Sad Panda Studios Ltd. and its employees (collectively, "Sad Panda") respect the privacy of its online visitors and users of its products and services. We know that you care about how your personal information is used and shared, and we take your privacy seriously. Please read this Privacy Policy to learn more about how we collect, use and share information from and about you when you play our games or visit our site. Thank you!

This policy is current as of its last revision date. However, please note that this policy may be amended from time to time to reflect changes and additions to the privacy policy. Please check back for the most current version before relying on any of the provisions in this privacy policy.

You must agree with the terms below, if you want to play our games. If you have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy - you should not play our games.

Controller & Data Processing Officer

The “Controller” is the legal person that decides, either alone or together with others, on the purpose and means of processing personal data. The Controller & DPO for our Games is:

Sad Panda Studios Ltd.
PO Box 20022 Towne Centre
Kelowna
BC V1Y 9H2
Canada
Email: [email protected]
Website: https://www.sadpandastudios.com

What information do we collect?

There are several methods by which data can be collected by Sad Panda.

Direct Communications
If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.

Game Play
If you load one of the Sad Panda titles on a supported publisher platform (Steam, Kongregate, Nutaku or other) then we will collect the username of your account so that we may assign or retrieve a unique ID (an SPS ID) to your game session. We do not collect any other information about your account.

If you play one of the Sad Panda titles the game may periodically send completely anonymous game usage information. This information is not tied to your account, your computer, or anything that would allow any sort of unique identification. This anonymous game usage information helps Sad Panda improve their games.

If you save your game using the available cloud save functionality then Sad Panda will store a compressed version of your save game on our servers. The compressed game content does not contain any personally identifiable information. On Steam you are able to opt-out of cloud save via the Settings menu.

If you make an in-app purchase in a Sad Panda game then we will store a record of that purchase. Sad Panda does not store any credit card information, as all payments are processed via a secure third party.

Website
We do not collect browsing information on our website ourselves. However, the embedded Humble Widget, which we use for DLC purchasing, does collect browsing information. You can learn more about about this data collection in the Humble Bundle Privacy Policy. We also use embedded YouTube videos, which only load if you opt into clicking them. If you do click a video link to have it loaded then you should also be aware of YouTube's terms of services.

What about Cookies?

Sad Panda does not store, collect or use cookies within any of our games or our website. However, the web based games do use a type of local browser storage called IndexedDB for storing save game information. By playing our games you consent to the use of local storage in accordance with this privacy policy.

How do we use the information we receive?

We may use the information we collect from and about you to:

• Personalize and improve our Services, and allow you to set up a user account and profile that can be used to personalize your experience in using our Services;
• Answering questions, respond to your inquiries or requests, and communicate with you about our products and services, including specials and new features;
• Develop new products and services;
• Provide you with customized advertising and content on the Services from us and on behalf of our partners and affiliates;
• Research, address problems and improve the usage and operations of the Services;
• Protect the security or integrity of the Services and our business; and
• As described to you at the point of collection.

How is my personal information shared?

We neither rent nor sell your personal information to anyone. We share your personal information only as described below.

Advertisers
We allow advertisers to choose the demographic information of users who will see their advertisements and you agree that we may use any of the information we have collected from you (including information you may have decided not to show to other users) to select or allow the advertiser to select the appropriate audience for its advertisements. For example, we may allow an advertiser to target an ad to you based on your country of residence.

Third Party Business Partners
We may become affiliated with third party businesses that may sell items to you through our Services, or we may provide services, or sell products jointly with these business partners. You can easily recognize when a business partner is associated with your transaction, and you acknowledge that you are providing your personal information to Sad Panda and the business partner for these transactions.

Service Providers
We may share information with our service providers, if the disclosure will enable them to perform a business, professional or technical support function for us.

Business Transfers
In some cases, we may choose to buy or sell assets during the normal course of our business. If Sad Panda, or substantially all of its assets are acquired, goes out of business or enters bankruptcy, our customer information may be one of the assets that is transferred or acquired by a third party. Should such transfers occur, we will use reasonable efforts to try to require that the recipient of the information use your personal information in a manner that is consistent with this Privacy Policy.

Protection of Sad Panda and Others
We may release personal information when we believe in good faith that release is necessary to comply with the law, respond to judicial process, or provide information to law enforcement or regulatory agencies; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Sad Panda, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With Your Consent
We may share information with third parties as described to you at the point of collection or as otherwise disclosed to you upon your consent. As part of our use of information, we may provide aggregate information to our partners about how our customers, collectively, use our Services. We may share this type of statistical data so that our partners also understand how people use the Services, so that they, too, may provide you with an optimal user experience. However, we do not disclose aggregate information to a partner in a manner that would identify you personally.

Social Networking and Chat Forums

Sad Panda's products or services may provide chat, forums, leaderboards, bulletin boards, or instant messaging tools to users. Any information that is disclosed in these services should be considered public information, and users who message one another may not know each other personally. Sad Panda has no obligation to keep private personally identifiable information that a user makes available to other users or the public using these functions. Users should exercise caution when deciding to disclose personal information in public forums. Users should also be aware that game play information disclosed during multiplayer game play (e.g. player name and current player statistics) is public information and may be displayed to other users.

Storage and Security of Personally Identifiable Information

You are responsible for actions taken under your account. To help prevent unauthorized access to your account information we recommend that you limit access to your computer (or other device) and browser by signing off after you have finished accessing your account. We endeavor to protect user information; however, we cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Erasure of Personal Data

Your personal data will be erased or blocked once the purpose of the storage has lapsed. It may be saved beyond that point in time if the latter has been stipulated by the European or national legislative authorities in any European Union regulations, laws or other provisions to which we are subject. Any blocking or erasure of said personal data will also be carried out if a storage period prescribed by said norms expires, unless there is any necessity to continue to store said personal data in regard to the conclusion of a contract or the fulfillment of a contract.

Links to Other Sites

Our games may contain links to other sites and apps. We are not responsible for the privacy policies and/or practices on other sites and apps. When linking to another site or app you should read the privacy policy stated on that site or app.

California Residents

Under California law, our players and customers that are residents of California may request information regarding the disclosure of personal information to third parties by Sad Panda.

If at any time you wish to opt out of having your personal information shared with third parties, and/or would like to unsubscribe from Sad Panda newsletters, services or promotions you may do so by contacting [email protected].

How do I correct or delete my unique Sad Panda account?

You may require us to erase the personal data concerning you without delay. We are obliged to erase said data without undue delay if one of the following reasons applies:

• (a) The personal data concerning you is no longer needed for the purposes for which it was gathered or processed in any other way;
• (b) you revoke your consent, on which the processing pursuant to Art. 6(1)(1)(a) GDPR was based, and there is no other legal basis for the processing;
• (c) pursuant to Art. 21(1) GDPR, you are filing an objection to the processing, and there are no overriding legitimate grounds for the processing, or you are filing an objection to the processing pursuant to Art. 21(2) GDPR;
• (d) the personal data concerning you has been processed unlawfully;
• (e) the erasure of the personal data is necessary in order to fulfill a legal obligation under EU law or the law of the Member States, to which we are subject;
• (f) the personal data concerning you has been gathered in regard to information society services offered pursuant to Art. 8(1) GDPR.

If you wish to make changes to your account, or delete your account completely, you may do so by contacting [email protected]. Please include your SPS identifier, which can be found within the game.

Your Rights

Your right to information
You may request from us a confirmation about whether any personal data concerning you is being processed by us. Should such processing be done by us, you may request the following information from us:

• (1) The purposes for which the personal data is being processed;
• (2) the categories of personal data that are being processed;
• (3) the recipients or categories of recipients to whom the personal data about you has been disclosed or is yet to be disclosed;
• (4) the period of time for which it is expected to store the personal data, or, if it is not possible to give specific details in this respect, criteria for establishing the period of storage;
• (5) the existence of a right to rectify or erase the personal data concerning you, a right to restrict the processing by us or a right to object to such processing;
• (6) the existence of a right to appeal to a supervisory authority;
• (7) any information available on the origin of the data if the personal data is not gathered personally from the data subject;
• (8) the existence of automated decision-making, including profiling, pursuant to Art. 22(1) and (4) GDPR, and – at least in such cases – meaningful information about the logic involved, as well as the impact and the intended effects of such processing upon the data subject.

You are entitled to request information on whether the personal data concerning you is transmitted to an external country or an international organization. In this context, you may request to be informed about the appropriate guarantees under Art. 46 GDPR in connection with the transmission.

Right to rectification
If the personal data processed relating to you is incorrect or incomplete, you are entitled to have your data rectified or completed by us. We will undertake the rectification without delay.

Right to restriction of the processing
You may, on the following prerequisites, request the restriction of the processing of personal data concerning you:

• (1) If you dispute the accuracy of the personal data concerning you for a period of time which enables us to check the accuracy of the personal data;
• (2) if the processing is unlawful and you reject the erasure of the personal data and instead request the restriction of use of the personal data;
• (3) if we no longer need the personal data for the purposes of the processing, however you need it in order to assert, exercise or defend any legal claims; or
• (4) if you have filed an objection to the processing pursuant to Art. 21(1) GDPR, and it has not yet been established whether our legitimate grounds outweigh your grounds.

Should the processing of the personal data concerning you have been restricted, this data may – except for being stored – only be processed with your consent or in order to assert, exercise or defend any legal claims or to protect the rights of another natural or legal person, or for reasons relating to a significant public interest of the EU or a Member State.

Should the restriction of the processing have been carried out in line with the above prerequisites, you will be notified by us before the restriction is lifted.

The right to have your data erased
You may require us to erase the personal data concerning you without delay. We are obliged to erase said data immediately if one of the following reasons applies:

• (a) The personal data concerning you is no longer needed for the purposes for which it was gathered or processed in any other way;
• (b) you revoke your consent, on which the processing pursuant to Art. 6(1)(1)(a) GDPR was based, and there is no other legal basis for the processing;
• (c) pursuant to Art. 21(1) GDPR, you are filing an objection to the processing, and there are no overriding legitimate grounds for the processing, or you are filing an objection to the processing pursuant to Art. 21(2) GDPR;
• (d) the personal data concerning you has been processed unlawfully;
• (e) the erasure of the personal data is necessary in order to fulfill a legal obligation under EU law or the law of the Member States, to which we are subject;
• (f) the personal data concerning you has been gathered in regard to information society services offered pursuant to Art. 8(1) GDPR.

Information passed on to third parties

Should we have published the data concerning you, and should we be obliged, pursuant to Art. 17(1) GDPR, to erase it, we will, taking into account the available technology and the costs of implementation, take reasonable steps, also of a technical nature, to inform the Controllers responsible for the data processing, who processes the personal data, that you, as a data subject, have required all links to said personal data or copies or replications of said personal data to be erased.

Exceptions

The right of erasure does not exist if the processing is necessary

• (a) to exercise the right to freely express an opinion and provide information;
• (b) to fulfill a legal obligation which requires the processing under the law of the European Union or the Member States to which the Controller is subject, or to take on a task which is in the public interest or in exercise of public authority that has been conferred upon the Controller;
• (c) for reasons of the public interest in the field of public health pursuant to Art. 9(2)(h) and (i), as well as Art. 9(3) GDPR;
• (d) for archival purposes or scientific or historic research purposes that are in the public interest, or for statistical purposes pursuant to Art. 89(1) GDPR, in so far as the right mentioned in Section a) will probably make the implementation of the objectives of said processing impossible or seriously impede them; or
• (e) in order to assert, exercise or defend any legal claims.

The right to notification
Should you have asserted the right to rectification, erasure or restriction towards us, we shall be obliged to inform all recipients to whom the personal data concerning you has been disclosed about said rectification or erasure of the data or restriction of the processing, unless this proves impossible or involves disproportionate effort.

You are entitled to assert against us the right to be notified about said recipients. The right to data portability
You are entitled to be given the personal data concerning you, with which you have provided us, in a structured, well-established and machine-readable format. In addition, you have the right to transmit said data to another controller, without any impediment by the Controller to whom the personal data was provided, as long as

• (1) the processing is based on consent pursuant to Art. 6(1)(1)(a) GDPR or Art. 9(2)(a) GDPR, or a contract pursuant to Art. 6(1)(1)(b) GDPR; and
• (2) the processing is carried out using automated procedures.

When exercising this right, you are, moreover, entitled to arrange for the personal data concerning you to be transmitted directly by us to another controller, in so far as this is technically feasible. No freedoms or rights of other persons may be compromised by this.

The right to data portability shall not apply to the processing of personal data that is required in order to take on a task that falls within the public interest or is carried out in exercise of public authority, which has been transferred to us.

The right to object
You are entitled, for reasons arising from your particular situation, to raise an objection at any time to the processing of the personal data concerning you based on Art. 6(1)(1)(e) or (f) GDPR. This also applies to any profiling activities conducted based on these provisions.

We will then no longer process the personal data concerning you unless we can provide evidence of compelling reasons for the processing, worthy of protection, which outweigh your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending any legal claims.

Should the personal data concerning you be processed in order to engage in direct marketing, you are entitled to raise an objection to the processing of personal data concerning you for the purpose of such advertising at any time. This also applies to profiling, in so far as it is connected with such direct marketing.

Should you raise an objection to the processing for direct marketing purposes, the personal data concerning you will no longer be used for said purposes.

In connection with the use of services of the information society, you may, notwithstanding Directive 2002/58/EC, exercise your right of objection using automated procedures that make use of technical specifications.

Right to revocation of any consent under data privacy law
You are entitled to revoke your declaration of consent under data privacy law at any time. The legitimacy of the processing that has been carried out based on the consent prior to revocation is not affected by the consent being revoked.

Automated decisions in the individual case, including profiling
You have the right not to be made the subject of any decision based exclusively on automated processing – including profiling – insofar as this decision has legally valid consequences for you or significantly adversely affects you in a similar manner.

This does not apply if the decision

• (1) is necessary for the conclusion or fulfillment of an agreement between you and us;
• (2) is legitimate based on legislation of the European Union or the Member States to which we are subject and said legislation includes appropriate measures to preserve your rights and freedoms, as well as your legitimate interests; or
• (3) is taken with your express consent.

The right to appeal to a supervisory authority
Irrespective of any other legal remedy under administrative law or any judicial remedy, you are entitled to lodge a complaint with a supervisory authority, especially in the Member State of your place of residence, place of work or the place of the presumed infringement, if you are of the opinion that the processing of the personal data concerning you violates the GDPR.

The supervisory authority with which the complaint has been lodged will inform the Appellant (you) about the status and results of the complaint, including the option of a judicial remedy under Art. 78 GDPR.

What is an SPS ID?

Your SPS ID is a unique identifier that is linked to your player account. For example, if you are playing a Sad Panda game on Steam, then your Steam ID will be used to generate a unique SPS ID that will be associated with your account. The SPS ID is generated by our own server software, which has been built in-house. We took this step to further protect your privacy and to offer a better service to our players. No personally identifiable information (including your IP address, location, or demographic) is stored by our software. Your SPS ID is used to provide cloud save functionality, purchase and receipt verification, as well as customer support for your account. As of writing, the SPS ID is used on all currently released Sad Panda products except the Nintendo Switch versions of Cabin Fever and Hush Hush.

What about Children under 13?

We do not direct the Services or knowingly collect personal information from children under age 13. To provide additional privacy protections regarding the collection of personal information, some of the features on certain Apps are age-gated so that they are not available for use by children.

What if I need to contact Sad Panda Studios?

If you have any questions or complaints about this privacy policy, or the privacy practices of Sad Panda, please contact us at [email protected]. We will make every effort to resolve your concerns.

You may also contact Sad Panda Studios Ltd. at the addresses below:
Sad Panda Studios
PO Box 20022 Towne Centre
Kelowna, BC V1Y 9H2
Canada

Third Party Partners on Mobile

Sad Panda Studios uses the following user acquisition and advertising partners for our mobile games. Please follow the links provided below to read their privacy policies and learn how you may exercise your data subject rights:

• AdColony
• Adjust GmbH
• Apple Game Center
• AppLovin
• Google LLC (Admob)
• Google Play Games
• ironSource
• Kongregate
• Liftoff Mobile
• Meta (Facebook)
• Mintegral
• Pangle
• Phoenix Lighthouse
• Unity Ads
• Vungle

This privacy policy was last updated on October 20th, 2025.

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