Welcome to the Signs of the Sojourner Privacy Policy.

We ask that you read this privacy policy carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities.

1. Who we are

Echo Night Games, LLC (“Echo Night Games”, “We”, or “Us”) collects, uses, and is responsible for certain personal information about you, as part of the Signs of the Sojourner video game software application and the related Echo Night Games website (together, the “Service”).

For those in the European Union, we are regulated under the General Data Protection Regulation (“GDPR”) which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.

2. The Personal Information We Collect and Use

Information collected by us: In the course of providing you with the Service, we collect the following personal information when you provide it to us or use the Service:

• Your email address is collected when you sign up for our mailing list on the Service or contact us for technical or customer support. Also, when you contact us for support or other reasons, we may collect your name (collectively, this is your “Contact Information”).
• Your gameplay behavior, device ID, and IP Address are collected automatically when you use the Service (your “Usage Information”).
• Any information you share on the Service’s chat functionality, provided through Discord (your “Posts”).

Information shared with us: In the course of providing you with the Service, others may share the following data with us:

• We use Google Analytics on parts of the Service, which shares information about your browser type, access times, pages viewed, IP Address, and activity just before and during your use of the Service with us (your “Analytic Information”). You can read more about this collection and sharing, as well as your ability to opt out, below in the section entitled “Cookies and other Usage Information.”
• If you make a purchase on the Service (such as purchasing the Signs of the Sojourner game), our payment processor will share information about your purchase, including your full name, billing address, and purchase history, so that we can properly credit you and provide you with any purchases on the Service (your “Purchase Information”). This payment processor may be the platform on which you made the purchase, or a third-party processor that we engage to process payments for us.

How we use your personal information: We use your personal information as follows:

• Your Contact Information is used to send you newsletters and promotional materials, to communicate with you about Service-related issues and provide customer and technical support (including receiving and responding to communications that you send us through the Service).
• Your Usage Information and Analytic Information is used to ensure the proper operation of the Service on your device and to analyze and improve the Service. To achieve this, we may make your Usage Information and the Analytic Information non-personally identifiable in aggregated or anonymized form, by either combining or aggregating it with information about other users, or by removing characteristics (such as your IP address) that make the information personally identifiable.
• Your Purchase Information is used to process purchases made on the Service, keep records of those purchases, and to ensure that those purchases are properly credited to you.

Who we share your personal information with: We share your personal information with certain third parties in operating the Service. This data sharing enables us to provide you with all of the Service’s functionality.

Some of those third party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.

We share your personal information with the following third parties:

• Newsletters: We use MailChimp to manage our newsletter and other communications related to the Service. You can view MailChimp’s privacy policy here.
• Analytics: We may use Unity Analytics on the Service, that employ cookies and other tracking methods (such as tracking pixels) to collect certain information concerning your use of the Service, including the Usage Information described above. You can view their privacy policy here.
• Chat: We use Discord to provide chat functionality for the community. Any Posts you make will be shared with Discord and with anyone else using the Service’s chat functionality. You can view Discord’s privacy policy here. Please be aware that when you disclose any information in on any public chat rooms, you do so at your own risk.
• Other Sharing: In addition to the above, we will share your personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Echo Night Games, its employees, clients, or users of the Service.

We will not share your personal information with any other third party.

How long your personal information will be kept: We will keep your personal information for the length of time required to provide you with the Service or until you request its deletion, unless a longer retention period is required by law. Afterwards, we delete all such data in our possession within a reasonable timeframe.

We do not verify the correctness of personal data that we collect or that you provide.

Please note that some data may be retained, if necessary, to resolve disputes, enforce Echo Night Games service agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.

Reasons we can collect and use your personal information: The laws in certain jurisdictions require that we notify you of the lawful basis for collecting your personal information.

To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:

• Consent: We rely on your implied or explicit consent for the collection, processing, storage, transfer, and disclosure of your Contact Information and Posts.
• To fulfill our contractual obligations: In order to fulfill our contractual obligations to you, either in providing the Service functionality or processing payments and fulfilling the associated purchases, we must collect, process, share, and store your Payment Information, Usage Information, and Analytic Information.
• Furtherance of legitimate interests: We may collect, process, store, transfer, or disclose your Usage Information, Analytic Information, and Purchase Information in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing you with the Service, (ii) protecting our users, staff, and property from fraud and other harm, and (iii) collecting information on how you use the Service in order to optimize the functionality of the Service.
• Legal compliance: We may collect, process, store, transfer, or disclose your Contact Information, Usage Information, Analytic Information, and Purchase Information to comply with our legal obligations.

Children’s Privacy: You must be at least 13 years of age to use the Service. Because of this, we do not knowingly collect any personal information from children under the age of 13. In addition, we may limit how we collect, use, and store some of the personal information of EU users between 13 and 16.

Cookies and other Usage Information: “Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Service to allow us to provide information to make your online experience more convenient and to enhance your experience with the Service. Cookies are not spyware or adware, and can’t deliver viruses or run programs on your computer. A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set.

We also employ third party tracking utility software technology called clear gifs (a.k.a. Web Beacons/Web Bugs) and tracking pixels. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. In short, clear gifs enable two websites to share information with one another. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel.

We use these technologies on the Service for the purpose of tracking users of the Service for marketing purposes, as follows:

• Google Analytics: We use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, US. On an anonymous basis, Google will analyze your use of the Service on our behalf. The information collected by Google in connection with your use of the Service will be transmitted to a server of Google in the United States, where it will be stored and analyzed.

The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address, or any other personal information, during this process. Google’s collection and use of information is subject to Google’s Privacy Policy. If you would like to opt out of Google Analytics tracking, please visit one of the following links:

• Google Ads Settings (http://www.google.com/settings/ads),
• the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/), or
• NAI’s consumer opt-out (http://www.networkadvertising.org/choices/).

“Do Not Track” Signals: Because there’s not yet a consensus on how companies should respond to web browser-based or other “do not track” mechanisms yet, we do not respond to web browser-based do not track signals.

3. Transfer of your Information out of the EEA

Echo Night Games is based in the United States. No matter where you are located, you consent to the processing, transfer, and storage of your information in and to the United States.

The laws the United States governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

If you would like further information, please contact us (see “How to contact us” below).

4. EU Residents - Your Rights

Under the GDPR, EU residents have several important rights free of charge. In summary, those include the rights to:

• Fair processing of information and transparency over how we use your use personal information
• Access to your personal information
• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal information concerning you in certain situations
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• Object at any time to processing of personal information concerning you for direct marketing
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• Object in certain other situations to our continued processing of your personal information, or otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the GDPR.

If you would like to exercise any of those rights, please:

• Email us at support@echodoggames.com or use a contact form on the Service
• Give us enough information to identify you, including your username, name, and date of birth
• Show us proof of your identity (a copy of your driving license or passport, for example)
• Let us know the information to which your request relates

If you would like to unsubscribe from any email newsletter, you can also click on the unsubscribe button or link at the bottom of each email newsletter.

5. Keeping Your Personal Information Secure

We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it through access controls. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

Additionally, we never ask you for your passwords and we advise you never to enter your account name or password into an email or after following a link from an email.

Lastly, we also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

6. How to Complain

We hope that we can resolve any questions or concern you raise about our use of your personal information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.

If you are an EU resident, the GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

7. Changes to this Privacy Policy

This privacy policy was published on May 24, 2019 and last updated on May 24, 2019.

We may change this privacy policy from time to time. When we do, we will inform you via email if you have provided an email address, or through the Service itself.

8. How to Contact Us

Please contact us if you have any questions about this privacy policy or the information we collect and store from you.

If you wish to contact us, please send an email us at support@echodoggames.com or mail us at our physical address at P.O. Box 261006, Los Angeles, CA 90026.