WANDERING STAR PRIVACY POLICY

PRIVATE SECTOR PRIVACY LEGISLATION

PERSONAL INFORMATION PROTECTION POLICY

 

WANDERING STAR PRIVACY MISSION

 

Wandering Star is a platform that prioritizes privacy by design principles and is compliant with COPPA regulations. Our platform ensures the safety and security of children's personal information while providing a seamless experience for parents and guardians.

Wandering Star is deeply committed to your child’s privacy as well as your own. We seek to collect the least amount of personally-identifiable information about your child while providing them with the games and experiences we offer. We endeavour to provide you with a high level of transparency, security, encryption and control so that you can make informed decisions on how your personal information is used. Wandering Star values your trust, and will never sell your data to third parties.

 

In creating a safe and secure environment that children of all ages can enjoy, Wandering Star is committed to adhering to regional privacy laws and regulations, and striving to exceed legal minimums.

 

We use Privacy by Design principles at every step by making privacy the default setting, building privacy into each feature from the start, and ensuring that your personal information is fully protected during its entire lifecycle.

 

PRIVACY POLICY

 

At Wandering Star Ventures Inc., we are committed to providing our users with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our users, protecting their personal information is one of our highest priorities.

 

We will inform our users of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

 

This Personal Information Protection Policy outlines the principles and practices we will follow in protecting users’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our users’ personal information and allowing our users to request access to, and correction of, their personal information.

 

SCOPE OF THIS POLICY

 

This Personal Information Protection Policy applies to Wandering Star Ventures Inc.

 

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Wandering Star Ventures Inc.

 

Terms

 

Personal Information (PI) – means information about an identifiable user or child, this includes, but may not be limited to, the following:

 

 

Contact information – means information that would enable a user to be contacted by email/SMS and includes name, address, mobile telephone number and email address.

 

Privacy Officer – means the individual designated responsibility for ensuring that Wandering Star Ventures Inc. complies with this policy and PIPA.

 

User – any individual using a Wandering Star services, whether parent or child. We will say ‘child user’ or ‘parent user’ where a distinction is necessary. Where we say parent user, we refer to parent users who are parents or legal guardians. Where the term ‘player’ is used in the app, it refers to the character in the game that any user is using to participate in Wandering Star games and activities.    

     

Verified account holder – a user who has declared that they are over the age of 13 in order to create a Wandering Star account (parent users will always be verified account holders).

 

Child user – an individual who is using the Wandering Star app via a verified account holder’s account. Child users under the age of 13 may not use the Wandering Star app without parental consent of a verified account holder.

 

1 – COLLECTING PERSONAL INFORMATION

 

1. Unless the purposes for collecting personal information are obvious and the user voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, in writing, before or at the time of collection.

 

2. We will only collect user and user information that is necessary to fulfill the following purposes:

 

Purpose	Personal Information Collected
To verify a user’s identity	We ask users if they are over 13 years old in order to determine whether or not we need parental consent, as per the US Children’s Online Privacy Protection Act (COPPA).   If the user is under 13, we request a parent user email address in order for the parent user to authorize the account.
To create an account for saving progress and for us to report game progress to you (including child user activities and user-submitted information)	For a parent user, we collect his or her name, address, mail address, and allow them to create a username/password for their account.   For child users, we collect a ‘nickname’ on the parent user’s account. Families are discouraged to add the child’s name to minimize the personal information provided about the child.
To identify user preferences	We collect and save selections made in a user’s account page.
To purchase downloadable content	We collect user’s identity and preferences to associate content to that user.
To save game progression	We collect and save user progression, activity details, and child user submitted diary information.
For the sole purpose of providing support for the internal operations of our website and service	We collect cookies about user activity and device/browser characteristics (see “Use of Cookies and Digital Tracking” section for more details).

 

3. When Wandering Star collects birthdate [OR information about whether the user is 13 years of age or older], it is to ensure that parental authorization is acquired before we collect personal information from children using the account. Wandering Star offers its services jurisdictions that require parental consent, and this information is collected in order to satisfy those requirements, and for no other purpose. Parents or guardians can change or revoke the consent choices previously made, and review, edit, or request the deletion of the personal data of the children for whom they provided consent or authorization.

 

4. Wandering Star uses augmented reality (AR) in some of its gameplay. AR uses computer graphics or video composited on top of a live video feed to augment the view and create interaction. When an AR portion of the game begins, the camera function of the user’s mobile device will turn on to create the live video feed. Wandering Star does not record or store any part of this video. If a user chooses to join another user in an AR interaction, they will share each other’s video feed with one another, which may include personally-identifying information, such as in the case that a user’s face is shown. Wandering Star is not responsible for what information users disclose to one another via video feed.

 

2 – CONSENT

 

1. We will obtain user consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

 

2. Consent can be provided electronically and in writing or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the user voluntarily provides personal information for that purpose.

 

3. Subject to certain exceptions (e.g., the withdrawal of consent would constrain the performance of a legal obligation), users can withhold or withdraw their consent for Wandering Star Ventures Inc. to use their personal information in certain ways.        A user’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the user in making the decision.

 

4. We may collect, use or disclose personal information without the user’s knowledge or consent in the following limited circumstances:

 

 

3 – USING, TRANSFERRING AND DISCLOSING PERSONAL INFORMATION

 

1. We will only use or disclose user personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

• To verify a user’s identity;
• To create an account;
• To identify user preferences;
• To identify user preferences;
• To purchase downloadable content;
• To save game progression;
• To contact parent users about child user progression;
• To contact parent users on child user activity;
• To ensure a high standard of service to our users;
• To meet regulatory requirements

 

2. We will not use or disclose user personal information for any additional purpose unless we obtain consent to do so.

 

3. We will not sell user personal information to other parties.

 

4. Where parents or legal guardians have added a child’s profile to their account, there will be a PIN-protected area where the parent user will be able to review the child’s progress, reports, and any diary information that the child submits during the game play.

 

5. We transfer personal information to third parties that provide support for the internal operations of Wandering Star, and do not disclose or use that information for any other purpose. In these cases, we take appropriate steps to ensure that the information is securely processed. Wandering Star’s third parties processors include:
   1. Unity, a game engine that powers Wandering Star’s app;

1. You may refer to Unity’s Privacy Policy here: https://unity3d.com/legal/privacy-policy
2. You may refer to Unity’s Controller Data Protection Addendum here: https://unity3d.com/profiles/unity3d/themes/unity/images/pages/gdpr/Controller-Controller-DPA-5-2-2018.pdf

2. Shopify, an e-commerce platform that supports our website;

1. You may refer to Shopify’s Privacy Policy here: https://www.shopify.com/legal/privacy
2. You may refer to Shopify’s Data Processing Addendum here: https://www.shopify.ca/legal/dpa

3. Azure, a cloud computing service created by Microsoft for managing the Wandering Star app;

1. You may refer to Microsoft Azure’s Privacy Policy here: https://docs.microsoft.com/en-ca/legal/gdpr
2. You may refer to Microsoft’s Data Protection Addendum here: https://www.microsoftvolumelicensing.com/Downloader.aspx?DocumentId=18600

 

6. Wandering Star has its headquarters in Canada, but the information may be processed outside of Canada. We will disclose personal information where required by law enforcement and national security authorities of other jurisdictions (for example, in the event of a court order, subpoena, or search warrant).

 

4 – RETAINING PERSONAL INFORMATION

 

1. If we use user personal information to make a decision that directly affects the user, we will retain that personal information for at least one (1) year so that the user has a reasonable opportunity to request access to it.

 

2. Subject to section 4.1, we will retain user personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. We generally retain your information for the period during which you maintain an account in Wandering Star, after which time your data is deleted, unless otherwise required by applicable laws.

 

5 – ENSURING ACCURACY OF PERSONAL INFORMATION

1. We will make reasonable efforts to ensure that user personal information is accurate and complete where it may be used to make a decision about the user.

 

2. Parent users may request correction to their personal information or their child’s personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify you as well as the personal information and the correction being sought.

 

A request to correct personal information should be forwarded to the Privacy Officer.

 

3. We will correct the information as required in all areas that we process personal information, if there are reasonable grounds to do so. If the correction is not made, we will note the user’s correction request in the file.

 

6 – SECURING PERSONAL INFORMATION

 

1. We are committed to ensuring the security of user personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

 

2. Wandering Star uses the following security measures to ensure that user personal information is appropriately protected:

 

• Only authorized APIs are used;
• High-level authentication systems are in place;
• The least privilege principle is used, means giving a user account or process only those privileges which are essential to perform its intended function;
• The Wandering Star app is thoroughly and repeatedly tested, ensuring the app is as secure as it can be;
• Appropriate technical and organizational measures are in place to protect data from:
  1. Accidental or unlawful destruction;
  2. Loss, alteration, unauthorized disclosure of, or access to, data
• Where possible, personal information is either deleted or anonymized when that information is no longer needed;
• Regular audits are performed to assess the security of data storage and systems that process financial information;
• All personal information is encrypted; and
• All personal information communicated through the internet is encrypted.

 

3. We will use appropriate security measures when destroying user’s personal information such as securely deleting electronically stored information.

 

4. We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

 7 – PROVIDING USERS WITH ACCESS TO PERSONAL INFORMATION

 

1. Users have a right to access their personal information, subject to limited exceptions.

 

Exceptions may include:

 

 

2. A request to access personal information must be made in writing and provide sufficient detail to identify you as well as the personal information being requested. A request to access personal information should be forwarded to the Privacy Officer.

 

3. Upon request, we will also tell users how we use their personal information and to whom it has been disclosed, if applicable.

 

4. We will make the requested information available within thirty (30) business days, or provide written notice of an extension where additional time is required to fulfill the request.

 

5. If a request is refused in full or in part, we will notify the user or requester in writing, providing the reasons for refusal and the recourse available to the user or requester.

 

6. Parents are provided with a pin-protected area to review reports about information that their child(ren) submit while using the app. As the verified account holder who have access to this information, parents are responsible for sharing this information with their children upon request.

 8 – UPDATES TO THIS PRIVACY POLICY

 

1. We may modify or revise this Privacy Policy from time to time. We will notify users of any changes to our Privacy Policy by posting the revised version with an updated date of revision on our website. If we change this Policy in a material manner, we will do our best to notify you of the changes by posting a notice on our website. Your continued use of the Services following the effective date of such update constitutes your acceptance of the revised Policy.

 

9 – PROTECTING CHILDREN’S PRIVACY

                

1. Protecting the privacy of children is especially important to us. For that reason, Wandering Star does not knowingly permit child users to register directly for our service without consent of a parent user. If Wandering Star learns that personal information of a child user has been collected via our service without parental consent, then we will take appropriate steps to delete this information. If you are a parent and discover that your child has registered for an account without your consent, please alert us by emailing our privacy officer (see contact information below).

 

2. Wandering Star has used Privacy by Design principles to build its product in order to collect the least amount of personally-identifiable information about your child in order to provide them with the games and experiences we offer.

 

10 – USE OF COOKIES AND DIGITAL TRACKING

 

1. We may use information collected through cookies and similar digital tracking technologies in order to provide better technical support, and as metrics that we use to enhance the user experience. For instance, we use cookies to track:

 

 

2. If you use our website or services, this constitutes your consent that we may store and access essential cookies on your computer or other devices, which are necessary for the operation of the services you are using.

 

3. If you wish to block or delete cookies, you can do so by opting out of cookies on this site, as well as setting your browser settings to disable non-essential cookies.

 

4. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

 

11 – QUESTIONS AND COMPLAINTS: THE ROLE OF THE PRIVACY OFFICER

 

1. The Privacy Officer is responsible for ensuring Wandering Star Ventures Inc.’s compliance with this policy and BC’s Personal Information Protection Act, and other relevant legislation.

 

2. Users should direct any complaints, concerns or questions regarding Wandering Star Venture Inc.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the users may also write to the Information and Privacy Commissioner of British Columbia.

 

3. Contact information for Wandering Star Ventures Inc.’s Privacy Team:

 

Wandering Star Ventures Inc.

300 – 1275 West 6th Ave.

Vancouver BC V6H 1A6

Email: privacy@wanderingstar.ca

 

WANDERINGSTAR.CA WEBSITE PRIVACY POLICY

 

This Privacy Policy describes how wanderingstar.ca (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

 

COLLECTING PERSONAL INFORMATION

 

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

 

DEVICE INFORMATION

 

ORDER INFORMATION

 

CUSTOMER SUPPORT INFORMATION

 

• Examples of Personal Information collected
• First name;
• Last name;
• Email address;
• Type of device;
• Type of problem/issue encountered.
  
  
• Purpose of collection: to provide customer support.
• Source of collection: collected from you.

 

MINORS

 

We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

 

SHARING PERSONAL INFORMATION

 

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example, we use:

 

• Shopify (privacy policy) to power our online store..
• Unity (privacy policy), a game engine that powers Wandering Star;
• Shopify (privacy policy), an e-commerce platform that supports our website;
• Azure, (privacy policy),  a cloud computing service created by Microsoft for managing the Wandering Star app.
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

 

USING PERSONAL INFORMATION

 

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

 

LAWFUL BASIS

 

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

 

 

RETENTION

 

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

 

AUTOMATIC DECISION-MAKING

 

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

 

In general, we do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data. However, ur processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

 

Services that include elements of automated decision-making include:

 

 

YOUR RIGHTS

 

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

 

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

 

COOKIES

 

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

 

We use the following cookies to optimize your experience on our Site and to provide our services.

 

Essential Cookies Necessary for the Functioning of the Store

 

Name	Function	Duration
__cfduid	Used to provide the identification of trusted web traffic.	30 days
_ab	Used in connection with access to admin.	2 years
_gid	Used to store and count pageviews.	1 day
_secure_session_id	Used in connection with navigation through a storefront.	24 hours
cart	Used in connection with shopping cart.	2 weeks
cart_sig	Used in connection with checkout.	2 weeks
cart_ts	Used in connection with checkout.	2 weeks
checkout_token	Used in connection with checkout.	1 year
cookieconsent_status	Used to store cookie consent preferences.	at least one session
secret	Used in connection with checkout.	2 weeks
secure_customer_sig	Used in connection with customer login.	20 years
storefront_digest	Used in connection with customer login.	2 years
_shopify_u	Used to facilitate updating customer account information.	1 minute

 

REPORTING AND ANALYTICS

 

Name	Function	Duration
__atuvc	Used to store performed actions on the website.	13 months
__atuvs	Used to store performed actions on the website.	1 year
_ga	Google Analytics.	2 years
_gat	Google Analytics.	1 minute
__utma	Google Analytics.	persistent
_tracking_consent	Tracking preferences.	1 year
_landing_page	Track landing pages	2 weeks
_orig_referrer	Track landing pages	2 weeks
_s	Shopify analytics.	30 minutes
_shopify_fs	Shopify analytics.	1 year
_shopify_s	Shopify analytics.	30 minutes
_shopify_sa_p	Shopify analytics relating to marketing & referrals.	30 minutes
_shopify_sa_t	Shopify analytics relating to marketing & referrals.	30 minutes
_shopify_uniq	Shopify analytics.	at least one session
_shopify_visit	Shopify analytics.	30 minutes
_shopify_y	Shopify analytics.	1 year
_y	Shopify analytics.	1 year
tracked_start_checkout	Shopify analytics.	at least one session

 

MARKETING AND RETARGETING

Name	Function	Duration
__adroll	Adroll	at least one session
__adroll_fpc	Adroll	at least one session
__adroll_v4	Adroll	at least one session
__ar_v4	Used to store and track conversions.	persistent
_fbc	Used to store last visit.	2 years
_fbp	Used to store and track visits across websites.	3 months
_gads	Used to provide ad delivery or retargeting.	13 months
BizoID	Used to enable user-based content.	1 month
GPS	Used to store location data.	session
IDE	Used to provide ad delivery or retargeting.	2 years
PREF	Used to store user preferences.	8 months

 

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

 

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

 

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

 

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

 

DO NOT TRACK

 

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

 

CHANGES

 

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

 

CONTACT

 

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@wanderingstar.ca or by mail using the details provided below:

 

Wandering Star

Privacy Department

1275 West 6th Avenue, Unit 300

Vancouver BC

V6H 1A6

Canada

 

Last updated: February 28, 2022

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here:

 

Office of the Privacy Commissioner of Canada

https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/file-a-complaint-about-a-business/