Privacy Policy

KingsIsle Privacy Statement

Last Updated: September 25, 2020

Please take the time to read this notice carefully

SCOPE AND YOUR AUTHORIZATION

This Privacy Statement ("Privacy Statement") applies to KingsIsle Entertainment, Inc. ("KingsIsle," "we," "us," or "our") websites, online games (such as Wizard101 and Pirate101), communications, advertisements, and other online services and resources that collect data and display or link to this Privacy Statement (collectively, "Online Games and Services"). This Privacy Statement does not apply to websites, games, products, services or other environments that do not display or link to this Privacy Statement or that have their own privacy policies, or information collected from you offline (unless you are a California resident, in which case our Supplemental Privacy Policy for California Consumers applies to information collected from you offline as well, as noted below).

We developed this Privacy Statement in order to be transparent about the data we collect about you and how it is used and shared, as well as the choices and rights available to you with respect to the data we maintain about you.

Our Online Games and Services are operated by KingsIsle in the United States and any personal data submitted through our Online Games and Services will result in the collection and processing of such information in the United States. As a result, if you are visiting or using our Online Games and Services from a country other than the United States, your personal data will cross an international boundary. The level of protection for your personal data in the United States may not be the same as the level of protection in your country.

Please be sure to read this Privacy Statement before using our Online Games and Services or submitting information to us. Our Privacy Statement may change from time to time and your continued use of our Online Games and Services constitutes acceptance of such changes, so please check this area periodically for updates to this Privacy Statement.

CALIFORNIA RESIDENTS: If you are a California resident, please review our Supplemental Privacy Policy for California Consumers (“California Privacy Policy”) available below. The California Privacy Policy provides additional information regarding our collection (both online and offline) and use of personal information about California consumers, and describes the privacy rights granted to California consumers under California law. The California Privacy Policy applies to California residents only.

If you reside in Europe, you must be at least 16 years old to use our Online Games and Services.

HOW YOU CAN CONTACT KINGSISLE

KingsIsle is based in Texas, United States, and develops and publishes high quality online games that appeal to a wide audience. We are responsible for and control the information collected from or about you in connection with our Online Games and Services subject to this Privacy Statement. You can contact us at any time if you have any questions:

KingsIsle Entertainment, Inc.
P.O. Box 5997
Round Rock, TX 78683 USA
E-Mail: Privacy@KingsIsle.com

For residents located in the EU:

We value your data subject rights under GDPR and have appointed GDPR-Rep.eu as our representative according to Art. 27 GDPR, through which you can easily submit privacy related requests. If you want to make use of your data subject rights, please visit: https://gdpr-rep.eu/q/17904698, or contact GDPR-Rep.eu at the following address:

GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o KingsIsle Entertainment Incorporated
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 17904698

INFORMATION WE COLLECT / USE OF YOUR INFORMATION

KingsIsle collects information that can be used to identify or contact a particular person (we refer to this type of data as "personal data"). Personal data may also include information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our Online Games and Services and which if combined with certain other information could be used to identify you.

The information we collect includes information you actively provide to us through our Online Games and Services, certain information collected passively through your use of our Online Games and Services, and information collected from other third-party sources. In addition, we may allow select third-party partners to passively collect certain information from you through your use of our Online Games and Services.

PLEASE NOTE: You may have a separate account for each Online Game and Service that you register for, or you may be able to use a single account across all of our Online Games and Services. In either case, this Privacy Statement applies to your use of our Online Games and Services and each separate environment or component thereof.

Active Information Collection

Much of the personal data we collect from our visitors and players is submitted by visitors/players in response to our requests, such as during the registration process, or in response to polls, forums, promotional offers or other interactivity incorporated into our Online Games and Services. From time-to-time, visitors and players may also submit personal data directly to us via e-mail. The information we actively collect may include some or all of the following:

  • Name
  • Address (including City, State, Country and/or Zip Code)
  • E-Mail address
  • Username
  • Password
  • Gender
  • Poll and survey responses
  • Promotional offers you select
  • Information regarding your computer hardware and network connectivity

We collect, use, store, organize, structure, disclose, or otherwise process this personal data for the following purposes:

  • We process personal data for the purposes for which such personal data was provided. For example, if you share your name and contact information with us when submitting an inquiry or registering to play one of our games, we will use this information to respond to you or provide you with access to the relevant game and manage your account with us. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services, provide, manage and optimize our products and services (including our Online Games and Services), and provide customer support.
  • To engage in direct marketing activities, including to personalize your experience on our Online Games and Services and to deliver content and product offerings relevant to your interests, including targeted offers and ads through our Online Games and Services, third-party websites and games, and via email or text message. The relevant legal basis under European law (where applicable) is our legitimate interest to improve your experience while using our Online Games and Services, promote our products and services, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.
  • To send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with KingsIsle, you generally may not opt out of receiving these communications. The relevant legal basis under European law (where applicable) is our legitimate interest to provide customer support and keep visitors/players information of our practices and terms. In specific circumstances, we may need to engage in these activities in order to comply with an applicable law. Where we process your personal data to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations.
  • To help maintain the safety, security, and integrity of our Online Games and Services, products, databases, and other technology assets. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services and to provide, manage and optimize our products and services (including our Online Games and Services).
  • For internal administrative purposes, such as auditing, data analysis, and research to improve our products, services, and customer communications. This includes processing for purposes of statistical analysis. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services, develop new products and services, and better understand users and their preferences.
  • Where we have legal obligations to process the personal data and for legal proceedings and government investigations (such as pursuant to warrants, subpoenas, and court legal orders).

In addition, we may require you to submit billing information to pay any fees applicable to participation in our Online Games and Services. Depending on the type of payment method, this billing information may include credit card or comparable payment account number, billing address, name on card/account, expiration date and security code. We use this information for purposes of processing your payment and providing you with the Online Games and Services purchased. The relevant legal basis under European law (where applicable) is our legitimate interest to fulfill our obligations under a contract to which you are subject.

Passive Information Collection

As you navigate through our Online Games and Services, other information that does not, on its own, identify any particular individual may be collected. This information includes:

  • Log data. When you use or interact with our Online Games and Services, our servers record certain information that is automatically reported by your browser (such as Apple's Safari, Microsoft's Edge, Google's Chrome, or Mozilla's Firefox) or device each time you request our Online Games and Services, or when content is downloaded to your browser from our Online Games and Services. This "log data" includes your IP address (which is used to infer approximate location); Internet service provider; browser type and settings (for example, content language, cookie/DNT preferences); device information (for example, type of device, operating system, device manufacturer); referring/exiting URL; request/response date and time; "clickstream" data which reflects activities on our Online Games and Services such as the features you visit and in what order; device ID or advertising ID; and data contained in cookies and similar technologies (discussed below). However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data.
  • Location data. Depending on the Online Games and Services and your computer or device permissions, we may collect information about your device's approximate (for example, country or zip code) or precise location ("location data"). Various technologies may be used to collect this location information, such as IP address, GPS, and other sensors that may provide information on nearby devices, Wi-Fi access points, and cell towers. We will only collect your computer's or device's precise location with your consent.
  • Cookie data. Our Online Games and Services also use technologies which are common among websites and online environments to collect and store certain information (such as log data or unique identifiers) when you visit or interact with our Online Games and Services. These technologies include cookies, Web beacons (also known as pixel tags or clear GIFs), statistical identifiers, and similar technologies. A "cookie" is a unique numeric code that is transferred to your computer or device to track your interests and preferences and to recognize you as a return visitor. A "Web beacon" is a transparent graphic image placed on a website that enables the monitoring of things such as user activity and site traffic. "Statistical identifiers" refer to identifiers created using certain device information and identifiers that makes your browser or device sufficiently distinct for a server or similar system to reasonably determine that it is encountering the same browser or device over time.

Our Online Games and Services use cookies and similar technologies to help us secure our Online Games and Services, as well as the information processed by our Online Games and Services; to monitor and enhance the performance of our Online Games and Services; to remember your preferences on our Online Games and Services; to collect "clickstream" data which reflects activities on our Online Games and Services such as the features you visit and in what order; to better understand visitor and user behavior; and to facilitate and measure the effectiveness of advertisements and website features.

The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services, provide, manage and optimize our products and services (including our Online Games and Services), improve your experience while using our Online Games and Services, promote our products and services, provide customer support, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

We may tie personal data actively collected from you to information collected passively as described above or from third parties. In such cases, if we associate non-personal data with personal data, the combined information will be treated as personal data for as long as it remains combined.

Do Not Track

Some web browsers may transmit "do-not-track" signals to websites with which the browser communicates. The webserver for our Online Games and Services does not currently respond to these signals.

Use of Cookies and Similar Technologies by Our Online Partners

We may use vendors and other online partners to perform some of the activities described above, including to provide audience measurement and analytics services, to serve ads on our behalf on our Online Games and Services and on third-party sites, and to track and report on the performance of such ads. These online partners may use cookies and similar technologies to collect and store certain log data, location data, cookie data and other information when you visit or interact with our Online Games and Services and other unaffiliated sites in order to identify your browser or device and provide their respective services. Further, to the extent permitted under applicable law, these online partners may combine data collected on our Online Games and Services with information collected on unaffiliated sites or with any other data maintained by these online partners. Their use of data collected on our Online Games and Services and third-party sites will be subject to their own terms of use and privacy policies.

For example, we may use third-party cookies to deliver our ads on third-party websites through a common form of online advertising known as "retargeting." Retargeting works by serving ads on one website based on an individual's activities on a different website. To do this, we allow our online partners (such as Google or other ad network vendors) to serve their own third-party cookies when users visit our Online Games and Services, allowing these online partners to recognize users who have previously visited our Online Games and Services. When these users visit a third-party website that includes features provided by our online partners (for example, where our online partners have purchased ad space), our online partners can recognize the users' interest in our products and services and deliver one of our ads on the third-party website.

Your Cookie Choices

Most browsers are set to accept cookies by default. However, browsers typically allow individuals to remove or block browser cookies if they choose. For more information on blocking and removing browser cookies, please review your browser's Settings or Preferences tab. More information can be found here:

Google Chrome

Internet Explorer

Mozilla Firefox

Safari (Desktop)

Opera

Opera Mobile

Android Browser

Safari (Mobile)

For other browsers, please consult the documentation that your browser manufacturer provides.

In addition to removing and blocking browser cookies generally, the following opt-out mechanisms may be available if our Online Games and Services utilize the third-party cookies listed below:

  • Google Analytics. Our Online Games and Services may use Google Analytics, a web analytics service provided by Google. Google Analytics utilizes cookies and similar technologies to collect and analyze information about the performance and use of our Online Games and Services. More information on Google Analytics can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google Analytics opt-out available here.
  • Google Retargeting. Our Online Games and Services may use Google's Remarketing with Google Analytics to allow Google to use information about your visits to our Online Games and Services and other unaffiliated websites in order to measure advertising effectiveness and serve ads about our products and services that may be of interest to you. As described above, Google places its own cookies when users visit our Online Games and Services which enable Google to recognize users who have previously visited our Online Games and Services when such users visit other unaffiliated sites that also use Google's services and cookies. More information on Google's Remarketing with Google Analytics can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google Analytics opt-out available here.
  • Google DoubleClick. Our Online Games and Services may use Google DoubleClick to deliver ads based on user preferences. More information on Google DoubleClick can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google opt-out available here.
  • Facebook Custom Audiences. Our Online Games and Services may use Facebook Custom Audiences to deliver ads on Facebook about our products and services that may be of interest to you. More information on Facebook Custom Audiences can be found here. If you would like to opt-out of having your information collected and used as described, please use the opt-out available here.
  • Interest Based Advertising. Our Online Games and Services may use cookies and similar technologies for targeted advertising based on user interests, demographics, and past browsing activity. If you would like to opt-out of having your information collected and used by us for these purposes, please visit:
    • HERE or HERE if you're in the United States
    • HERE if you're in Europe
    • HERE if you're in Canada

The list above identifies some of the third-party cookies we may use on our Online Games and Services. However, we may use other third-party cookies and similar technologies on our Online Games and Services that are not listed here. This list is subject to change at any time and without notice.

BY CONTINUING TO USE OUR ONLINE GAMES AND SERVICES, YOU CONSENT TO THE USE OF COOKIES AND SIMILAR TECHNOLOGIES AS DESCRIBED IN THIS PRIVACY STATEMENT.

INTERACTION WITH SIGN-IN SERVICES AND SOCIAL MEDIA ACCOUNTS

From time-to-time, our Online Games and Services may allow you to log in using sign-in services such as Facebook Connect, Apple’s Game Center, or an Open ID provider. These services will authenticate your identity and may provide you the option to share certain personal data with us such as your name, email address, and resume to pre-populate our sign-up form. Once your identity has been authenticated, we may collect certain information such as the sign-in service used, and a unique identification code associated with the sign-on service.

From time-to-time, our Online Games and Services may also contain functionality which enables you to import profile information or contacts from third party services (e.g., LinkedIn, Facebook, Twitter, Gmail, FourSquare, Instagram, Vine, etc.) (collectively, "Third Party Social Media Accounts"). If you choose to do this, you may have to log into the applicable Third-Party Social Media Account, using such account’s username and password. The copy of the information received by us shall be subject to this Privacy Statement. However, any data maintained by such third-party service and your use of that third-party service will be subject to that third party’s terms of use and privacy policy. You may have the ability to post information from our Online Games and Services to your Third Party Social Media Accounts (including, without limitation, by taking advantages of features such as the Facebook "like" button appearing on our Online Games and Services). All such postings are also subject to the terms of use and privacy policy of the applicable third parties as well as the terms of this Privacy Statement.

The relevant legal basis under European law (where applicable) when processing your personal data for these purposes is our legitimate interest to guarantee the stability and security of our Online Games and Services, provide, manage and optimize our products and services (including our Online Games and Services), improve your experience while using our Online Games and Services, promote our products and services, provide customer support, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We will not sell or otherwise disclose personal data about you, except as described here.

  • Service Providers. In the course of doing business, we employ other companies and individuals to perform a variety of functions on our behalf. For example, we may provide your information to companies that host our Online Games and Services or process credit card information. These service providers may have access to personal data about you if it is needed to perform their functions for us, but they are not authorized by KingsIsle to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.
  • Social Media. As discussed in the "Interaction with Sign-In Services and Social Media Accounts" section above, you may have the ability to share information from our Online Games and Services to your Third-Party Social Media Accounts. Online Games and Services that allow you to do this use social plugins (e.g., the Facebook "Like" button) to enable you to easily share information with others. When you visit our Online Games and Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Online Games and Services. If you are logged into the Third Party Social Media Account (e.g., Facebook) while browsing on our Online Games and Services, the social plugins allow that social media websites to receive information that you have visited our Online Games and Services. The social plugins also allow the social media website to share information about your activities on our Online Games and Services with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our Online Games and Services to your Facebook friends.
  • Online Partners. Please see the "Use of Cookies and Similar Technologies by Our Online Partners" section above.
  • Legally Required. We reserve the right to disclose information if required to do so by law or by a regulatory authority. We may also disclose your information as part of an investigation or enforcement action relating to improper or illegal conduct in connection with our Online Games and Services, including, without limitation, any situations that may potentially involve threats to the safety or privacy of any person, misuse of Online Games and Services or violation of our Terms of Use.
  • Sale or Bankruptcy. During the normal course of our business, KingsIsle may sell or purchase assets. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data provided through our Online Games and Services in a manner that is consistent with this Privacy Statement.
  • Aggregated and Non-Personal Data. KingsIsle may maintain aggregate data or other non-personal data about you, such as usage statistics, online traffic patterns and user feedback. In addition to using this information for the purposes discussed above, KingsIsle may disclose this information to third parties without restriction.

SPECIAL NOTE ABOUT CHILDREN
Users in the United States

Except as described below, KingsIsle will not ask children under the age of 13 who register to use our Online Games and Services hereafter to submit any personal data. The only information requested from children under 13 will be a username and a user password. We may also ask such users to answer one or more security questions that do not request personal data. PLEASE NOTE: it is critical that users under the age of 13 retain their passwords because KingsIsle may not be able to reset the passwords when we have not collected a user or parental e-mail address.

If it becomes necessary to collect personal data from children under 13, KingsIsle will only do so after obtaining verifiable parental consent, as defined under COPPA, or as otherwise permitted under COPPA. For example, COPPA permits collection of personal data where (i) the sole purpose of collecting online contact information from a child is to respond directly on a one-time basis to a specific request from the child, and where such information is not used to re-contact the child or for any other purpose; (ii) the purpose of collecting a child’s and a parent’s name and online contact information is to protect the safety of a child; or (iii) KingsIsle collects online contact information of the child’s parent or guardian to obtain parental consent or to provide voluntary notice and/or updates to the parent or guardian about participation in our Online Games and Services.

On our Online Games and Services, we offer many features, such as the ability to view or download game content or images, news, or participate in forums, which do not require a child to provide any personal data. KingsIsle will not condition a child’s participation in any online activity on the child’s disclosure of more personal data than is reasonably necessary to participate in that activity. We also may enable users to chat online through our Online Games and Services, but we take measures to limit users’ ability to communicate personal data through this chat function.

Parental Review of Personal Data

In certain circumstances on some of our Online Games and Services, parents will have the ability to set up parental accounts to administer their children’s accounts and review the personally data maintained by KingsIsle from such accounts. Parents or guardians may establish a parental account during the initial registration process for the child’s account or, subsequently, through the account management features applicable to the child’s account. Although a child over the age of 13 may register without the electronic consent of a parent or guardian, a parent or guardian may also submit a request to KingsIsle at the contact information below to review any personally data from such child. However, such requests will be subject to the parent or guardian demonstrating proper identification to KingsIsle’s satisfaction after reasonable investigation

Users located in Europe

If you reside in Europe, you must be at least 16 years old to use our Online Games and Services. Our Online Games and Services are intended for general audiences and we do not knowingly collect any personal data from children in Europe under the age of 16. If it becomes necessary to collect personal data from children under 16 (in Europe), KingsIsle will only do so after obtaining verifiable parental consent or as otherwise permitted under applicable law. If you believe that a minor of whom you are a parent or guardian has provided us with personal data, please contact us at Privacy@KingsIsle.com and we will make reasonable efforts to remove all personal data related to the minor.

CHOICES YOU HAVE ABOUT HOW KINGSISLE USES YOUR INFORMATION

You have the following choices regarding the personal data we collect or otherwise process about you:

You may send us an e-mail message at Privacy@KingsIsle.com to request access to review, correct or delete any personal data maintained on our systems that you or your child has provided to us through Online Games and Services registration process or other request. To protect your privacy, we will respond only to e-mail messages sent from the e-mail account that you specified (or was given by your child) during the account registration process.

You may also opt out of receiving newsletters and other promotional materials from KingsIsle by notifying us at Privacy@KingsIsle.com.

YOUR RIGHTS

You have various rights with respect to the collection, use, transfer and processing of your personal data, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified by KingsIsle or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the contact information provided in the " HOW YOU CAN CONTACT KINGSISLE" section above.

Access Right

You have the right to obtain confirmation as to whether or not your personal data is being processed by KingsIsle. Where we are processing your personal data, you have the right to access the data and to obtain certain information about the processing of such data.

Right to Rectification

You have the right to obtain rectification of any personal data that is inaccurate or incomplete, including by means of providing a supplementary statement, subject to any limitations or exceptions under applicable law.

Right to Erasure

You have the right to have your personal data erased in certain circumstances, subject to any limitations or exceptions under applicable law.

Right to Restriction of Processing

If you reside in the European Union (or if otherwise required under applicable law), you have the right to restrict the processing of your personal data where one of the following applies:

  • The accuracy of the personal data is contested.
  • The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead.
  • KingsIsle no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims.
  • Where the processing is based on KingsIsle's (or a third party's) legitimate interest and you have objected to processing (as described below).

Right to Object

If you reside in the European Union (or if otherwise required under applicable law), you have the right to object (on grounds relating to your particular situation) at any time to the processing of your personal data for direct marketing purposes or where the processing is based on KingsIsle's (or a third party's) legitimate interest. When objecting to processing based on our legitimate interest, KingsIsle will no longer process your personal data unless KingsIsle demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Withdraw Consent

Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.

Right to Data Portability

If you reside in the European Union (or if otherwise required under applicable law), you have the right to receive your personal data, which you have provided to KingsIsle, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another entity without hindrance from KingsIsle, subject to any limitations or exceptions under applicable law.

Right Not to Be Subject to Solely Automated Decisions

If you reside in the European Union (or if otherwise required under applicable law), you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.

Right to Submit a Complaint to Supervisory Authorities

If you reside in the European Union (or if otherwise required under applicable law), you have the right to lodge a complaint with an applicable data protection authority. If you reside in Europe, you have the right to lodge such a compliant in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.

California Residents: If you are a California resident, please see our California Privacy Policy below for additional information regarding your rights under California law, including how to exercise such rights.

HOW KINGSISLE PROTECTS YOUR INFORMATION

We work hard to protect your personal data. We use both technical and procedural methods to maintain the integrity and security of our databases, including giving users a unique user name and password for access to our Online Games and Services, SSL encryption for data transfer, firewalls, and restricted access to data.

However, the safety and security of your information also depends on you. You should never share your password with anyone else and you should always logoff before leaving your computer or device. You should also use password security on your device itself. If you believe someone has unauthorized access to your password or account, please contact us promptly.

Our Online Games and Services may contain links to other websites operated by third parties that may be of interest to you (including links embedded in advertising appearing on components of our Online Games and Services or related applications). When you follow a link and leave our Online Games and Services, you do so at your own risk because we do not control such third-party websites.

RETAINING YOUR PERSONAL DATA

We generally retain personal data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain information for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period.

CONSENT TO PROCESSING YOUR INFORMATION IN THE UNITED STATES AND ELSEWHERE

Our Online Games and Services are owned and operated by KingsIsle in the United States, but the information you provide will be accessible to our affiliates, vendors, and suppliers in other countries. Furthermore, if you are visiting our Online Games and Services from a country other than the United States, any information we collect or you provide will necessarily result in the transfer of information across international boundaries. The level of legal protection for such information is not the same in all countries; however, we will take the security measures described in this Privacy Statement in an effort to keep your information secure. By using our Online Games and Services, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

YOUR CHOICE TO EXCHANGE INFORMATION WITH OTHER USERS

Our Online Games and Services may also include forums, chat functionality or other features where you can exchange information or otherwise interact with other users of our Online Games and Services. When you do so, you understand that all information transmitted will be made available to and accessible by KingsIsle and applicable users. You have no expectation of privacy in connection with such communications. KingsIsle is not responsible for whether or how such third parties utilize the information you post or share through such features.

EFFECTIVE DATE; CHANGES

This Privacy Statement is effective as of September 25, 2020.

KingsIsle reserves the right to change its privacy policy in its sole discretion. In such case, KingsIsle will post the new Privacy Statement on Online Games and Services and the effective date of the new Privacy Statement will be clearly marked.

Supplemental Privacy Policy for California Consumers

Last updated: September 25, 2020

This Supplemental Privacy Policy for California Consumers (“California Privacy Policy”) provides additional information required under the California Consumer Privacy Protection Act (CCPA) regarding the personal information we collect from and about California residents, and describes the rights granted to California residents under the CCPA.

This California Privacy Policy applies to information collected from or about California residents only. This California Privacy Policy is broader in scope than our Privacy Statement because it applies to any and all personal information about California residents collected by KingsIsle, including personal information collected in connection with our Online Games and Services and Mobile Games/Apps, as well as personal information collected online and offline.

Definitions Specific to California Privacy Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to KingsIsle’s other Privacy Statements, including the following terms:

Personal information” (regardless of whether such term is capitalized or not) means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information obtained from government records or deidentified or aggregated consumer information.

Sell,” “selling,” “sale,” or “sold” (regardless of whether such terms are capitalized or not) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer‘s personal information by the business to another business or a Third Party for monetary or other valuable consideration.

Service Provider” means certain for-profit legal entities that process information on behalf of KingsIsle and to which we disclose your personal information for a defined business purpose pursuant to a written contract that prohibits this service provider from retaining, using, or disclosing your personal information for any purpose other than for the specific purpose of performing the services specified in the contract with us.

Third Party” means another business that collects or receives your personal information, other than a Service Provider.

All other capitalized terms used but not defined in this California Privacy Policy shall have the meanings ascribed in our Privacy Statements.

Personal Information Collection and Use

KingsIsle has collected the following categories of personal information about California consumers in the preceding twelve (12) months:

  • Identifiers and contact information, including full name, player/user ID, postal address, telephone number, email address, date of birth, account name, IP address, online identifier, social network or platform account username/handle, device ID, and mobile advertising ID.
  • Commercial information, including games played, in-app purchases and other products and services purchased, survey responses, content posted on forums and discussion boards, Online Games and Services preferences, Mobile Game/App preferences, in-game activities, character development and character interaction, and other purchasing and consuming histories and tendencies.
  • Financial information, including credit or debit card number and payment amounts.
  • Internet activity information, such as log data, browsing history, cookie data, referring/exiting URL, clickstream data, time spent on our Online Games and Services and Mobile Games/Apps, and other information regarding user interaction with our Online Games and Services, Mobile Games/Apps, other websites and apps, emails, and advertisements.
  • Geolocation data, including approximate or precise device location.
  • Physical/demographic information, such as age (or age group) and gender.
  • Photographs, such as a player/user profile photo.
  • Written signature, such as a signature on a parental consent form.
  • Inferences drawn from any of the information listed above to create a profile about a California consumer reflecting the individual’s preferences, characteristics, behavior, or abilities.

KingsIsle collects the categories of personal information identified above from the following categories of sources:

  • You (directly from consumer/user).
  • Parents and legal guardians.
  • Your computer and mobile device (automatically) when you visit or interact with our Online Games and Services and Mobile Games/Apps.
  • Social media platform providers.
  • Payment processors and other financial institutions.
  • Vendors who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
  • Vendors who assist with fraud prevention, detection, and mitigation.
  • Network advertising partners.
  • Mobile app store/marketplace providers (e.g., Apple, Google).
  • Vendors who assist with our information technology and security programs
  • Data aggregators and public databases.
  • Internet service providers.

KingsIsle collects the categories of personal information identified above for the following purposes:

  • Creating and managing your account.
  • Providing you with customized content, targeted offers, and advertisements.
  • Contacting you regarding polls and surveys.
  • Addressing problems and reviewing the usage and operations of our Online Games and Services, Mobile Games/Apps or business, and improving our content, products, and services.
  • Fulfilling and tracking purchases and processing payments.
  • Providing you with access to forums and chat rooms.
  • Responding to your inquiries and contact you.
  • Engaging in direct marketing activities, including to personalize your experience on our Online Games and Services and Mobile Games/Apps, and to deliver content and product offerings relevant to your interests, including targeted offers and ads through our Online Games and Services, Mobile Games/Apps, third-party websites and games, and via email or text message.
  • Maintaining the safety, security, and integrity of our Online Games and Services, Mobile Games/Apps, products, databases, and other technology assets.
  • Internal administrative purposes, such as auditing, data analysis, and research to improve our products, services, and customer communications. This includes processing for purposes of statistical analysis.
  • Developing new products or services and improving existing products and services.
  • Remembering your preferences on our Online Games and Services and Mobile Games/Apps.
  • Tracking accurately numbers of users or referring websites or advertisements to our Online Games and Services and Mobile Games/Apps.
  • Keeping track of your in-game activities, character development and character interaction.
  • Allowing our Online Games and Services and Mobile Games/Apps to interact with third party social networks or platforms (where you have chosen to allow such interaction).
  • Identifying you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with our Online Games and Services, Mobile Games/Apps, and advertisements.
  • Comply with laws and regulations.
  • Monitor, investigate, and enforce compliance with and potential breaches of policies and procedures and legal and regulatory requirements.
  • Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
  • Exercise or defend the legal rights of KingsIsle and its employees, affiliates, customers, contractors, and agents.

Personal Information Disclosures

In the preceding twelve (12) months, KingsIsle has disclosed for a business purpose the categories of personal information identified below to the associated categories of Third Parties listed.

CATEGORIES OF PERSONAL INFORMATION DISCLOSED TO THIRD PARTIES IN PRECEDING 12 MONTHS

CATEGORIES OF THIRD PARTIES TO WHOM
PERSONAL INFORMATION IS DISCLOSED

Identifiers and Contact Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Internet service providers.

Third Parties who deliver our communications, such as the postal service and couriers.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Other users/players.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Commercial Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Other users/players.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Financial Information

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Internet Activity Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Internet service providers.

Third Parties who deliver our communications, such as the postal service and couriers.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Geolocation Data

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Internet service providers.

Third Parties who deliver our communications, such as the postal service and couriers.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Physical/Demographic Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Other users/players.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Photographs

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Other users/players.

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Written Signature

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Inferences

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

KingsIsle does not sell personal information about California consumers. Without limiting the foregoing, KingsIsle has no actual knowledge that it sells the personal information of minors under 16 years of age.

Your California Rights

If you are a California resident, you have the following rights under the CCPA with respect to your personal information:

  • Right to Notice. Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it.
  • Right of Access (“Request to Know”). You have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of personal information disclosed or sold, and the categories of third parties with whom we shared or sold the personal information. You also have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
  • Right to Deletion (“Request to Delete”). You have the right to request that we delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right to Opt-Out of the Sale of Personal Information. KingsIsle does not sell your personal information as the term is defined based on our understanding of the CCPA. We have not sold any personal information to third parties for business or commercial purposes in the 12 months prior to the effective date of this California Privacy Policy.
  • Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.

You can exercise your rights by contacting KingsIsle as described in the Contact Us section below.

Request Verification

We value the security and confidentiality of your personal information. Therefore, if you submit a Request to Know or Request to Delete, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully. Along with your request, we will ask that you provide us with certain information previously collected from you, such as your email address, phone number, postal address, or other information as appropriate.

Authorized Agent

If you are making any of the requests above as an authorized agent, we will require notarized written authorization or a notarized Power of Attorney. Additionally, we will seek to verify your identify in the manners stated above (depending on the request type). To make a request using an authorized agent, please email us at Privacy@KingsIsle.com.

Additional Information

We will maintain records of requests that are made that include the date of request, nature of request, manner in which the request was made, the date of our response, the nature of our response, and the basis for any denial of the request if it is denied in whole or part.

You are not required to create an online account with us in order to exercise your rights.

Contact Us

If you have any questions or concerns about KingsIsle’s privacy policies and practices, please contact us at the contact information listed below:

U.S. Mail

KingsIsle Entertainment, Inc.
Attn: Privacy Department
P.O. Box 5997
Round Rock, TX 78683
United States

Email

Privacy@KingsIsle.com

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