Last Updated: 2 September 2024
1. Introduction
Clever Trickster Studio SRL (« we », « us », or « our ») is committed to protecting your privacy and ensuring that your personal data is handled with care and respect. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our products and services, including our website, games, and other online services.
We are dedicated to being transparent about the data we collect and the reasons behind it and, importantly, we do not sell your data to third parties.
Our primary reason for collecting data is to enhance our products and your overall experience with them. Whether we are gathering information about who you are and what you prefer, or assisting you through customer support when issues arise, our aim is to make sure you enjoy our offerings to the fullest. However, we strive to minimize the amount of data we collect, limiting it to only what is essential.
This policy applies to all Clever Trickster Studio products (including games, merchandise, etc.) and services, such as our website, as well as offline interactions like events or booths at conventions.
By accessing or using any Clever Trickster Studio-owned website, you agree to the ways in which Clever Trickster Studio collects, uses, and processes your personal data. This does not imply that you are giving explicit consent to every processing activity. Instead, it means that for types of processing that do not require explicit consent, you are implicitly agreeing to Clever Trickster Studio’s reasons for processing. If you disagree with the contents of this policy, you should refrain from using any Clever Trickster Studio websites.
2. Data Controller
Clever Trickster Studio SRL, with its registered office at Chaussée de Liège 624, 5100 Jambes, Belgium, and registered in Belgium under the number BE0798 242 593, is the data controller for the personal data you provide directly on our website.
3. Personal data we collect and why
We collect personal data to provide you with the best possible service. The type of data we collect depends on how you interact with us:
a. Learning about Clever Trickster Studio
When you seek more information about Clever Trickster Studio, you might visit a virtual or physical site we manage, such as browsing our websites, attending an event we organize or participate in, or subscribing to our newsletter. During these interactions, you may voluntarily provide personal data like your name and email address. Additionally, cookies or similar technologies might collect information when you visit our websites.
We Collect: Name, email address, IP address, and information provided by cookies or similar technologies.
Why: To share news about events and products offered by Clever Trickster Studio. We collect the minimum necessary personal data to ensure the smooth operation of our websites.
Rationale: We gather this data with your explicit consent. Whether or not you choose to share personal data with us, you will still have access to Clever Trickster Studio’s informational services. Note that necessary cookies might be used on our websites solely for functional purposes to enable you to access the website.
b. Purchasing Clever Trickster Studio products
When you buy products directly from us, we may ask for certain information to complete your purchase.
We Collect: Name, phone number (optional), email address, shipping address, and payment information.
Why: To complete your transaction, assist with delivery, manage returns, and handle other purchase-related matters. We do not store any payment or credit card information: such details are only used in connection with your purchase.
Rationale: This information is necessary to fulfill the contract formed when you purchase a product from Clever Trickster Studio.
c. Setting up a Clever Trickster Studio account
You may choose to sign up for the Clever Trickster Studio account launcher, which requires setting up an account.
We Collect: Username (login), display name, email address, encrypted password, platform ID (user ID from platforms like Steam), save game data.
Rationale: We collect this data to operate the account service, enable cross-platform play and saves, and potentially fulfill your purchase orders. Thus, processing personal data is necessary for the performance of the contract.
d. Getting help from Clever Trickster Studio
Occasionally, you may reach out to our support team for assistance with Clever Trickster Studio products. To provide the best service, we may collect certain data from you or your products.
We Collect: Contact information such as your name, email address, and the content of your emails, chats, and other communications with Clever Trickster Studio Support. In some cases, it may be helpful for the Support team to have diagnostic information about your hardware. We collect this data with your permission when assisting you in troubleshooting your Clever Trickster Studio product. Optionally, you can provide a dxdiag file, which contains details about your computer (e.g., CPU, GPU, driver information). Typically, this data is not considered personal data, but we treat it as such when combined with other data you share in the context of your request.
Why: We collect this information to offer you the best and most efficient customer support.
Rationale: Receiving personalized help from Clever Trickster Studio is a service that players can choose to use or not. You can continue to use and enjoy Clever Trickster Studio’s products even without receiving personal support. Therefore, we obtain and process this information based on the performance of a contract—where the player requests personal help, and Clever Trickster Studio fulfills it.
f. Doing business with Clever Trickster Studio
Clever Trickster Studio primarily engages in business with other companies. However, in fulfilling agreements with business partners, we may collect contact details of their staff.
We Collect: Name, email address, telephone number, and/or photo of the business partner’s contact person.
Why: We need this information to fulfill our obligations, exercise our rights, and maintain our professional relationship with our business partners.
g. Applying for a job or internship at Clever Trickster Studio
If you apply for a position with Clever Trickster Studio, we need to process relevant personal data to evaluate your application.
We Collect: Name, email address, CV, and the information contained therein, phone number (optional), current employer (optional), LinkedIn profile (optional), and additional links to portfolio websites (optional).
Why: We collect this information to assess candidates for potential employment. Thus, this processing is necessary for the preparation of a potential contract.
h. Gameplay data (anonymous)
When playing our game, you have the option to share gameplay data. Whether you choose to share this data or not will not affect your ability to play the game.
We Collect: Gameplay logs that record story decisions, combat decisions, deaths, in-game locations visited, party and character customization choices. This data does not include hardware or software information, IP address, email address, usernames, or anything unrelated to playing the game. This is generic data used by our production teams.
Why: We collect this information to ensure Clever Trickster Studio products are balanced, enjoyable, clear, and function as intended, and to predict and prevent potential issues.
4. Information we obtain from third-party sources
We handle personal data obtained from third parties according to the practices described in this Policy, and we also apply any additional restrictions imposed by the data source. These third-party sources may vary over time but typically include partners with whom we offer co-branded services or engage in joint marketing activities.
5. Purposes for processing personal data
Clever Trickster Studio always processes your data based on one of the lawful processing grounds allowed by the GDPR. These legal grounds include “consent” for website usage, “legal obligations” and “contractual necessity” for services and products, or “legitimate interest.”
Clever Trickster Studio uses the data collected for the following purposes:
- Providing our product experience
- Customer support
- Product improvement
- Dispute resolution / legal requirements
- Business operations
- Communication, marketing, and advertising
6. Sharing and disclosure
Clever Trickster Studio does not sell personal data about its customers. We only disclose your data as described in this statement. We may share information with the following types of third parties, always ensuring that such third parties adhere to the same principles:
Third-Party Vendors
Clever Trickster Studio uses a variety of third-party vendors to perform services such as website management and hosting, online product purchases and shipping, credit card processing and email communications. We share your personal data as necessary to complete any transaction or provide any product or service you have requested or authorized, with vendors or agents working on our behalf for the purposes described in this statement. An up-to-date list of these parties may be requested from Clever Trickster Studio at any time.
Required by Law or Legal Proceedings
We may disclose your data when we reasonably believe it is required by law or in connection with legal proceedings, to prevent harm to Clever Trickster Studio or its customers, for the prevention and detection of crime or the apprehension or prosecution of offenders, and to protect the rights or property of Clever Trickster Studio.
Merger, acquisition, or sale of assets
We may disclose your data to complete a financial or corporate transaction such as a merger or sale of assets.
7. Your rights as a data subject
Clever Trickster Studio wants to ensure that all our data subjects are well informed about their rights and can exercise them effectively. Therefore, we have summarized them below:
a. Right of access
You have the right to obtain access to your personal information and to be informed about the purpose of the processing by Clever Trickster Studio.
b. Right to rectification, erasure or restriction
You have the option to share your personal information with Clever Trickster Studio. You can request that Clever Trickster Studio rectify your personal information or erase it. You can also request that the processing of your personal data be restricted. When you choose not to share data or request that we erase your personal information, we may be prevented from providing you with certain services, products, and access to a Clever Trickster Studio website.
c. Right to object
You have the right to object to the processing of your personal information for legitimate reasons. You also have the right to object to the use of your personal information for direct marketing purposes. In such cases, specific reasoning will not be requested.
d. Right to data portability
You have the right to obtain your personal information, which is processed by Clever Trickster Studio in a structured, commonly used, and machine-readable format, and/or to transfer this data to another data controller.
e. Right to withdraw consent
When processing is based on prior consent, you have the right to withdraw this consent.
f. Rights related to automated decision-making
If we were to use automated processes, including profiling, that significantly impact you, you have the right to know about it, request human intervention, and challenge the decision. At present, we do not process personal data in this manner.
Please note that you generally will not have to pay to exercise any of these rights regarding your personal information. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in those circumstances.
8. How to access and control your personal data
You can view, edit, or delete your personal data in your Clever Trickster Studio account, or by reaching out to us directly at hello@clevertrickster.com.
Please be advised that when receiving a request regarding personal data, we may be required to first take appropriate action to verify your identity and ensure that you are who you claim to be and that you have a legitimate interest in the personal data you are inquiring about.
Note that you can also always choose to stop receiving promotional emails and other types of marketing communication from us by unsubscribing from our mailing list at the bottom of the email.
9. Cookies and similar technologies
We use cookies and similar technologies like pixels and other identifiers to help us personalize our website for you, remember your preferences, understand how users are engaging with our website, and help customize our marketing offerings. By visiting our website, you agree to the use of cookies and similar technologies for the purposes we describe in this statement.
a. Cookies
A « cookie » is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a « persistent » or « session » cookie. Clever Trickster Studio uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.
With the exception of cookies that are used solely to transmit communications or those that are strictly necessary for the functioning of our websites, we will only place cookies where you have previously provided your consent. You can do this when prompted by our cookie banner. If you do not provide your consent, then you can still access and use our websites.
We use the following types of cookies on our website:
Strictly necessary cookies
These cookies are essential to enable you to browse our website and use its features.
Performance cookies
These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate.
Functional cookies
These cookies allow our website to remember your settings and help personalize your experience. For instance, we may store your geographic location in a cookie to ensure that we show you the Clever Trickster Studio website localized for your area.
Analytics cookies
We use analytics cookies, such as those offered by Google Analytics, to help us understand things like how long a visitor stays on our website, what pages they find most useful, and how they arrived at clevertrickster.com.
When you visit our websites, a cookie banner appears, giving you the option to either agree to our use of cookies and similar technologies for the purposes we describe in this statement or to deny the use of non-necessary cookies. For the technical running of the website, the necessary cookies will remain turned on, with more information provided in the cookie banner.
b. Pixels
In addition to cookies, we sometimes utilize small graphic images known as « pixels » (also known as web beacons, clear GIFs, or pixel tags). We may use pixels in our email communications sent to you (if you have opted to receive such communications) to help us understand whether our email communication was viewed. Additionally, we may use third-party pixels (such as those from Google, Facebook, and other advertising networks) to help us provide advertising for Clever Trickster Studio products or services that are relevant to your interests.
10. Security
We use a variety of security technologies and procedures to protect your personal data from unauthorized access, use, or disclosure.
While no security system is completely secure, Clever Trickster Studio takes reasonable industry-standard measures to protect personal data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.
The servers on which your personal data is stored are kept in a controlled and secure environment with restricted access. Activity on the server is monitored so we can track and trace any irregularities and act quickly in case of any issues.
11. Children’s privacy
Clever Trickster Studio does not knowingly collect personal data from children or send them requests for personal data.
Although visitors of all ages may navigate through our website, we do not intentionally collect personal data from individuals under the age of 16. If we become aware, through a parent or guardian or other means, that a minor has improperly registered on our site or service by using false information, we will cancel the child’s account and delete the child’s personal data from our records.
12. International data transfers
Personal data collected by Clever Trickster Studio may be stored and processed in your region, in the United States, or in any other country where Clever Trickster Studio or its affiliates, subsidiaries, or service providers maintain facilities.
All information you provide may be transferred or accessed by entities around the world as described in this statement. Whenever we share your personal data outside the EEA, we will ensure the adequate protection of your personal data and apply lawful measures of data transfer, such as EU standard contractual clauses.
13. Data retention
Clever Trickster Studio retains personal data for as long as necessary to provide the services, support your product, and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products or services, actual retention periods can vary significantly.
14. Changes to this privacy policy
Clever Trickster Studio may modify or update this statement when necessary to reflect customer feedback and changes in our products and services, so please review it periodically. When we update this statement, we will revise the « Last Updated » date at the top of the statement. If there are material changes to the statement or in how Clever Trickster Studio uses your personal data, we will notify you either by posting a notice of such changes before they take effect or by sending you a notification. We encourage you to periodically review this statement to learn more about how Clever Trickster Studio is using and protecting your information.
15. Data protection authority
If you have any complaints about the way Clever Trickster Studio collects, uses, and/or processes your personal data, you have the right to file a complaint with your national Data Protection Authority.
While we have multiple entities in different locations, we consider our main Data Protection Authority to be the Belgian Data Protection Authority (DPA), and all our processing activities fall under its governance and scope:
Belgian Data Protection Authority
Rue de la Presse 35
1000 Brussels, Belgium
+32 (0)2 274 48 00
contact@apd-gba.be
https://www.dataprotectionauthority.be/citizen
16. How to contact us
If you have any questions about the use of your personal data, please contact us at hello@clevertrickster.com.
Unless otherwise stated, Clever Trickster Studio SRL is the data controller for personal data we collect through the products and services subject to this statement. Our address is:
Clever Trickster Studio SRL
Chaussée de Liège 624, 5100 Jambes – Belgium