Updated: November 15, 2019
- TYPES OF INFORMATION WE COLLECT
- HOW WE COLLECT YOUR INFORMATION
- USE OF YOUR INFORMATION BY MANTICORE GAMES
- SHARING YOUR INFORMATION WITH OTHER COMPANIES
- YOUR CONTROLS, RIGHTS AND CHOICES
- YOUR EUROPEAN UNION PRIVACY RIGHTS
- YOUR STATE-SPECIFIC PRIVACY RIGHTS
- CHILDREN’S PRIVACY
- DATA TRANSFERS, SECURITY, AND LAWFUL BASIS FOR PROCESSING
1. TYPES OF INFORMATION WE COLLECT
We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate information. Personal Information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s first and last name, postal address, email address and/or telephone number. Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual (including an individual’s computing device). Aggregate Information means information about groups or categories of individuals which does not identify and cannot reasonably be used to identify an individual. We may share Aggregate and Anonymous Information with other parties without restriction.
We collect the following categories of information:
- Registration information you provide when you create an account, which may include personal data such as: your first name and surname, country of residence, date of birth, email address, username and password.
- Transaction information you provide when you request information or purchase a product or service from us, whether on our sites or through our applications, including identification information, your date of birth, your postal and/or residential address, telephone number and payment information. If you conduct transactions, we may collect and retain some or all of the information related to these transactions, including transaction amount(s), parties involved, time and manner of exchange, and other transaction circumstances, such as payment method and names or emails of external third-party accounts.
- Information you provide in public forums on our Service. Please note that our sites and applications may offer chat, forums, community environments (including multiplayer gameplay) or other tools that do not have a restricted audience. If you provide Personal Information when you use any of these features, that Personal Information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party. We do not require our users to include sensitive data (e.g., race, ethnicity, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health, sexual life or criminal record) in their account. If you choose to post any such data to your account or public forums on our Service, please understand that it is visible to others as noted above. We have no obligation to keep private any sensitive information or personally identifiable information that you have made available to other users or the public using these functions. To request removal of your Personal Information from a public forum on one of our sites or applications, please contact Customer Support at https://docs.google.com/forms/d/e/1FAIpQLSdpHIY56by19xUTSJjLiCY64SOz5SOxhJU4Cf0HvODOkB0dhg/viewform.
- Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information.
- Content, communications and other information you provide to us, view or engage with when you use our sites and applications, our applications on third-party sites or platforms (such as social networking sites) or link your profile from a third-party site or platform to your registered account. We collect information about how you use our Services, such as the types of content you view or engage with, the features you use, the actions you take, the people or accounts you interact with, and the time, frequency and duration of your activities.
- Location information, with your consent, when you visit our sites or use our applications, including location information either provided by a mobile device interacting with one of our sites or applications, or associated with your internet protocol (IP) address, where we are permitted by law to process this information.
- Usage, viewing and technical data, including your device identifier and features, IP address, web pages you visited prior to coming to our sites, proxy server, operating system, web browser and add-ons, internet service provider or your mobile carrier, and third-party user handles associated with your account when you visit our sites, use our applications on third-party sites or platforms, or open emails that we send. We use log-ins, cookies, device information and IP addresses to identify you and log your use.
- Your marketing preferences.
- Information you share with us in connection with surveys, contests, or promotions.
- Communications that you send to us, such as Customer Support inquiries or other inquiries related to your account.
- Do Not Track: We currently do not employ technology that responds to do not track signals sent by your browser.
Additionally, there are a few special circumstances to note:
- Intellectual Property Claim Notices: If you notify us of an intellectual property claim, the information in your claim notice may be shared with other parties to the disagreement or third parties in our discretion and as required by law;
- Alpha/Beta Service User: If you volunteer to serve as a participant for our pre-commercial content, we may track bug reports and individual system performance in an effort to test our technology rigorously before it is deployed;
- Former Customer: If you discontinue your use of our Service, we may keep your registration file in our database for use in the event that you elect to renew your use of our Service, as well as for anti-fraud and other such protective measures.
2. HOW WE COLLECT YOUR INFORMATION
We collect information you provide directly to us when you request products, services or information from us, register with us, participate in public forums or other activities on our sites and applications, respond to customer inquiries or surveys, or otherwise interact with us. We also record some of this information automatically when you use our Services. We also may receive some of this information from third parties.
- We collect the types of information as outlined in Section 1 and when you visit our sites or applications, when you register and manage your account, when you use our Services, when you purchase a product or services from us, when you post to public forums or chats, if you send us support inquiries, intellectual property claims or other claims, complaints or inquiries, when you participate in contests or promotions, or when we ask you for information for contractual or legal reasons.
- We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.
3. USE OF YOUR INFORMATION BY MANTICORE GAMES
Manticore will be the data controller for your information. We may use your information for the following purposes: We may contract with third party service providers who may have access to your information (as a data processor) where they perform services on our behalf and, unless prohibited under applicable law, for use on its own behalf (as a data controller) for the following purposes:
- Provide you with the products and services you request, such as create and manage your account, process payments, send you emails or other communications about your transactions and Service-related announcements, provide you with customized services based on your preferences
- Communicate with you about your account or transactions with us and send you information about features on our sites and applications or changes to our policies
- Consistent with local law and choices and controls that may be available to you:
- Send you offers and promotions for our products and services or, as permitted, third-party products and services
- Personalize content and experiences on our sites and applications
- Provide you with advertising based on your activity on our sites and applications and on third-party sites and applications
- Administer surveys, contests, or promotions
- Optimize or improve our products, services and operations
- Detect, investigate and prevent activities that may violate our policies (including our Terms of Service) or be illegal, including law enforcement requests
- Verify accounts and monitor activities within our Services to promote safety and security of our Services
- Comply with applicable laws and regulations
- Develop, test, evaluate and improve our Services
- Respond to your inquiries or concerns.
4. SHARING YOUR PERSONAL INFORMATION
Except under certain limited circumstances as set forth herein, Manticore does not disclose to third parties the Personal Information or other account-related information that you provide to us without your permission. You understand, however, that we may disclose your Personal Information or other account-related information under the following circumstances:
- If we believe in good faith that such disclosure is necessary under applicable law, or to comply with legal process served on Manticore;
- In order to protect and defend the rights, safety, property, or interests of Manticore, its products and services, other users of such products and services, and/or others;
- In order to report to law enforcement authorities, or assist in their investigation of suspected illegal or wrongful activity, or to report any instance in which we believe a person may be in danger;
- To service providers with whom we have contracted to assist us with the features or operations (such as anti-fraud functions, billing, collections, registration, customer support, email delivery, age verification, or Core’s operations), to fulfill your service requests, offer new content or help us improve our products and/or services. Our contracts with these third parties prohibit them from using any of your Personal Information for purposes unrelated to the product or services they are providing;
- To other third parties (a) to provide you with services you have requested, (b) to offer you information about our products or services (e.g. events or features), or (c) to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). For instance, we may provide certain information to our payment processor, to credit card associations, banks or issuers (if you are using a credit card), or to providers of other services you request. If you choose to use these third parties’ products or services, then their use of your information is governed by their privacy policies. You should evaluate the practices of third party providers before deciding to use their services; and
- To others if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets) business entities, should we plan to merge with or be acquired by that business entity.
Except as provided above, we We will not share your Personal Information outside of Manticore except in limited circumstances, including:
- When you allow us to share your Personal Information with another company, such as:
- Directing us to share your Personal Information with third-party sites or platforms, such as social networking sites
- Please note that once we share your Personal Information with another company, the information received by the other company becomes subject to the other company’s privacy practices
5. YOUR CONTROLS, RIGHTS AND CHOICES
5.1 Data Retention
5.2 Right to Access and Control your Personal Information
You may exercise your controls, rights and choices, or request access to your Personal Information, by modifying your selections on your account preferences page, following the unsubscribe instructions provided in communications that we send to you, or sending correspondence regarding your request(s) or the communications or services you no longer wish to receive from us to email@example.com
5.3 Account Closure
We retain your Personal Information even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, respond to government investigations, maintain security, prevent fraud and abuse, enforce our Terms of Service or other terms or policies, and protect our and other’s rights. We will retain Anonymous Information and Aggregate Information after your account has been closed. As we do not control data you shared with others, such data will remain visible or accessible.
6. YOUR EUROPEAN UNION PRIVACY RIGHTS
Under certain circumstances, you have rights under data protection laws to access, modify or delete the personal information we hold about you.
If you are based in the European Economic Area, under certain circumstances you have the following rights:
- Request access to your personal information. You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
- Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
- Request erasure of your personal information. You may have the right to request that personal information held about you be deleted.
- Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.
- Request transfer of your personal information. You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.
Also, where you believe that we have not complied with our obligations under this policy or European data protection law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.
You can exercise any of these rights by contacting us using the contact details set out above.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
7. YOUR STATE-SPECIFIC PRIVACY RIGHTS
California residents are permitted by California law to request information about the manner in which we share certain categories of information with others for their marketing purposes. We do not share your personal information with third parties for their direct marketing use unless we have your permission. To withdraw permission previously granted please email us at firstname.lastname@example.org. Once we receive your instructions we will cease sharing your information, but this will not affect previously shared information.
For site visitors from Nevada, we do not transfer Personal Information for monetary consideration. If you would like to tell us not to sell your information in the future, please email use at email@example.com with your name, postal address, telephone number and email address with “Nevada Do Not Sell” in the subject line.
8. CHILDREN’S PRIVACY
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under thirteen (13) years of age. If Manticore learns that personal information of persons under thirteen (13) has been collected on or through our Services, Manticore will take appropriate steps to delete this information.
If you are the parent or legal guardian of a child under thirteen (13) who has provided personal information to Manticore without your knowledge, please contact Manticore at firstname.lastname@example.org to have that child’s account terminated and/or personal information deleted.
For residents of the European Economic Area, where processing of personal data is based on consent, Manticore will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
9 DATA TRANSFERS, SECURITY AND LAWFUL BASIS FOR PROCESSING
9.1 Cross Border Data Transfers
We implement technical, physical and organizational security safeguards designed to protect your data from loss, misuse and unauthorized access and disclosure. We regularly monitor our systems for possible vulnerabilities and attacks. However, given the nature of electronic communications and information processing technologies, we cannot guarantee the security or safety of any information that is sent to us, transmitted through the Internet or stored on our systems. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach by others of any of our physical, technical, or organizational safeguards. In the event that Personal Information is compromised due to a breach of security, Manticore will promptly notify our users in compliance with applicable law.
9.3 Lawful Basis for Processing
We will collect, use, process and store your Personal Information where we have a valid lawful basis. Our lawful bases include one or more of the following:
- Consent (you have given Manticore consent, which you can change at anytime);
- Performance of a contract (our processing is necessary for the performance of a contract we have with you to deliver the Services you have requested, to respond to your inquiries or to take specific steps before entering into a contract with you);
- Legal obligation (processing is necessary for Manticore to comply with laws, regulations and regulatory authorities, court orders or law enforcement requests);
- Vital Interest (processing is necessary to protect your vital interests or vital interests of another person);
- Legitimate interest (improve our business or customer relationships, marketing and advertising, resolve disputes, prevent fraud and abuse, analyze and improve safety and security of our Services, enforce our Terms of Service, to anonymize and subsequently use the information).