MANTICORE GAMES’ PRIVACY POLICY

Effective:  January 1, 2024

Manticore Games, Inc. (“Manticore”) respects the privacy of its online visitors and users of its websites, products and services, including communication services, (collectively, the “Services”). We recognize the importance of protecting information collected from our users and have adopted this Privacy Policy to inform you about how we gather, use, process, store and disclose your information, including personal information, in conjunction with your access and use of our Services.

By using our Services, you confirm that you have read and understood this Privacy Policy. We will not share your personally identifiable information except as described herein.

  1. TYPES OF INFORMATION WE COLLECT
  2. HOW WE COLLECT YOUR INFORMATION
  3. USE OF YOUR INFORMATION BY MANTICORE GAMES
  4. SHARING YOUR INFORMATION WITH OTHER COMPANIES
  5. YOUR CONTROLS, RIGHTS AND CHOICES
  6. YOUR EUROPEAN UNION PRIVACY RIGHTS
  7. YOUR STATE-SPECIFIC PRIVACY RIGHTS
  8. CHILDREN’S PRIVACY
  9. DATA TRANSFERS, SECURITY, AND LAWFUL BASIS FOR PROCESSING
  10. CHANGES TO THIS PRIVACY POLICY; COMMENTS AND QUESTIONS

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:

Additionally, there are a few special circumstances to note:

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.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, through our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this Privacy Policy and the information that the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.

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:

Manticore uses cookies to perform authentication of your account, show you accurate information, personalize your experience (including communication preferences, features and customized content), enable and support our security features, help us detect malicious activity, conduct marketing campaigns and track their performance, and improve our services.

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:

Except as provided above, we will not share your Personal Information outside of Manticore except in limited circumstances, including:

5.   YOUR CONTROLS, RIGHTS AND CHOICES

5.1 Data Retention

We retain your Personal Information while each of your accounts is in existence or as needed to provide you with Services.  We also retain your Personal Information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations.  If required by law or if the information is subject of a legal request or governmental investigation, we retain certain financial transaction information and Personal Information for as long as we are required to comply with applicable laws, regulations or such legal process or investigation.  We also retain Personal information in order to protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

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 privacy@manticoregames.com 

5.3 Account Closure

You may close your account by submitting a request to us. If you choose to close your Manticore account, we retain information for the purposes set out in this Privacy Policy and as noted below.

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 others’ 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:

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

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 privacy@manticoregames.com 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 operate globally and may transfer your information or Personal Information to individual companies of Manticore or third parties in locations around the world for the purposes described in this Privacy Policy. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that your information may be transferred to a country or jurisdiction that does not have the same data protection laws as your jurisdiction and you consent to the: (1) transfer of information to the U.S. or any other country in which Manticore or its subsidiaries, affiliates or service providers maintain facilities; and (2) the use and disclosure of information about you as described in this Privacy Policy. Whenever your Personal Information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Information in accordance with applicable law.

9.2 Security

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:

10.   CHANGES TO THIS PRIVACY POLICY; COMMENTS OR QUESTIONS

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you through our Services if these changes are material and, where required by applicable law, we will obtain your consent.  If you object to any changes, you may close your account. You acknowledge that your continued use of our Service after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

If you have a comment or question about this Privacy Policy or our privacy practices, please send an email to privacy@manticoregames.com.