Privacy Policy

# Privacy Policy **Last updated and effective:** September 1, 2026 This Privacy Policy explains how Kelli Rose Studios ("Kelli Rose Studios," "we," "us," or "our") handles personal information in connection with the video game *Smack Your Balls* (the "Game"), the website at [https://smackyourballs.com](https://smackyourballs.com) (the "Website"), and related support or communications (together, the "Services"). Kelli Rose Studios is based in Ontario, Canada and is responsible for the personal information under its control. Valve Corporation separately operates Steam and handles Steam account, store, payment, and platform data under Valve's own privacy terms. ## 1. Information We Collect ### A. Information from the Game The Game does not require a separate Kelli Rose Studios account. Game settings, progress, unlocks, and save data are normally stored locally on your device. Local data is not sent to us merely because you play the Game. If Steam Cloud is enabled for the Game, Valve may store and synchronize supported save data through Steam. When you launch or use the Game through Steam, the Game may exchange limited information with Steamworks to provide enabled Steam features, such as: - a Steam account identifier (SteamID) and license or ownership status; - achievement progress and gameplay statistics associated with achievements; - Steam Cloud synchronization, if enabled; and - technical responses needed to initialize Steamworks and provide the Steam overlay or other platform functions. Steam may associate achievements and statistics with your Steam account and may display some of that information on your Steam Community profile according to your Steam privacy settings. We do not receive your Steam password or complete payment-card information. The Game does not contain third-party advertising and is not designed to send independent gameplay analytics or automatic crash telemetry directly to Kelli Rose Studios. If you voluntarily send us a crash report, log, screenshot, save file, or other diagnostic material, we will receive the information contained in that submission. ### B. Information Collected Through the Website When you visit the Website, our hosting and analytics providers may automatically process limited technical and usage information, including: - IP address and approximate location derived from it; - browser, operating system, device type, language, and screen information; - pages viewed, referring page or campaign, dates and times, session duration, and interactions with Website features; - cookie or similar device identifiers; and - request, error, security, and diagnostic logs. We use Google Analytics 4 ("Google Analytics") to understand aggregate Website traffic and improve the Website. Google's default Analytics implementation collects information such as user and session counts, approximate geolocation, and browser and device information. Google Analytics may use first-party cookies, including `_ga` and `_ga_<container-id>`, to distinguish users and sessions. We do not ask Google Analytics to collect names, email addresses, SteamIDs, or other information that directly identifies you. We do not use Google Analytics for targeted advertising, remarketing, or cross-context behavioural advertising. ### C. Information You Choose to Provide If you contact us by email, social media, or another support channel, we may receive your name or username, email address, message, attachments, and any other information you choose to provide. Please do not send passwords, payment-card details, government identification numbers, health information, or other unnecessary sensitive information. The Website does not currently offer a Kelli Rose Studios user account, newsletter sign-up form, or direct payment form. If we add a mailing list, account system, survey, contest, or other form that collects additional personal information, we will provide an appropriate notice at collection and update this Privacy Policy when necessary. ### D. Purchases Through Steam Purchases, refunds, tax processing, and payment authentication on Steam are handled by Valve and its payment providers. We may receive sales reports and transaction-related information needed for accounting, fraud prevention, customer support, or legal compliance, but we do not receive your complete payment-card number from Steam. ## 2. Why We Use Personal Information We use personal information only as reasonably necessary to: - operate, deliver, secure, and troubleshoot the Game and Website; - provide Steamworks features and verify access to the Game; - understand Website performance and improve content and usability; - respond to support, privacy, business, and press inquiries; - investigate abuse, fraud, security incidents, or violations of applicable terms; - maintain business, tax, and legal records; and - comply with law, enforce our rights, or protect users and the public. We do not use personal information to make solely automated decisions that produce legal or similarly significant effects. ## 3. Legal Bases for Processing Where European Economic Area ("EEA") or United Kingdom data-protection law applies, we rely on one or more of the following legal bases: - **Contract:** processing necessary to provide the Game, support, or a service you request. - **Legitimate interests:** operating and securing the Services, responding to inquiries, preventing fraud, and understanding basic Website performance, provided those interests are not overridden by your rights. - **Consent:** non-essential analytics cookies, embedded media, or marketing communications where consent is required. You may withdraw consent at any time without affecting prior lawful processing. - **Legal obligation:** tax, accounting, regulatory, court-order, and other compliance requirements. Where Canadian privacy law applies, we collect, use, and disclose personal information with consent or as otherwise permitted by law, for purposes that a reasonable person would consider appropriate in the circumstances. ## 4. Cookies, Analytics, and Embedded Content Cookies are small files stored by your browser. The Website may use: - **Essential or preference storage** needed to remember privacy choices or provide requested Website functions. - **Google Analytics cookies**, including `_ga` and `_ga_<container-id>`. Google's default expiration for these cookies is two years, although browser restrictions, our configuration, or your choices may shorten that period. - **Embedded-media technologies** used by YouTube when a video player is loaded or used. Google and YouTube may receive technical information and may use cookies or similar technologies according to your settings and their policies. Where the law requires consent, non-essential analytics and embedded-media technologies are activated only after you consent. You can reject or withdraw optional-cookie consent through the Website's privacy controls. You may also block or delete cookies through your browser, although doing so may affect some features. You can learn more or opt out using the [Google Analytics Opt-out Browser Add-on](https://tools.google.com/dlpage/gaoptout). Google explains its data practices in the [Google Privacy Policy](https://policies.google.com/privacy). ## 5. Third-Party Services We use or link to the following services: - **Valve/Steam:** distribution, purchases, license verification, Steamworks, achievements, statistics, Steam Cloud if enabled, and other Steam platform functions. See the [Steam Privacy Policy](https://store.steampowered.com/privacy_agreement/). - **Google Firebase Hosting:** Website hosting, delivery, security, and related technical processing. See [Privacy and Security in Firebase](https://firebase.google.com/support/privacy). - **Google Analytics:** Website measurement and aggregate usage reporting. See the [Google Privacy Policy](https://policies.google.com/privacy). - **YouTube:** embedded trailers and video playback. YouTube is a Google service and is subject to Google's privacy terms. - **Google Drive:** delivery of press-kit files when you choose the press-kit download link. - **External platforms:** links may take you to Steam, Discord, social-media services, or other third-party sites. Their privacy practices apply after you interact with them. These providers may process information in Canada, the United States, or other countries. Their own terms and privacy policies govern information they independently control. ## 6. When We Disclose Information We may disclose personal information: - to service providers that process information for the purposes described in this Policy; - when you ask us to or give consent; - to comply with applicable law, legal process, or a lawful government request; - to investigate or prevent fraud, abuse, security threats, or harm; - to establish, exercise, or defend legal claims; or - as part of a merger, financing, reorganization, sale, or transfer of all or part of the studio or its assets, subject to appropriate confidentiality and legal requirements. We do not sell personal information. We do not share personal information for cross-context behavioural advertising and do not use personal information for targeted advertising. ## 7. International Processing Kelli Rose Studios is located in Canada. Our providers, including Valve and Google, may process information in the United States and other countries where privacy laws may differ from those in your location. Where required, we use provider agreements and other lawful safeguards for international transfers. Information may also be accessible to courts, law-enforcement agencies, or national-security authorities where it is processed, subject to applicable law. ## 8. Retention We keep personal information only for as long as reasonably necessary for the purposes described above, including: - **Support and business correspondence:** generally up to 24 months after the last interaction, unless a longer period is needed for an unresolved matter, legal claim, contract, or legal obligation. - **Google Analytics user-level and event-level data:** up to 14 months, subject to the retention setting configured in Google Analytics. Aggregate reports that no longer identify a particular user may be kept longer. - **Hosting, security, and diagnostic logs:** for the shortest period reasonably necessary for delivery, security, troubleshooting, and provider operations, subject to provider settings and legal obligations. - **Transaction and accounting records:** for the period required by tax, accounting, and other applicable laws. - **Local game saves:** until you delete them or uninstall the Game. Steam-held information, including Steam Cloud data and achievements, is retained under Valve's settings and policies. We may retain information longer when necessary to comply with law, resolve disputes, enforce agreements, or protect the Services. We may retain de-identified or aggregated information that cannot reasonably identify you. ## 9. Security We use reasonable administrative, technical, and organizational safeguards appropriate to the sensitivity of the information we handle. These measures may include access controls, provider security features, encrypted transmission, limited collection, and restricted access. No system or method of transmission is completely secure, so we cannot guarantee absolute security. ## 10. Your Privacy Rights and Choices Depending on your location and subject to legal exceptions, you may have the right to: - ask whether we hold personal information about you and request access to it; - request correction of inaccurate or incomplete information; - request deletion or restriction of processing; - object to certain processing, including direct marketing; - withdraw consent where processing relies on consent; - request a portable copy of information you provided where applicable; and - complain to a privacy or data-protection authority. To make a request, email [Social@smackyourballs.com](mailto:Social@smackyourballs.com) with the subject line "Privacy Request." Describe the request and the Service involved. We may need to verify your identity before responding. We will respond within the period required by applicable law. Some information is controlled by Valve or another provider rather than Kelli Rose Studios. For Steam account, purchase, achievement, statistic, or Steam Cloud requests, use Steam's privacy and account tools or contact Steam Support. We will assist when reasonably possible but cannot directly fulfill requests for information we do not control. Canadian residents may contact the [Office of the Privacy Commissioner of Canada](https://www.priv.gc.ca/) about unresolved concerns. EEA and UK residents may complain to the data-protection authority where they live or work. ## 11. Additional Notice for U.S. Residents In the preceding 12 months, we may have collected the following categories of personal information: online identifiers such as IP address, cookie identifiers, and SteamID when Steam features are used; internet or electronic-network activity; approximate geolocation; device and browser information; transaction-related business records; and correspondence you choose to send us. We collect these categories from you, automatically from your device or browser, and from providers such as Valve and Google. We use and disclose them for the operational, support, analytics, security, and legal purposes described in this Policy. We do not knowingly collect sensitive personal information for the purpose of inferring characteristics about you. Where applicable law grants additional state privacy rights, you may request access, correction, deletion, or a copy of covered personal information, and may appeal a refusal where required. You may also use an authorized agent where permitted by law. We will not discriminate against you for exercising a privacy right. We do not sell personal information or share it for cross-context behavioural advertising. We therefore do not offer a sale-or-sharing opt-out link. If a browser sends a legally recognized Global Privacy Control signal, we will treat it as an opt-out request to the extent applicable to our practices. Other "Do Not Track" signals are handled according to applicable law because there is no universally accepted standard for them. ## 12. Children's Privacy The Services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13. We also do not knowingly use children's personal information for targeted advertising. If you are under the age at which you may consent to data processing in your country, use any feature that submits personal information only with the involvement and consent of a parent or legal guardian. If you believe a child provided personal information to us without appropriate consent, contact us so we can investigate and delete it where required. ## 13. Changes to This Policy We may update this Privacy Policy to reflect changes to the Game, Website, providers, or law. We will post the revised version on the Website and update the date at the top. If a change materially affects how we use information already collected, we will provide additional notice or obtain consent when required. ## 14. Contact Us **Kelli Rose Studios** Ontario, Canada Email: [Social@smackyourballs.com](mailto:Social@smackyourballs.com) Subject: Privacy Request