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Privacy Policy

Last Updated: 10 November 2020

What We Do

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Our Vision

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Come Play with Us

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Open Positions

Creative

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Marketing

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BTN Pte Ltd (“BTN”, “we”, “our”, “us”) offers its Virtual Spaces services (the “Services” – including associated websites and applications) to individuals and organizations (“client”, “host”) who in turn may provide it to end users (“you”, “your”). This Privacy Policy sets forth how we collect, use, protect, store, and otherwise process end user Personal Information (defined below). This Policy does NOT apply to information we collect through any of our other services, offline or that you provide to or is collected by any third party (except as otherwise provided below).  

1. Types of Personal Information we collect

We may collect different types of information from you depending on how you use our Services, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person. The categories of Personal Information we may collect are listed below. Certain types of Personal Information may fall under more than one category.

  • Identifiers: We may collect your first and last name, email address, username, device identifier, IP address, or display name.

  • Characteristics: We may collect your date of birth or age.

  • Sensory data: After asking for and receiving permission to access the microphone on your device, we may receive your voice through your microphone and transmit it to other users of the Services. We do not store voice data beyond each user session.

  • Internet or other similar network activity: We may assess your network connectivity status and speed.

  • Other categories: We may collect and transmit information from the content that you create and/or share publicly while using the Services, and information you choose to reveal via the Services through multiplayer voice and text chat or other public functions.

We may also collect information that does not generally identify you but may become associated with your account. We may use information that does not identify you for any permissible business purpose under applicable law.

2. Children Under the Age of 16

This section notifies parents of our practices with respect to the collection of personal information from children under the age of 16 (“Children” and each a “Child”) and the use and disclosure of such information. This section only applies to Children and supplements the other provisions of this Policy.

If a client expects end users under the age of 16, we include neutral age gates within our Services for that client. In such cases, if an end user of the Services self-identifies or is identified by us as being under the age of 16, their experience of the app is automatically set to “Junior Mode.”

In order to comply with the Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”), users in “Junior Mode” (“Junior Users” and each a “Junior User”) may have access to fewer features of the Services than non-Junior users. This is designed to limit our access and the access of users of the Services to the Personal Information of Children. Junior Users have restricted communication with other users. For example, Junior Users are unable to use “whiteboarding” and voice communication functions of the Services, their text chat content is processed through a strict obscenity filter and Junior Users’ display names will be truncated/anonymized.

Junior Users may authenticate their access to the Services using a process similar to the one adults go through; however, in compliance with COPPA, Junior Users may first be subject to a parental notice and/or consent process prior to activation of their account. To initiate the registration and/or consent process for a Junior User, we collect a Parent’s email address, and the Parent is then requested to confirm the creation of their Child’s account by receiving a parental password via email which the Child is required to enter into the Services before proceeding.

The Personal Information we collect from/about Children is used to give Children access to certain features of the Game and communicate with a Parent about the Child’s registration, including for the purpose of verifying their Child’s information in connection with registration. We do not share or otherwise disclose Children’s Personal Information except (1) as may be necessary to protect the safety of a Child, including by disclosing their Personal Information, where appropriate, to law enforcement agencies or for an investigation related to public safety; (2) to enable us to take precautions against liability; (3) to protect the safety and security of the Services; or (4) where required to do so by law or legal process.

We and the third-party service providers listed below may collect or maintain Children’s Personal Information through the Services.

  • Exit Games GmbH

  • Google Cloud Platform

  • Unity Analytics

Please contact us with questions about our service providers’ privacy policies and collection and use practices by email at info@btn.sg.

When a client does not expect users under the age of 16 to use the services, we include a checkbox for users to self-certify that they are over the age of 16. In such cases, our Service is not directed to children under the age of 16, and if you are under 16 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Service from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information.

At any time, parents may review their Child’s Personal Information maintained by us, require us to correct or delete such Personal Information, request that we delete their Child’s account, and/or refuse to permit us from further collecting or using the Child’s Personal Information by contacting us using the email address provided above.  If you are a parent or guardian and discover that your child under 16 years of age has obtained an account on the Service without your consent, then you may alert us at the email address provided above and request that we delete that child’s Personal Information from our systems. To protect parents’ privacy and security and the privacy and security of Children that use the Services, we may require parents to take certain steps or provide additional information, which we will keep strictly confidential, to verify a parent’s identity before we provide any information or make any changes.

3. Sources of Personal Information

We may collect your Personal Information when you provide it to us directly. For example:

  • When you register for an account to use our Services, we may collect your age or date of birth, email address, username, and display name.

  • When you contact us or report a problem with the Services, we may collect records and copies of your correspondence.

  • In case the Services encounter a bug or crashes during use, we may collect information about your computer, your username, and the data gathered from a stack trace.

  • When you use the multiplayer chat or other public functions in the Services, we may collect the information you choose to disclose such as your username and the content your share.

  • When you respond to a survey or questionnaire, we may collect the information provided.

  • Microphone – The Services may request access to the microphone on your device in order to support real time voice chat. Voice chat is optional and may be turned off at any time. The Services will continue to function (without voice chat) if you choose to deny permission.

We may receive Personal Information from or through our service providers that helps us provide or facilitate your access to the Services. For example, we may receive your Personal Information from:

  • Third-party authentication providers (such as Github, Google, Facebook, etc.)

  • Multi-player platform providers;

  • Cloud computing providers;

  • Data analytics providers.

We abide by this Policy when we use Personal Information provided to us by third parties. However, we do not control the Personal Information that third parties collect or how they use that Personal Information. You should review the third parties’ privacy policies for more information about how they collect, use, and share information they obtain and use.

4. Purpose of collecting Personal Information

  • To provide or improve the Services – We may use your Personal Information to process your requests to access the Services and certain of their features and to generally present and improve our Services. By way of example, we may use your microphone to provide the real-time voice chat features.

  • To administer the Services – We may use your Personal Information for any lawful business purpose in connection with administering the Services. For example, if you reach out to us with a customer service inquiry, we may use your Personal Information to respond to you or to troubleshoot an issue you reported having with the Services. By way of another example, we may use your Personal Information to verify your age.

  • To market the Services – We may use your Personal Information to market our Services to you. For example, with your prior consent, we may send you news and updates about our products and Services, including special offers and promotions.

  • In furtherance of legal, health, and safety objectives – We may access, use, and share with others your Personal Information for purposes of health, safety, and other matters in the public interest. We may also provide access to your Personal Information to cooperate with official investigations or legal proceedings (e.g., in response to subpoenas, search warrants, court orders, or other legal processes). We may also provide access to protect our rights and property and those of our agents, users, and others including to enforce our agreements, policies, and our Terms of Service (available at https://btn.sg/virtualspacesterms).

  • In connection with a sale or other transfer of our business – In the event all or some of our assets are sold, assigned, transferred to, or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy, or otherwise, your Personal Information may be among the transferred assets.

  • As may be described to you when collecting your Personal Information.

We do not use automated decision-making in connection with the processing of your Personal Information, except to the extent necessary for age-gating functions.

Lawful Basis

We only collect, use, or store your Personal Information if:

  • you voluntarily provide it to us with your specific and informed consent (for example, when you sign up for marketing communications);

  • it is necessary to provide you a Service that you have requested (for example, providing you access to the Services);

  • we have a legitimate business interest that is not outweighed by your privacy rights (for example, to provide customer service).

  • it is necessary to protect your vital interests or the vital interests of others (for example, we may collect or share Personal Information where necessary to protect the health or safety of one of our users or someone else).
     

5. Disclosure of Personal Information

We may disclose your Personal Information:

  • To our subsidiaries and affiliates;

  • To our lawyers, consultants, accountants, business advisors, and similar third parties who owe us duties of confidentiality;

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company pertaining to the users of our Services is among the assets transferred;

  • To comply with any court order, law, or legal process, such as responding to a government or regulatory request;

  • To enforce any contract we may have in effect with you;

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others; and

  • If you have consented to such a disclosure.
     

6. Protection of Personal Information

We protect your Personal Information through a combination of collection, security, and retention policies.

  • Limited retention. We only keep your Personal Information for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations. For example, we may retain Personal Information collected from you to support customer service inquiries and prevent repeated violations or suspected violations of the Terms of Service if your account has been banned or your access to the Services has been disabled for any reason. By way of another example, we may retain the content that you create and share publicly with other users even after you stop using the Services.

  • Purpose limitation. We will use your Personal Information only for the Services you choose to access and for the purposes for which you choose to share it. We will respect your requests to start or stop processing your Personal Information for marketing purposes, as well as the types of marketing messages you may wish to receive.

  • Security measures. We use appropriate measures to ensure a level of security appropriate to the risk involved and have implemented contractual, technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, use, and modification. For example, when you directly provide us with Personal Information, including through registration, we will encrypt that information using secure socket layer technology or similar technologies. As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this Policy does not guarantee the security of your Personal Information. In the event of a security breach, after we become aware of such a breach, we will promptly notify the proper regulatory authorities and any affected users of the breach.

Your practices and activities are likewise very important for the protection of your own Personal Information. You can take certain steps to help protect your Personal Information, such as being mindful of what you post or share in public places such as in text and voice chats. We have no control over what third parties do with the content of such public communications and no responsibility or obligation regarding third parties.
 

7. Transfer of Personal Information out of the EU

We may store or process your Personal Information outside of the country where we collect it or which you reside. Our primary place of business is in Singapore with subscriptions to cloud services located across the globe including the United States of America. You should understand that we may transfer some or all of your Personal Information to Singapore or the USA to carry out certain operational and processing needs as described in this Policy.

When transferring Personal Information out of the EU, we implement technical, organizational, and physical safeguards to protect your Personal Information. Please contact us if you have questions related to the relevant transfer mechanism for your Personal Information.
 

8. Your rights to your Personal Information

Subject to any limitations and exceptions under applicable law, you have the right to request access to your Personal Information and exercise a number of rights:

  • You have the right to correct or update certain types of Personal Information. In many cases, you can review your account information by accessing your account from within the Services.

  • You have the right to request deletion of your Personal Information. If you choose to have your Personal Information removed from our Services, we will carry out your request within 30 days of account verification, subject to extension, and will only retain minimal Personal Information to document your request and the actions we took to carry out your request.

  • You have the right to withdraw your consent at any time.

We will comply with your requests in accordance with, and subject to, applicable law. For example, the Company is not required to delete your Personal Information if it has an overriding legitimate ground for retaining that information such as to prevent fraud. Please note that we are legally prohibited from carrying out requested actions in some instances, including (1) when we are unable to confirm your identity; (2) where the request is considered excessive; and (3) where doing so would adversely affect the rights or freedoms of other individuals.

Please email us at info@btn.sg with the subject line “Data Subject Rights” if you would like to exercise any of the rights described above or if you have questions regarding your rights.

 

9. Cookie Policy

Cookies are created when a user's browser loads a particular website. A cookie file is stored in your web browser and allows the website or a third-party to recognize you and make your next visit easier and the website more useful to you.  For information on cookies, please visit https://www.allaboutcookies.org/.

Cookies placed by third-parties

Our website (btn.sg) may embed third-party content such as interactive design mockups, YouTube videos etc or have cookies placed by our hosting provider. The cookies placed and used by these third parties are out of BTN’s control and are subject to third-party cookie and privacy policies. Our website is hosted on the Wix.com platform. Your data may be stored through Wix.com’s data storage and databases. 

Deleting cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

10. Changes to this Privacy Policy

We reserve the right to change this Policy from time to time consistent with applicable law. If we make changes to this Policy, we will notify this by revising the date at the top of this Policy. In the event that any changes we make to Policy affect Children in a way that requires prior parental consent under COPPA, we will obtain such prior parental consent.

If you have questions about this Privacy Policy, you may email us at info@btn.sg

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