Your privacy is important to Surge Games Studio (here in after “the Company”). This statement outlines Company policy on how we collect personal information and how we maintain, use, store and disclose the personal information we hold and reflects our commitment to you. Surge Games Studio (“we” or “our”) is the owner, author and publisher of www.surgegames.studio (“Website”) which lists and permits transactions in relation to Service (“Service(s)”). All visitors of the Website are together termed as “you” or “Users”. It applies to all operations within the Company, including visitors to our Websites.
We are committed to being open and transparent about how we manage personal information.
B. Types of data and information held by Company and when and how it is collected
1. Sensitive Personal Data or Information (“SPDI”)
SPDI is a special category of personal information defined under Section 43A of the Act and the Privacy Rules framed there under that could be used for the purpose of identifying you or to form an opinion about you. SPDI is such personal information which consists of information relating to:
any of the information received above by a body corporate for processing, whether stored or processed under lawful contract or otherwise:
As outlined under the Act and the Privacy Rules, your personal information and/or SPDI can only be collected, handled, processed or stored by us and / or disclosed to / shared with third party(ies) only after obtaining your prior written consent. However, the Act read with the Privacy Rules provide for the following circumstances in which we may not obtain your consent while collecting, handling, processing or storing your personal information and / or while disclosing your personal information to a third party:
When you request information about our Services, you must submit your name and email address. In addition, you may insert the reason for your communication. We will use this Personal Information to:
D. General information collected from visitors to our website
We gather personal information and / or SPDI about all our website users collectively, such as what areas users visit more frequently and what services users access the most. This information helps us determine what is most beneficial for our users, and how we can continually create a better overall website experience for you.
When you use or transact on our website, we collect Personal Information about you periodically. The objective really is to give a seamless, safe and a personalised experience which will make you using our website a pleasant experience. Also we do need some personal information that is essential in order to execute the orders that you place on our site.
All your information is maintained by Surge Games Studio in electronic form on its equipment, and on the equipment of its employees. User information may also be converted to physical form from time to time. Surge Games Studio makes all User information accessible to its employees only on a need-to-know basis, and binds all such employees to strict confidentiality obligations.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect such information into a file specific to you.
In our efforts to continually improve our service offerings, we collect and analyse demographic and profile data about our users’ activity on our Website.
We identify and use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address is also used to help identify you and to gather broad demographic information.
We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, or income level). We use this data to tailor your experience at our Website, providing you with content that we think you might be interested in and to display content according to your preferences.
We use your personal information to resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our services, inform you about online and offline offers, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; and as otherwise described to you at the time of collection.
Not with standing the above, Surge Games Studio shall not be responsible for any breach of security or for any actions of any third parties that receive Users’ personal data or events that are beyond the reasonable control of Surge Games Studio including, acts of government, computer hacking, unauthorised access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of internet service or telephone service etc.
E. Tracking Information when users navigate the Site
We use data collection devices such as “cookies” on certain pages of the Website to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. A “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. We place both permanent and temporary cookies in your computer’s hard drive. In the course of serving advertisements or optimizing services to its Users, Surge Games Studio may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies do not contain any of your personally identifiable information.
The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from Surge Games Studio. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other anonymous data we have about our clients to provide you with information about Surge Games Studio and our services. We will conduct this review on an anonymous basis.
Banking and credit card information
Surge Games Studio may require the User to pay with a credit card, wire transfer, debit card or cheque/cash. Surge Games Studio will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process. User’s credit card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, Surge Games Studio provides you an option not to save your payment details. User is advised, however, that internet technology is not full proof safe and User should exercise discretion while using the same.
We use personal information to provide the services you request. To the extent we use your personal information to market to you, we will provide you the ability to opt-out of such uses. We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after setting up an account.
If you want to remove your contact information from all www.surgegames.studio lists and newsletters, please contact us.
Links to Other Sites
Our Website may link you to other websites that may collect personally identifiable information about you. www.surgegames.studio is not responsible for the privacy practices or the content of those linked websites.
Our Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.
F. Purposes and use for which we collect personal information
1. Your personal information / SPDI may be used in connection with:
2. When you register to proceed with the Services, we ask you for your name, your position and the organization you work for, e-mail address, country, postcode, telephone number, billing address or payment details.
We use this information to:
We may disclose your personal information (including to trusted third parties) for the purposes for which it is primarily held or for a related secondary purpose and in some cases we may only disclose information with your consent (unless already granted). Your personal and sensitive information may be disclosed to:
H. Management of personal information
At Company, we train our staff to respect the confidentiality of customer information and the privacy of individuals. Company regards breach of your privacy very seriously and any breach will result in disciplinary action being taken, dependent upon severity. Company has appointed a Privacy Officer to ensure that our management of personal information and / or SPDI is in accordance with this policy and the relevant Act. As per the requirements of the Privacy Rules, Company has designated a Grievance Officer to redress your complaints, if any, with respect to processing of information in a time bound manner. The Grievance Officer shall endeavour to redress your complaints expeditiously within one month from the date of receipt of any communication in this regard from you.
I. How do we store and protect personal information?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium and ensure implementing reasonable security practices and procedures to protect your personal information/SPDI. We will provide you the name of the agency(ies) who may maintain, handle or store your personal information / SPDI as service provider on our behalf. We and / or through our service provider shall hold personal information/ SPDI in a combination of secure computer storage facilities and paper-based files and other records, and take such steps as are reasonable in the circumstances to protect the personal information/ SPDI we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
J. How do we keep personal information accurate and up to date?
Company takes such steps as are reasonable in the circumstances to ensure that the personal information it holds and discloses is accurate, up to date and complete. We recognise that information changes frequently with changes of address and other personal circumstances. Please advise the Company when your personal details change. Any change in your personal information / SPDI shall be updated by us after obtaining the same from you in writing.
If you have created a profile with Company via our website, you are able to review and edit your personal information at any time by logging into your account and reviewing your profile. You can delete your personal information or close your account by contacting the Privacy Officer. If you do choose to close your account with Company, Company may retain personal information from your account as and where required by law.
K. Enquiries & complaints
We aim to acknowledge receipt of all complaints within 15 working days, and aim to resolve all complaints within one month from the date of receipt of such complaint. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time. If you are not satisfied with our response to your complaint, you may take recourse to redress your complaint as per the mechanism provided under the Act.
L. Access and Your Rights
Surge Games Studio does not provide online access to its customers to view or amend personal information in its database, however, you have the right to ask us to do any amendment in any personal information we hold about you if it is inaccurate or misleading. We also note that our knowing about changes to some of your Personal Information, (e.g. email address) may be key to effectively communicating with you at your request so we encourage you keep us informed of changes to your Personal Information. To update your details, please contact us by email at [email protected] or at the following address:
Surge Games Studio
Attn: Customer Care
The following rights (which may be subject to certain exemptions or derogations), shall apply in addition to the above to EU users of the Site or the Services:
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
Company has several areas on our website where you can submit feedback, under the ‘contact us’ section. Any feedback that is submitted through this area becomes the property of Company. We may use this feedback, such as success stories or responses to surveys, for marketing purposes, or to contact you for further feedback on the site.
N. Contact us
Surge Games Studio
Attn: Customer Care
We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wishes to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.