.

We use the personal data we collect to:

• Operate, maintain, and improve the Site;

• Respond to your inquiries and provide customer or press support;

• Send newsletters and updates to subscribers, and manage unsubscribe requests;

• Review and process job applications and manage recruiting;

• Process orders, if we begin offering merchandise or digital content for sale through the Site in the future;

• Monitor, secure, and troubleshoot the Site, and prevent fraud or misuse; and

• Comply with legal obligations and enforce our terms.

Where required by applicable law, our legal basis for processing includes: your consent (e.g., newsletter sign-up), performance of a contract or steps prior to entering one (e.g., job applications), our legitimate interests (e.g., Site security and improvement), and compliance with legal obligations.

We do not sell your personal data. We may share personal data in the following circumstances:

• Service Providers – with vendors that support our operations, such as our website hosting platform and email/newsletter provider. These providers are only permitted to use your data to perform services on our behalf.

• Community & Social Platforms – information you post publicly on our Discord server, social media pages, or comments is visible to others and governed by that platform’s own terms and privacy policy.

• Legal & Safety – where required by law, such as in response to a subpoena or other legal process, or where necessary to protect the rights, property, or safety of Spearhead Games, our users, or others.

• Business Transfers – if Spearhead Games is involved in a merger, acquisition, financing, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate confidentiality protections.

Our Site, which is built on a third-party website platform, may use essential cookies and similar technologies to operate core functionality (e.g., remembering your session) and your preferences. We do not currently use analytics, advertising, or other tracking cookies on our Site.

You can control or disable cookies through your browser settings; however, some parts of the Site may not function properly if you do so. If we begin using non-essential cookies in the future, we will request your consent where required by law and update this Policy.

We are based in Canada, and our Site is hosted using third-party infrastructure that may store and process data outside of Canada, including in the United States. Where your personal data is transferred outside of Canada or your home jurisdiction, we take reasonable steps to ensure it continues to be protected in accordance with this Policy and applicable law.

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, including to satisfy legal, accounting, or reporting requirements. For example:

• Newsletter subscriber data is retained until you unsubscribe;

• Job application materials are retained for the duration of the recruitment process and a reasonable period afterward, in case the role or a similar one becomes available, unless you ask us to delete it sooner; and

• Contact inquiries are retained as long as needed to address your request and for our records.

Our Site is intended for a general audience and is not directed at children. We do not knowingly collect personal data from children under the age of 13 (or the relevant age of digital consent in your jurisdiction) through the Site. If you believe a child has provided us with personal data, please contact us at info@spearheadgames.ca and we will take steps to delete it.

Depending on where you live, you may have rights regarding your personal data, including the right to:

• Know what personal data we hold about you and how it is used;

• Access a copy of your personal data;

• Correct inaccurate or incomplete personal data;

• Request deletion of your personal data, subject to certain exceptions;

• Object to or restrict certain processing (e.g., withdraw consent to marketing emails); and

• Receive your data in a portable format, where technically feasible.

Canada (PIPEDA)

If you are located in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) gives you the right to access and request correction of your personal information, and to know how it is being used or disclosed.

European Economic Area / United Kingdom (GDPR)

If you are located in the EEA or UK, the General Data Protection Regulation (GDPR) or UK GDPR may give you the additional rights described above, including the right to lodge a complaint with your local data protection authority.

California (CCPA/CPRA)

If you are a California resident, you have the right to know, access, delete, and correct your personal information, and the right to opt out of the sale or sharing of personal information. We do not sell or share personal data for cross-context behavioural advertising as those terms are defined under the CCPA/CPRA. We will not discriminate against you for exercising your privacy rights.

How to Exercise Your Rights

To exercise any of these rights, please contact us at info@spearheadgames.ca. We may need to verify your identity before processing certain requests. We will respond within the timeframe required by applicable law.

Our Site links to third-party platforms we do not control, including Discord, Facebook, X (Twitter), Instagram, YouTube, Twitch, and LinkedIn, as well as game distribution platforms such as Steam, PlayStation, Xbox, and the Epic Games Store. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with personal data.

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

We may update this Policy from time to time. Any changes will be posted on this page with an updated “Last Updated” date. If we make material changes, we will take reasonable steps to notify you, such as by posting a notice on our Site.

If you have questions about this Policy or how we handle your personal data, please contact us at:

Spearhead Games Inc.
160 Rue Saint-Viateur, Unit #300
Montréal, QC H2T 1A8, Canada
Email: info@spearheadgames.ca

You also have the right to contact your local data protection authority, including:

• Canada – Office of the Privacy Commissioner of Canada (OPC)

• EEA – your local Data Protection Authority

• United Kingdom – Information Commissioner’s Office (ICO)