Privacy Policy

​1. Scope of this Policy

This Policy describes how BKOM Studios (“BKOM”, “we”, “us”) collects, uses, discloses, and retains your personal information in connection with:

• our website www.bkom.com and its forms (contact, newsletter, job applications); and

• our games and other platforms (collectively, the “Service”).

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This Policy is established in accordance with Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, and other applicable laws depending on your place of residence (e.g., the GDPR for residents of the European Economic Area).

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This Policy does not cover the practices of third parties (platforms, social networks, app stores). A link to a third-party site does not establish any affiliation; we invite you to review their own policies.​

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2. Person in charge of the protection of personal information

Serge Mongeau, President and CEO

Person in charge of the protection of personal information

Email: cprp@bkom.com

Address: 5700, boulevard des Galeries, bureau 300, Quebec City, Quebec G2K 0H5, Canada

Any question, request to exercise your rights, or complaint regarding your personal information should be addressed to this person.

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3. Information we collect

You are not required to provide personal information to access certain parts of the Service; however, some features may then be unavailable to you.

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3.1 Website

• Contact form: name, email address, message content. (Purpose: responding to your request.)

• Newsletter: email address, [first name]. (Purpose: sending the communications you subscribed to.)

• Job applications: name, contact information, resume and submitted documents. (Purpose: evaluating your application.)

• Technical data: IP address, operating system, browser type and language, access times, referring site. (Purpose: operation, security, and improvement of the site.)

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3.2 Games & Products

• Technical Data: We collect a pseudonymized persistent device identifier (generated from a unique hardware signature), IP address, geographic location data derived from your IP address (such as country, region, city, postal code prefix, and time zone), and machine performance telemetry (such as frame rates, frame times, and load times).

  (Purpose: Technical troubleshooting, game optimization, system stability, performance monitoring, and delivering localized content.)

   

• Game Telemetry & Logs: In-game interactions and events including gameplay actions, combat metrics, character progression, inventory and item usage, quest status, and session duration recorded via our analytics infrastructure.

  (Purpose: Game balancing, gameplay feature improvements, defect resolution, and service enhancement.)

   

• Customer Support: Email address and the content of your requests when you reach out to our team.

  (Purpose: Providing customer service, technical troubleshooting, and follow-up support.)

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We only collect information that is necessary for the purposes identified above or as communicated to you at the time of collection.

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3.3 Aggregate statistics

We receive aggregate, anonymous performance reports from Google regarding the display of our business profile in Google Search. This data does not identify you and does not come from any tracking tool installed on our site.

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4. Consent

Your consent is obtained in a manifest, free, and informed manner, for specific purposes and for each distinct purpose:

• subscribing to the newsletter requires an active action on your part (no pre-checked box);

• non-essential cookies and trackers are only activated after your consent (Section 8);

• any use for a new purpose will require new consent, except as otherwise permitted by law.

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Use of the Service does not, in itself, constitute consent. You may withdraw your consent at any time (Section 11), subject to certain features becoming unavailable as a result.

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5. Use of your information

We use your information only for the following purposes:

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• creating and managing game accounts and enabling use of the Service;

• operating, securing, and improving the Service;

• responding to your questions and providing technical support;

• sending you communications necessary to the Service (confirmations, technical notices, security alerts, updates to this Policy) — these essential communications cannot be opted out of;

• with your consent, sending you promotional communications (news, promotions, events) — you may opt out at any time;

• producing internal statistics and understanding usage trends, and

• complying with our legal obligations.

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6. Disclosure of your information

We do not sell your personal information.

We disclose it only in the following cases, to third parties offering a level of protection at least equivalent to our own:

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Service providers acting on our behalf and under our instructions

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​We rely on trusted third-party service providers to support our operations and deliver our Services.

Wix.com Ltd. provides our website hosting, online forms, and newsletter infrastructure, processing browsing data, contact details, and subscriber information.

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For recruitment and talent acquisition, we use Zoho Corporation (Zoho Recruit) to process and manage job application records.

Additionally, we utilize PostHog for product analytics, which processes product usage data along with technical telemetry such as device identifiers, IP addresses, locale, and approximate geo-location.

 

• Business transaction: in connection with a merger, sale of assets, financing, or acquisition, subject to the conditions and obligations provided by law;

• Legal obligations: where required by law, to respond to an order from a court or competent authority, prevent fraud, or protect our rights and the safety of our users, in cases provided by law;

• Aggregate or anonymized data that does not identify you: may be shared with partners for statistical purposes.​

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We do not disclose your personal information to third parties for their own marketing purposes without your express and separate consent.

We do not currently feature advertising within our games or Service, and no advertising networks receive your information through the Service.

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7. Disclosure outside Quebec

Our service providers retain data outside Quebec, notably in the United States (Wix, PostHog, Zoho). Before any disclosure of personal information outside Quebec, we carry out a privacy impact assessment (« évaluation des facteurs relatifs à la vie privée », or PFVP) to ensure that this information benefits from adequate protection, notably through contractual undertakings (data processing agreements with our providers). The laws of these jurisdictions may differ from those of Quebec.

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8. Cookies, trackers, and similar technologies

8.1 On our website

 

Our site uses essential cookies (session, security, remembering your consent choices) as well as, with your consent, functional and analytics cookies. On your first visit, a banner allows you to accept, refuse, or customize non-essential cookies. No non-essential cookie is set before your consent, and you may change your choices at any time via the “Cookie Settings” link at the bottom of the site.

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8.2 In our games and applications

 

Our games use PostHog for product analytics purposes, which may involve collecting device identifiers, approximate geo-location, locale, and IP address, as described in Section 6. We do not currently feature advertising in our games; if this changes, this Policy will be updated and the relevant consent mechanisms will apply. Any tracking features respect platform consent mechanisms (Apple's App Tracking Transparency, Android advertising identifier) and are subject to your prior authorization.

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8.3 Social modules

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Some pages include social network modules (Share, Like buttons). These modules are only activated after your consent to functional cookies and are governed by the policies of the companies that provide them.

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9. Retention and destruction

We retain your information only for as long as necessary for the purposes identified in this Policy or as prescribed by law:

• Game & Product Telemetry: Game logs and analytics data are retained for up to 24 months to support product stability and performance analysis.

• Newsletter Subscribers: Contact information is retained until you choose to unsubscribe.

• Job Applicants (Not Interviewed): If you apply for a position and are not selected for an interview, your personal information (resume, contact details, etc.) is permanently deleted upon position closure, unless you consent to its retention. With your consent, we retain your candidate profile for up to two (2) years following position closure to consider you for future career opportunities.

• Job Applicants (Interviewed): If you participate in an interview (phone or in-person), your application file is retained for three (3) years following position closure. This retention period is required to comply with applicable laws and professional obligations as Chartered Professionals in Human Resources (CRHA), and applies regardless of consent.

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Upon expiry of these periods, your information is permanently and securely destroyed or anonymized in accordance with recognized industry practices.

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Exercising Recruitment Data Rights: You may request access to, rectification of, or withdrawal of consent for your job application data at any time by contacting our Privacy Officer at cprp@bkom.com. Requests will be processed within a maximum of 30 days. Please note that withdrawing your consent cannot shorten retention periods mandated by applicable law or professional obligations.

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10. Security

We apply security measures that are reasonable and proportionate to the sensitivity of the information: encryption of communications (HTTPS/TLS), access control based on the principle of least privilege, [multi-factor authentication on administrator accounts, logging, employee training]. Our providers maintain their own certifications [e.g., ISO 27001, SOC 2]. No method of transmission or storage being infallible, we cannot guarantee absolute security, but we are committed to acting diligently.

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11. Your rights

You have the following rights:

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• Access: to know what information we hold about you and to receive communication of it;

• Rectification: to have inaccurate, incomplete, or ambiguous information corrected;

• Withdrawal of consent: to stop the use or disclosure of your information;

• Deletion: to request deletion of your game data or your account;

• Portability: to receive your computerized information in a structured, commonly used format;

• De-indexation / cessation of dissemination, in cases provided by law.

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To exercise these rights: write to cprp@bkom.com, specifying your request. We will respond within 30 days. If you are not satisfied with our response, you may file a complaint with the Commission d'accès à l'information du Québec (https://www.cai.gouv.qc.ca). Residents of other jurisdictions may contact their own data protection authority.

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To unsubscribe from promotional communications: use the unsubscribe link in each email, or your device settings for push notifications.

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12. Privacy incidents

In the event of a privacy incident presenting a risk of serious harm, we will notify the Commission d'accès à l'information du Québec as well as the affected individuals, and will take reasonable steps to reduce the risks. We maintain a register of all privacy incidents.

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13. Protection of minors

Our games and Service are not directed at children under the age of 13, and we do not knowingly collect their personal information. In accordance with Quebec law, no personal information concerning a minor under 14 years of age may be collected without the consent of the person holding parental authority, except where the collection is clearly for the benefit of the minor. If we learn that we have collected information in contravention of the foregoing, we will delete it. Minors aged 14 to 17 should review this Policy with a parent or guardian.

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14. Automated decision-making

We do not make any decision based exclusively on automated processing of your personal information.

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15. Changes to this Policy

We may amend this Policy. The update date appears at the top of the document. In the event of a significant change, we will notify you at least 30 days before it takes effect, through a prominent notice on the Service or by email. If a change expands the purposes for which your information is used, we will seek your consent again, continued use of the Service alone does not constitute acceptance.