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SINN STUDIO PRIVACY POLICY

Last modified: July 2024

INTRODUCTION

This Privacy Policy (“Policy”) describes the policies of SINN STUDIO INC., a corporation under the provincial laws of Ontario (“Sinn Studio,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of your personal information and non-personal information while using and interacting with our website sinnstudio.com (“Website”) the game SWORDSMAN VR (“Game”), or our Discord channel (collectively known as the “Services”).

We value your privacy and are committed to protecting your personal information. Please read this Policy carefully to understand our practices regarding your privacy. Please note that this Policy may be updated from time to time. If such updates are made, we will notify you through a notice on our Website home page (https://sinnstudio.com/). You are responsible for periodically visiting our Website and this Policy to check for any changes or updates.

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This Policy describes:

● The types of information we may collect or that Services or Game users (“you”) may provide when using and interacting with our Services.

● Our practices for collecting, using, maintaining, and protecting that information.

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We will only use your personal information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

We have developed our Policy in compliance with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and the Substantially Similar Provincial Privacy Laws including Alberta’s Personal Information Protection Act (Alberta PIPA), British Columbia’s Personal Information Protection Act (BC PIPA), and Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Quebec Act).

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This Policy is also compliant with the European Union’s (EU) General Data Protection Regulation (GDPR). We want to ensure that you can make informed decisions about any data that we may collect from you.

The GDPR defines "personal data" as any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly, or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The terms personal information and personal data maybe used interchangeably throughout this Policy.

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This Policy DOES NOT apply to information that:

● We collect offline.

● Through websites you may access through the Services or Game including third-party websites or platforms such as those hosted and provided by Steam, PlayStation, Meta, Microsoft, Discord, etc.

● You provide to us or is collected by any third-party, except that which is referenced explicitly herein.

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COLLECTION OF INFORMATION

While using our Services, we may collect and store non-personal and non-identifiable information for analytical purposes, such as:

Website:

● Traffic Data

● Session Statistics

● Approximate Geolocation

Swordsman VR:

● Platform Usernames, User ID, or User Profile

● Gameplay Statistics

● Device Information (e.g., device model, operating system version)

● In-game Preferences

Additionally, we will be releasing a new feature in Swordsman VR that will allow us to improve our AI systems. This will involve collecting anonymized data that are grouped into data sets as random strings of numbers and characters that cannot be linked or traced to any particular individual. This will allow us to determine how users are striking and interacting with AI opponents so that we can design better and more challenging AI opponents, improving the overall quality and experience of gameplay for users. We note that this information is strictly anonymized and does not identify or reveal to us the identity of any user.

We do not collect or otherwise process any personal information or data (whether yours or that of any other person) solely from your use of the Services or Game.

There may be times when we do collect identifiable information from you through a fillable contact form found on our Website or through your email submissions to us or through third-party services such as Microsoft Azure PlayFab or social media platforms such as Discord. Please note that such information is provided by you voluntarily, and that you have the right to opt-in and opt-out of such third-party services. Examples of information that may be collected include your names, email addresses, username, city, and country.

If you do not want us to collect this information, you have the right to not opt-in to the use of third-party services, of which you may easily opt-out of if you have already opted-in. You also have the right not to use our Services or the Game.

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How We Collect and Use Your Information

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We collect information directly from you:

• When you voluntarily provide information through our website’s contact form.

• When you play or interact with the Game.

• When you submit a support ticket, we may collect your email address, and records of your correspondence

• When you send us an email.

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We use the information that we collect about you to:

● Deliver, manage, repair, and improve the Game for legitimate reasons, including to train our AI systems to improve combat and overall quality of gameplay and experience.

● To improve the gameplay and experience by posting your Platform Usernames or User ID on Swordsman leaderboards.

● To contact you (if you have completed and submitted a contact form on our Website or have sent us an email).

● To present our Website and its contents to you.

● To send you newsletters and updates.

● To respond to your email queries.

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Information We DO NOT Collect

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Swordsman VR:

While using our Game, we DO NOT collect or use any personal or identifiable information. This includes personal or identifiable information such as your:

● Name

● Mailing Address

● Email Address

● Telephone Number

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Third Parties

We may receive your personal information from or through third parties that help us provide or facilitate your access to the Services. For example we may receive your personal information from the below third parties:

Microsoft Azure PlayFab: If you opt-into our leaderboards feature.

• We may receive your PlayFab ID

• Username

• City and/or country location

Discord: If you are a participant on our Discord channel

• Discord username

• User ID

• Information you share publicly on our Discord channel

Although we follow this Privacy Policy with respect to any personal or non-personal information provided to us by the above third parties, we cannot control how such third parties collect or use the personal information. We urge you to review the third parties’ respective privacy policies for more information on their collection and use of personal information.

• Microsoft Azure PlayFab

• Discord

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SECURITY

We are deeply committed to the security of your information and data. With an appreciation for the sensitivity of the information you share through our Services and Game, we have implemented industry-standard measures to fortify the protection of your data.

Please note, however, that despite our diligent and best efforts, no security system is perfect and impenetrable to all potential breaches. While we strive to protect your information, we cannot guarantee its absolute security.

CHILDREN

The Services we provide, inclusive of our Website and Game, are not intended for individuals under the age of seventeen (17) (“Permitted Age”). It is against our policy to knowingly collect or store personal information from those under the Permitted Age. If you are under the Permitted Age, we kindly ask that you do not use or submit any information through the Website or during the use of the Game. If we discover someone under the Permitted Age has provided personal information without confirmation of parental consent, such information will be expeditiously deleted from our records. If you have reason to believe we may have personal information from or about a user under the Permitted Age, we urge you to please contact us via the contact form on our Website or by emailing us at info@sinnstudio.com.

CHANGES TO OUR PRIVACY POLICY

From time to time, we may make changes to our Policy as we continue to update and improve the Services and release new features. In the event that such changes occur, we will post any changes to our Policy on this page as well as an in-game notice on Swordsman VR that the Policy has been updated.

We include the date the Policy was last revised at the top of the page. You are responsible for periodically visiting our Website or reviewing notices in the Game regarding changes and updates to this Policy.

CONTACT US

If you have any questions, concerns, or requests regarding our Privacy Policy or the privacy practices of Sinn Studio, please contact us at info@sinnstudio.com.

We have procedures in place to receive and respond to inquiries about our compliance with this policy, and with applicable privacy laws.

We also want to confirm that by using our Services, including the Website and Game, you signify your acceptance of this Policy. However, if you disagree with this policy, we recommend that you refrain from using our Services or the Game.

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