1. Introduction and Scope
Welcome to Winter Champions ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit and use our website and social gaming services (collectively, the "Service"). This policy applies to all users located in Canada and complies with applicable Canadian privacy legislation including the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial privacy laws.
By accessing or using Winter Champions, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service. We reserve the right to modify this Privacy Policy at any time, and we will notify you of any material changes by posting the updated policy on our website.
2. Information We Collect
2.1 Personal Information
We may collect various types of personal information from you, including but not limited to:
- Identification Information: Name, email address, username, and date of birth (to verify you are 19 years of age or older in Canada)
- Contact Information: Email address, mailing address (if provided), and phone number (optional)
- Account Credentials: Username, password, and security questions/answers
- Communication Data: Records of your communications with us, including customer support inquiries and feedback
2.2 Technical and Usage Information
We automatically collect certain technical information when you access our Service:
- Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers
- Log Data: IP address, access times, pages viewed, time spent on pages, links clicked, and referring website addresses
- Cookie Data: Information collected through cookies, web beacons, and similar tracking technologies (see Section 4 for details)
- Game Play Data: Information about your gaming activity, preferences, and usage patterns within the Service
- Performance Data: Technical data about how our Service performs on your device, including error reports and diagnostic information
2.3 Information from Third Parties
We may receive information about you from third-party services if you choose to connect your account with such services, including social media platforms or authentication services. This may include your profile information and contact details as permitted by those services.
3. How We Use Your Information
We use the collected information for various purposes, including:
3.1 Service Provision and Improvement
- To provide, maintain, and improve our social gaming Service
- To create and manage your account
- To personalize your gaming experience and provide customized content
- To develop new features and enhance existing functionality
- To conduct research and analysis to understand user behavior and preferences
3.2 Communication
- To communicate with you about your account, including important updates and security notifications
- To respond to your inquiries, comments, and customer support requests
- To send you promotional materials and special offers (with your consent, where required)
- To conduct surveys and gather feedback about our Service
3.3 Security and Compliance
- To verify your age and ensure compliance with our 19+ age requirement in Canada
- To detect, prevent, and address technical issues, fraud, and security violations
- To protect the rights, property, and safety of Winter Champions, our users, and the public
- To comply with legal obligations and enforce our Terms of Service
3.4 Analytics and Performance
- To monitor and analyze usage trends, user engagement, and Service performance
- To conduct statistical analysis and generate aggregated, anonymized data for business purposes
- To measure the effectiveness of our marketing campaigns and communications
4. Cookies and Tracking Technologies
Winter Champions uses cookies and similar tracking technologies to enhance your experience and collect information about how you use our Service.
4.1 Types of Cookies We Use
- Essential Cookies: Necessary for the operation of our Service, including authentication and security functions
- Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferences
- Analytics Cookies: Help us understand how visitors interact with our Service by collecting and reporting information anonymously
- Marketing Cookies: Used to track visitors across websites to display relevant advertisements (with your consent)
4.2 Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to refuse or accept cookies, delete existing cookies, or set preferences for certain websites. However, please note that disabling certain cookies may affect the functionality of our Service. You can also opt out of interest-based advertising by visiting industry opt-out pages.
5. Data Sharing and Disclosure
We do not sell your personal information to third parties. We may share your information only in the following circumstances:
5.1 Service Providers
We may share your information with trusted third-party service providers who assist us in operating our Service, conducting business activities, or servicing you. These providers are contractually obligated to use your personal information only for the purposes we specify and to protect the confidentiality and security of your data. Examples include:
- Cloud hosting and storage providers
- Analytics and data processing services
- Customer support and communication tools
- Security and fraud prevention services
5.2 Legal Requirements
We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, government agencies). We may also disclose information when we believe it is necessary to:
- Comply with legal obligations or enforce applicable terms of service
- Protect and defend the rights or property of Winter Champions
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of users or the public
5.3 Business Transfers
In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you via email and/or prominent notice on our Service of any such change in ownership or control of your personal information.
6. Data Security
We implement appropriate technical and organizational security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit using SSL/TLS protocols
- Secure data storage with access controls and authentication
- Regular security assessments and vulnerability testing
- Employee training on data protection and privacy best practices
- Incident response procedures for data breach situations
However, please be aware that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider:
- The nature and sensitivity of the information
- The purposes for which we process the information
- Whether we can achieve those purposes through other means
- Applicable legal, regulatory, tax, accounting, or other requirements
When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention and deletion policies.
8. Your Privacy Rights
Under Canadian privacy laws, you have certain rights regarding your personal information:
8.1 Access and Portability
You have the right to request access to the personal information we hold about you and to receive a copy of that information in a structured, commonly used format.
8.2 Correction and Update
You have the right to request that we correct or update inaccurate or incomplete personal information.
8.3 Deletion
You have the right to request deletion of your personal information, subject to certain legal exceptions (e.g., compliance with legal obligations).
8.4 Withdrawal of Consent
Where we process your personal information based on consent, you have the right to withdraw that consent at any time.
8.5 Objection and Restriction
You have the right to object to certain processing of your personal information and to request restriction of processing in certain circumstances.
8.6 Exercising Your Rights
To exercise any of these rights, please contact us using the contact information provided in Section 12. We will respond to your request within 30 days or as otherwise required by applicable law. We may need to verify your identity before processing your request.
9. Children's Privacy
Winter Champions is strictly intended for users who are 19 years of age or older in Canada. We do not knowingly collect personal information from individuals under 19. If you are under 19, please do not use our Service or provide any personal information. If we become aware that we have collected personal information from someone under 19 without verification of parental consent, we will take steps to delete that information promptly.
Parents and guardians who believe that their child has provided personal information to us should contact us immediately so we can delete such information.
10. International Data Transfers
Your personal information may be transferred to and processed in countries other than Canada where our service providers are located. These countries may have data protection laws that are different from Canadian laws. When we transfer personal information internationally, we ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:
- Posting the updated Privacy Policy on our website with a new "Effective Date"
- Sending you an email notification (if you have provided your email address)
- Displaying a prominent notice on our Service
We encourage you to review this Privacy Policy periodically. Your continued use of our Service after we post modifications constitutes your acceptance of the updated Privacy Policy.
12. Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us at:
Winter Champions Privacy Officer
Email: privacy@winterchampions.example
Address: [Your Business Address]
We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and applicable privacy laws.
Important Notice for Canadian Users: This Service is a social game for entertainment purposes only. There are no real money prizes, no financial transactions, and no gambling involved. This is not a casino or gambling service. Users must be 19 years of age or older to access this Service in Canada. We are committed to responsible entertainment and comply with all applicable Canadian privacy and consumer protection laws.
Last Updated: December 14, 2025