Infinite Victory^™ Game Privacy

This Privacy Policy describes the practices of Bit Fry Game Studios, Inc. (“we”, “us”, “our” or “Bit Fry”) with respect to information we collect from and about users (“you”, “your” or “users”) playing our Infinite Victory™ game (collectively, the “Games”).

This Privacy Policy is specific to the Games as played, except where distinctions are expressly noted, applies to Infinite Victory™. If you are interested in learning about Bit Fry’s practices applicable to the Games played on specific platforms, or to your interactions with us via other channels, including our website, please consult our other published privacy policies applicable to those contexts.

By playing our Games, you acknowledge that you have read and understand the terms of this Privacy Policy. This Privacy Policy may be revised periodically, and any such revisions will be reflected by the effective date above. Please revisit this page to stay aware of any changes. If we make material changes to this Privacy Policy, we will provide you with additional notice of such changes by providing alerts within our Games.

Bit Fry is committed to transparency about its privacy practices.  This section of the Privacy Policy is intended to provide background regarding how privacy and security considerations inform the Games’ design.

Certain game features – resumption of gameplay over time and across devices, multiplayer gameplay and matchmaking, game personalization, and progression tracking – inherently rely on data specific to individual users (such data is defined as “Gameplay Data” in this Privacy Policy).  Like other game developers who offer such features, we need a user identifier in order to match up individual users with their Gameplay Data.  Instead of using persistent identifiers, such as names, email addresses, phone numbers, IP addresses, and mobile device identifiers, that are more susceptible to abuse in the hands of bad actors, we use two types of identifiers that do not have meaning outside the context of the Games:

The first is a “teamPlayerID” available through Microsoft Azure PlayFab. Each teamPlayerID is specific both to the user and to our Games. In other words, each user’s teamPlayerID for our Games is different not only from other users’ teamPlayerID for our Games but also from the user’s teamPlayerIDs for other developers’ games. The second is a universally unique identifier (a “URID”) that we randomly generate for each teamPlayerID.
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Our use of these identifiers is designed intentionally in order to help reduce any privacy impact or security risk associated with gameplay.

In the remaining sections of this Privacy Policy, we describe certain aspects of our data practices in additional detail.

We collect the following types of information from or about users:

Note that requests for user support are handled through our website, www.infinitevictory.com, and the collection of any personal information, such as contact email address, needed to respond to such requests is subject to our website privacy policy available here.

We may share the above-identified types of user data with third parties as follows:

In addition, we may share Metrics and any other aggregated or de-identified user data that cannot reasonably be used to identify any user with our Service Providers and with our licensors, such as the professional sports leagues and players’ associations with whom we partner in order to offer certain content included in the Games.

In addition, we may share user data: (i) with our affiliates or any successor to all or part of our business; (ii) in order to comply with a subpoena, court order, or applicable law; and (iii) in order to protect the rights, property, or personal safety of users, us, or the public.

As used above, “Service Providers” means third parties who perform services (such as data storage and data analytics) on our behalf.

We take reasonable measures designed to protect user data from unauthorized access and against unlawful processing, accidental loss, destruction, and damage.

This section of the Privacy Policy does not apply to aggregated or de-identified user data that cannot reasonably be used to identify you.

We will retain your user data for the duration of your use of or access to our Games.  We may retain your user data for longer as necessary and relevant to our legitimate operations in accordance with applicable laws, such as to resolve any legal proceedings.

After an extended period of inactivity on the relevant Game (2 years for Infinite Victory), and if there are no other reasons why retaining your user data is necessary and relevant to our legitimate operations, we will delete your user data; however, we may create (using a one-way hash function) a fingerprint of that data that allows us, should you choose to reengage with our Games and enable this option, to recover your user data using data stored locally on your device. We will delete this fingerprint upon request.

You have choices with respect to how we collect and use your personal data.

In-Game Permissions: We obtain Permissions before: (i) generating Limited Identifiers that enable us to track your game progress; (ii) collecting and using Gameplay Data that specifically pertains to and enables online gameplay; (iii) collecting and using Gameplay Data that specifically pertains to and enables multiplayer gameplay; and (iv) collecting and using Metrics, which will help us improve our Games, but is not required for any features.  You may decline to grant such Permissions, but doing so may result in the corresponding features (e.g., resumption of gameplay over time and across devices, online gameplay, multiplayer gameplay) not being available to you. You have the ability to review and adjust previously granted Permissions in the Games’ settings menus.

Local Settings: In addition to the user data stored by Bit Fry and our Service Providers, data relating to your gameplay will be stored on your local device. To turn off such storage or to delete such stored data, you must adjust settings on your local device. As a result, however, you may only be able to play in single-player offline mode, and without the ability to resume saved games.

Rights and Requests: You can contact us at any time using the contact information listed in the last section of this Privacy Policy to request we do any of the following:  (i) erase or delete all or some of your user data; (ii) change, update, or correct your user data; (iii) restrict how we use all or some of your user data; (iv) access your user data and, where applicable and feasible, request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what user data we collect, use, disclose, or sell.  We will consider and respond to any such requests promptly and otherwise in accordance with applicable laws.  Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested user data in all situations.  For example, we may not be able to provide the user data requested if it imposes an undue burden or expense, requires us to release confidential commercial information, requires the disclosure of information relating to another person, or requires authentication of the request that is not feasible in light of our design of the Games around Limited Identifiers (defined above).

California residents and European residents should also review the additional information applicable to them in the sections that follow.

Note for California Residents: If you are a resident of California, this section applies to you and supplements the rest of this Privacy Policy.

The California Consumer Privacy Act (“CCPA”) generally gives California residents the rights to: (i) request that we disclose certain information to you about our collection, disclosure and sale of your personal information (“know/access”); (ii) request that we delete your personal information (“delete”); (iii) opt-out of the sale of your personal information (“opt-out of sale”); and (iv) not receive discriminatory treatment by a business for the exercise of your consumer privacy rights conferred by California law.

As described in additional detail above, under “Our Use of Microsoft Azure PlayFab Tools to Limit the User Data We Collect and Store,” our Games are designed intentionally in order to help reduce any privacy impact or security risk associated with gameplay. The user information we collect and use, described above under “Collection and Use of User Data,” is not reasonably capable of being associated with or linked to a particular consumer or householder, and thus does not constitute “personal information” within the meaning of the CCPA.

Thus, while you may, by visiting our Consumer Privacy Request Form located here, or sending an email to privacy@bitfry.com to request the form, submit a request to know/access, delete or opt-out of sale, we do not collect or sell personal information within the meaning of the CCPA.  Should you submit such a request, we may ask you for additional information in order to verify your identify before responding to such requests, but we will use such additional information only for purposes of such verification.  We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).   You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof to us that they are authorized to act on your behalf, and we may also require your authorized agent to verify their own identity.

Note for European Economic Area Residents: If you are a European Economic Area (EEA) resident, this section applies to you and supplements the rest of this Privacy Policy.

While our focus is generally on the United States, insofar as we may from time to time process personal data of individuals in the European Union, Iceland, Liechtenstein, Norway, or the United Kingdom, which processing may be subject to the European Union’s General Data Protection Regulation (“GDPR”), please note the following:

We do not collect Metrics from users who are known to our Service Providers to be below the age of consent for data collection. We do collect and process other information from children in the same ways as for our user base as a whole. The design of the Games allows us to do so in compliance with laws applicable to children’s privacy.

Any comments, concerns, questions, or specific requests relating to this Privacy Policy should be directed to Bit Fry Game Studios, Inc. at privacy@bitfry.com.