21.07.20PRIVACY POLICY – EGS – Grindstone

Last Updated: July 21, 2020


This Privacy Policy details important information regarding the collection, use, processing and disclosure of user information collected about customers, purchasers, subscribers, and/or users of the Grindstone application and game (the “Game”) which is owned and operated by Capybara Games Inc. (“Capybara” or “we” or “us” or “our”) and available through the Epic Game Store (“EGS”). By using the Game you signify your assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Game.



We may collect certain data directly from you automatically via your use of the Game, including non-identifiable game play information from you and/or your device as you use the Game, such as a persistent device identifier, gameplay progress, inventory, items collected and/or unlocked, levels played/replayed/completed, achievements earned, settings, etc. to send to EGS for save games, leaderboards and for achievements.



Use of Information by Us. We may use your information: (1) to improve our Game and to customize your experience with the Game; (2) for internal business purposes; (3) for purposes disclosed at the time you provide your information, and (4) as otherwise set forth in this Privacy Policy.


Third Parties. We may engage vendors, agents, service providers, and affiliated entities to provide services to us. In providing their services, they may access, receive, maintain or otherwise process personal data on our behalf. Our contracts with these service providers do not permit use of your personal data for their own marketing and other purposes.


To EGS. We may send automatically collected non-identifiable game play information to EGS for save games, leaderboards and for achievements.


Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you as may be permitted or required by law or to prevent or investigate suspected fraud or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information and/or communications in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat; or (ii) your conduct that we believe is inappropriate and inconsistent with generally accepted norms of behavior.



If for any reason you are concerned that any information you provided to us is not correct and you wish to change or delete it, you have the ability to review and update your personal information to the extent we have it. If you would like to do so, please contact us as set forth below. You may also contact us to request access to, transfer of, or erasure of your personal information to the extent we have any. Specify the nature of your request and the information that is subject to your request.


We reserve the right not to allow access to your information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent or request transfer or erasure. Please note that changes or access you request may not be effective immediately. Please also note that despite any request for removal of or change to personal information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed.


With regards to automatically collected non-identifiable game play information, we do not retain such information, but instead provide it directly to EGS. Therefore, you may decline to store data in or to send data to EGS.



We do not track cookies or use other tracking technologies.



We rely on the following legal grounds to use your personal data:


• Where it is needed to provide you with our Game.

• Where it is in our legitimate interests to do so, such as: managing our products and services, and providing our Game to you.

• To comply with our legal obligations.

• With your consent or explicit consent, where applicable.

• For a public interest.



Your rights under data protection laws. Here is a list of the rights that individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not.


• The right to be informed about the processing of your personal information.

• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed.

• The right to object to processing of your personal information.

• The right to restrict processing of your personal information.

• The right to have your personal information erased (the “right to be forgotten”).

• The right to request access to your personal information and to obtain information about how we process it.
• The right to move, copy or transfer your personal information (“data portability”).

• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.


If you have any questions or concerns regarding these rights please contact us via the contact information below.


How long is your personal information retained by us. Unless we explain otherwise to you, we’ll hold information based on the following criteria: for as long as we have reasonable business needs, such as managing our relationship with you and managing our operations; for as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or retention periods in line with legal and regulatory requirements or guidance.


Children’s Privacy. This section explains our information practices in connection with information provided by all children under the age of 13, and is applicable to such children. We support the Children’s Online Privacy Protection Act (“COPPA”) and other frameworks like the General Data Protection Regulation (“GDPR”). Our goal is to minimize the information gathered from and disseminated about children while permitting them active participation in the Game.


Types of data and information which may be collected from children includes passively collected non-identifiable and anonymous information such as the non-identifiable game play information and/or persistent device identifier described above for the limited purposes of supporting the internal operations of the Game.

We do not collect or process from children any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about children. We also do not collect or process any financial or payment information, any government identification numbers, any contact information, any microphone and camera sensor data, or any sensitive device data concerning children.


The information collected from Children is collected and processed for the purpose of supporting the Game’s internal operations and/or with a legitimate interest. This means the following:

• providing and improving the Game as well as ensuring proper functioning of the Game;
• maintaining or analyzing the functioning of the Game;
• protecting the security or integrity of the Game;
• ensuring legal or regulatory compliance;
• pursuant to the approval of a child’s legal guardian, in order to supply certain services that such legal guardian or user may have requested.


We may share this information only in limited cases, including the following:

• to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
• to enforce this Privacy Policy, including investigation of potential violations thereof;
• to detect, prevent, or otherwise address fraud, security or technical issues;
• to protect the rights, property, or personal safety of us, our users, or the general public;
• pursuant to the approval of a child’s legal guardian, in order to supply certain services that such legal guardian or user may have requested.


We do not otherwise share your child’s information with any third parties except as provided in this Privacy Policy


If you are a parent, and we need your consent to certain collecting, processing, and sharing of your children’s information, we will delete your child’s information, if any that we may hold, on request. For your child’s protection, we may need to verify your identity before implementing any request described herein. We will try to comply with your request as soon as reasonably practicable.


As noted above, with regards to automatically collected non-identifiable game play information, we do not retain such information, but instead provide it directly to EGS. Therefore, you may decline to store data in or to send data to EGS.


If a parent has any further questions or concerns about his or her child’s use of the Game, we encourage the parent to contact us via the contact information below.


No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any information relating to users of the Game.


Contacting Us. If you have any questions about this Privacy Policy, or have inquiries about your personal data, please contact us at:


174 Spadina Ave. Suite 302
Toronto, Ontario, Canada
M5T 2C2