Manticore Games’ California Privacy Rights Act Notice
Effective Date: January 1, 2023
For purposes of the CPRA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
In the event of a conflict between this CPRA Notice and any of our other privacy policies, this CPRA Notice shall control only with respect to Consumers and their personal information.
California employees (current, former or applicants) can learn about our information collection and disclosure practices and how to exercise their CPRA rights by contacting Human Resources.
Information collected and sources
We collect personal information from you when you interact with us online through our website or mobile applications (collectively the “Site”) or offline. This includes information that you provide to us directly, information we collect from you automatically, information that we collect when you interact with us such as through your online postings, and information that we may collect from third parties such as service providers, affiliated companies, marketing or data partners, or other third parties with whom you interact. It also includes information that we collect about employees and business partners and vendors from those individuals directly or from references, referrals or consumer reporting agencies. Not all information is collected from everyone who interacts with us.
During the past twelve (12) months we may have collected the following categories of personal information:
● Identifiers such as contact information (your name, address, phone number, email or postal address), Unique Personal Identifiers (that may include but are not limited to your legal name or preferred alias and online identifiers like user account names or persistent identifiers in cookies), an encrypted version of your password, communications. We may collect additional information from suppliers, vendors, or employees including business contact information, phone number, email and postal addresses and titles.
● Protected information such as financial and payment information like your credit or debit card information, or PayPal account email address.
● Commercial information such as your transaction histories, billing and shipping information, and product preferences.
● Inferences we make about you or your interests based on analysis of other information we have collected.
● Geolocation information.
● Audio or video information such as call center recordings or monitoring records from our customer support centers and security video recordings at our facilities.
● Employment, education and professional related information, protected classification information, biometrics (collected from current and prospective employees, contractors, service providers, vendors and suppliers, and students).
● Sensitive Personal Information such as social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation.
● Other types of personal information that we may disclose to you prior to the point of first collection.
Processing Sensitive Personal Information
We collect and process Sensitive Personal Information for the purposes disclosed at the time we collect this information. We do not process or disclose this information for purposes other than the purpose for which it was originally collected unless required by law. We use and process Sensitive Personal Information collected from California employees, job applicants or vendors (including racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status) to comply with laws including anti-discrimination laws and disability accommodation laws. We use Sensitive Personal Information from other consumers (including racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status) to provide disability accommodations.
Business Purposes for Collecting Personal Information
We collect personal information in order to operate and grow our business, improve our Site, manage our employees and vendors, and to offer our or third-party products or services that we think you may find of interest. More specifically, we collect personal information for the following business purposes:
● Provide the products, services and information you have requested from us and notices relating thereto including processing and fulfilling your orders, collecting payment, and providing customer support.
● Verify your identity when you create or log into an online account.
● Provide information to you about products that we think may be of interest to you.
● Provide you with marketing communication and information.
● Analyze, improve, and customize our products and business operations including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our users.
● Administer the website, web platform and Services and for internal operations, including troubleshooting, data analysis, testing, research, security, statistical and survey purposes.
● Respond to your inquiries about posted job positions and evaluate employment applications.
● For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention, or fraud.
● Internal and external audit requirements, information-security purposes, and as we otherwise believe to be necessary or appropriate to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, to enforce our terms and conditions or other agreements; and to protect our rights, privacy, safety, or property, or those of other persons.
Disclosing Personal Information
Information disclosed for a business purpose
During the past twelve (12) months we may have disclosed the following categories of personal information to the following types of third parties for a business purpose.
● Our affiliated companies: We may have shared your information such as identifiers, commercial information, and inferences within our company and our affiliated companies for the purposes of decision making, reporting, management, analysis, administering programs, promoting service offerings and other business purposes.
● Service providers: We may have shared your information such as identifiers, commercial information and financial information with our service providers who provide us support services such as hosting our Site, processing payments, legal and accounting professional services, postal delivery and electronic mail, mobile messages, product delivery, conducting analysis to improve our products and Site, fulfilling requests you make, managing payments and answering your questions. Service providers only use the information they receive from us for the purposes we hired them for; we do not allow them to retain, use or otherwise handle the data for their own purposes.
● Marketing Partners: We may have shared your information such as electronic network activity, identifiers, commercial information and inferences with marketing partners to display online, mobile or other advertising based on your activity on websites and mobile apps, and preferences you share with us so we can provide you with promotions and special offers that may interest you. We may also share information with marketing partners to help us analyze data, sometimes combined with other sources, so that we can send more relevant communications to you.
● With Third Parties, including governmental authorities and law enforcement, for legal or compliance purposes: We may share any or all categories of your information where we believe the disclosure is required by law or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies or protect or defend the rights and property of our customers, the company, our partners or the public (including for fraud prevention purposes).
Disclosing Personal Information in Sale Arrangements
We do not sell personal information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and analytics, and security, which may fall under the definition of for “other valuable consideration” and which may therefore be considered a “sale” under the CPRA. We do not sell the personal information of individuals we actually know are less than sixteen (16) years of age. Please see below for opting out of having your information sold. In the preceding twelve (12) months we may have disclosed identifiers and platform activity to third parties such as advertising and analytics providers for a business purpose which falls within the definition of a ‘sale’.
Sharing Personal Information for Cross-Context Behavioral Marketing
Sharing your personal information means making it available to a third party so that they can use it to display targeted or cross-context behavioral advertisements to you. Cross-context behavioral or targeted advertising means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from your activities across other companies’ websites, applications or online services that we use to predict your preferences or interests. Targeted advertising does not include using your interactions with us or information that you provide to us to select advertisements to show you.
Your CPRA Rights
The CPRA provides California residents with specific rights regarding their personal information.
● Information Access Rights
As a California resident you have the right to request that we disclose certain information upon request about our information collection and disclosure practices information. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a twelve (12) month period. Once we receive and confirm your verifiable request, we will disclose to you:
• The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold.
• The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior twelve (12) months along with the categories of recipients of such information.
• The specific pieces of personal information we collected about you during the prior twelve (12) months, or, at your option, since January 1, 2022. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily usable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
● Information Deletion Rights
California residents have the right to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You may make deletion requests at any time. We may deny your deletion request if retaining the information is permitted by one or more of the statutory exceptions. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations.
● Information Correction Rights
California residents have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account. You can make information correction requests at any time.
● Opt Out Rights
• Do Not Sell My Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
• Do Not Share My Personal Information. You have the right to opt out of having your personal information shared with others for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you.
We do not share your personal information with third parties for cross-context or behavioral advertising purposes.
• Limit Processing of Sensitive Personal Information. You have the right to tell us not to process Sensitive Personal Information for any purpose other than the purpose for which we originally collected it.
We only process Sensitive Personal Information for the purpose for which we originally collected it.
How to Exercise Your Rights
We operate exclusively online and have a direct relationship with consumers from whom we collect personal information. In order to make a request for disclosure California residents may contact us by emailing us at firstname.lastname@example.org. You are required to provide information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be.
We will acknowledge receipt of your Access, Correction or Deletion request within ten (10) days and will endeavor to respond within forty-five (45) days of receipt of your request, but if we require more time (up to an additional forty-five (45) days) we will notify you of our need for additional time. Please understand that we cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
For requests for a copy of the personal information we have collected we will endeavor to provide the information in a format that is readily usable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
Opt-Out Rights. To opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral marketing purposes or to ask us to limit processing of your Sensitive Personal Information, you may submit a request to us by emailing us at email@example.com. We will comply with your request promptly, and at least within fifteen (15) business days. Once we receive your request we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing.
You may also opt out by activating a user-enabled global privacy control, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal, we will stop setting third party, analytics, or advertising partner cookies on your browser. This will prevent the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code. If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated.
We will not discriminate against you as a result of your exercise of any of these rights.
Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own Identity directly with us and (5) your agent provides us with proof that they are so authorized.
We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Retention of Personal Information
We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed. We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CPRA for a period of two years.
Changes to This CPRA Notice
We reserve the right to amend this CPRA Notice at our discretion at any time. When we make changes to this Notice, we will post the updated notice on our website and update the Notice’s effective date.
If you have questions or concerns please contact us by emailing us at firstname.lastname@example.org or by postal mail at 1800 Gateway Drive, San Mateo, CA 94404.