Effective May 25, 2018
- Your Privacy Rights
- Our Privacy Program Certifications
- Our Policies Concerning Children
- What Personal Information We Collect from You
- What Non-Personal Information We Collect from You
- Information on Cookies and Related Technology
- How We Use and Share the Information We Collect from You
- Information about Links and Third Parties Related to the Sites
- How You May Access, Change or Delete the Information You Have Provided to Us
- Privacy Disclosures for California Residents
- Privacy Disclosures for Residents of the European Union
- Information for Persons Outside the United States
- Notice to Minors
- Security of Personal Information Collected
- Contact Us
2. YOUR PRIVACY RIGHTS
- You can send mail or email expressly making such request to: Trion Worlds, Attention: Privacy Officer, 2400 Bridge Parkway, Suite 100, Redwood City, CA 94065 or email@example.com; or
- You can access your user profile and modify your privacy preferences by opting-out of direct marketing communications from Trion and/or our third party marketing affiliates; or
- You can find additional information from the Trion Support page at https://support.trionworlds.com/hc/en-us/articles/204400287-Contacting-Trion-Support or submit a Support Request here https://support.trionworlds.com/hc/en-us/requests/new.
- Upon receipt of any electronic marketing communication from us, you can click on a link on the bottom of such communication to “unsubscribe” from any future marketing communications from us.
In the event that you contact us with a specific request or “opt in” to Trion communications, including but not limited to participating in services, events, sweepstakes, contests and/or promotions, after choosing to opt out, we reserve the right as is permitted by applicable laws, to transmit communications containing transactional or relationship content to you as necessary. We will take reasonable steps to ensure that such communications will be limited to the scope of your request and/or the subject matter of your “opt in.” You hereby acknowledge that it is your responsibility to renew your “opt out” request after you choose to “opt in” as set forth above.
3. OUR PRIVACY PROGRAM CERTIFICATIONS
OUR CERTIFICATION UNDER ESRB PRIVACY CERTIFIED
DISCLAIMER: Although ESRB Privacy Certified does not monitor our non-English language Sites, we make all best efforts to ensure that non-English language Sites adhere to applicable data collection guidance and principles set forth by ESRB Privacy Certified, including adherence to the EU and other jurisdiction’s regulations.
OUR CERTIFICATION under the PRIVACY shield FRAMEWORK
In compliance with the Privacy Shield Framework, Trion commits to resolve complaints regarding our collection or use of your Personal Information. Individuals in European Union member countries and Switzerland with inquiries or complaints regarding Trion’s Privacy Shield policy should first contact Trion at firstname.lastname@example.org.
Trion has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain limited conditions, individuals may invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information go to https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Additionally, at any time, a European Union or Swiss individual may submit a complaint directly to his or her local European Union data protection authority or the Swiss Federal Data Protection and Information Commissioner, as applicable.
Trion is responsible for the processing of Personal Information it receives under the Privacy Shield that is subsequently transferred to a third party acting as an agent on our behalf. Trion may be liable under the Privacy Shield Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the Trion proves that it is not responsible for the event giving rise to the damage.
4. OUR POLICIES CONCERNING CHILDREN
If parents believe that we have unintentionally collected their child’s Personal Information, they should contact us at Trion Worlds, Attention: Privacy Officer, 2400 Bridge Parkway, Redwood City, CA 94065 or email@example.com to request the deletion of the information.
5. WHAT PERSONAL INFORMATION WE COLLECT FROM YOU
Personal information is any information relating to an identified or identifiable individual, such as your name (first and surname together), email address, postal address and/or phone number, and online identifiers (“Personal Information”). Visitors purchasing products or services will be required to provide additional Personal Information such as a valid credit card number, expiration date and shipping and billing addresses. With the exception of certain technical information later described, we do not collect any Personal Information from you unless you provide it to us voluntarily (e.g. through interaction or registration with the Sites).
If you decide to provide us your Personal Information, it will generally be for: (1) account or product registration, or registration for online game participation; (2) the purchase of goods or services through our online store (including the purchase of in-game digital items (“Virtual Items”)); (3) message boards or forums; (4) newsletters; (5) e-cards or Invite a Friend promotions; (6) sweepstakes or contest registrations or surveys; (7) customer service or technical support; (8) consumer complaint(s); and (9) social media interaction.
ACCOUNT OR PRODUCT REGISTRATION AND ONLINE GAME PARTICIPATION
When you play any of the Games offered and/or served by Trion, or use any of the communication features on the Site, your Internet Protocol address (the unique number assigned to your server or Internet Service Provider) (your “IP Address”) from which you access any of the above may be stored in our records. Trion may track such IP addresses for system administration, to report aggregate information, Site tracking, security purposes, or to prevent our servers from being abused.
When any Game is updated or “patched,” our patch routine may check your computer to see that you have the most recent version of Game-specific files; when you communicate within any Game or any other communication feature within the Sites (e.g. live chat, instant message services and the like), even “privately” to another person, you do so with the understanding that those communications go through our servers. You expressly agree to waive any rights of confidentiality that you may have in and to your communications (if any) when using any of the Sites’ communication features, you agree you have no expectation of privacy in any of those communications; and, accordingly, where and to the extent permitted by applicable law, you expressly agree to monitoring of communications (including technical support and customer service communications) that you send and receive. When you log in to one of our Games, your system specifications (such as OS, RAM, video card, monitor, system configuration, crash data, diagnostic data, etc.) may be reviewed/recorded by us for the purposes of analyzing and optimizing your Game experience and in order to provide you with customer service.
Prior to May 2018, users’ payment method details were automatically saved in order to facilitate future transactions. Trion’s latest purchase flow permits users to choose to have their payment method stored and those who do not wish to have their payment method stored can choose a one-time purchase option. Users have the ability to access, change and delete their payment method details through their Account.
MESSAGE BOARDS OR FORUMS
Please take note that information you post to the public areas of our Sites, which include but are not limited to, message boards, forums, chat rooms, and/or profiles, if applicable, will be displayed publicly and we cannot prevent further use of the information by third parties.
NEWSLETTERS AND INVITE A FRIEND PROMOTIONS
Typically you need to have an Account in order to receive emails from us, provided that you may receive email communications from us on a one-time basis if you have contacted us directly with regard to a specific request or for email newsletters. You can opt-out of receiving future marketing emails from us by following the directions contained in the email to “unsubscribe.”
Notwithstanding your email preferences, from time to time, Trion may send a transactional or relationship message which provides information concerning a transaction you have agreed to, your membership, subscription or account and/or warranty or safety information.
Also, except in jurisdictions where it may be prohibited by law to do so, the Site or service offerings available thereon may allow you to submit information about other people. For example, we may offer “Invite a Friend” promotions, like electronic postcards available on the Site or through our newsletters. In these situations, you may provide the email address and, sometimes, the name of a friend. After the “Invite a Friend” transaction is completed, that information is deleted. We will not retain the recipient’s email address for longer than necessary to complete the transmission. In our communication to your friend in this circumstance, he or she will only receive further information from us if he or she has affirmatively opted-in to receive future emails from us.
SWEEPSTAKES, CONTESTS, AND SURVEYS
CUSTOMER SERVICE, TECHNICAL SUPPORT OR CONSUMER COMPLAINTS
In order to resolve issues related to customer service, billing questions, technical and computer support, etc., we require you to provide us with the information necessary to look up your Account (e.g. billing information including personal information such as your billing and/or shipping address) so that we may resolve such issues properly.
SOCIAL MEDIA INTERACTION
RESUME SUBMISSIONS AND BUSINESS CAPACITY
INDIRECT COLLECTION OF PERSONAL INFORMATION
6. WHAT NON-PERSONAL INFORMATION WE COLLECT FROM YOU
General, aggregated, demographic, and non-Personal Information may be collected by Trion. This type of anonymous, aggregated profiling and session data includes information that you have provided to us through surveys, polls, etc., and is combined with your IP address.
As part of the registration process for some services, you will be asked to provide information that does not personally identify you. For example, you will be asked to provide information concerning your date of birth, country, entertainment preferences, purchasing habits, and the like. This information is generally optional, but where provided it will be included in your Account profile and you hereby agree to this information being tied to your Personal Information. Trion requests this information to understand you better and to also bring to your attention new services, programs, or offers that may be of interest to you. Where Trion automatically collects non-Personal Information as stated above, and it is possible to link this information to your Personal Information, you hereby agree to Trion linking relevant non-Personal information to your Personal Information.
7. INFORMATION ON COOKIES AND RELATED TECHNOLOGY
The Sites, and some services and advertisements displayed or made available thereon, may contain “cookies.” Cookies are a feature of your web browser which allow websites to transfer bits of information to your computer for recordkeeping purposes. A cookie stored on your computer can be used to “remember” things such as your password or that you have already registered an Account. This enables us to accelerate your future activities, saving the time that you would otherwise spend entering information such as your username or password.
Trion (itself or through a third party service) also employs a software technology called clear GIFs (also known as “web beacons”) that helps us better manage content on our Sites by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded invisibly on Site pages and are about the size of the period at the end of this sentence. These clear gifs are tied to unique identifiers such as your IP address. Technology and tools such as clear GIFs assist in the delivery of cookies.
We also use clear GIFs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For this reason, these types of clear GIFs are tied to Personal Information.
- enable you to move around the Sites and use its features, such as accessing secure areas of the Sites;
- collect information about how you use our Sites, estimate our audience size and usage patterns, and improve how our Sites work;
- store information about your preferences, so as to allow us to customize your experience with the Sites and its subsites;
- to speed up your searches;
- recognize you when you return to our Sites;
- retrieve information for promotional, marketing or security purposes; and
- collect information about your browsing habits in order to make advertising relevant to you and your interests.
We use Google Analytics to provide web analytics data about our Site. Google Analytics places a cookie on your web browser that tracks and reports website traffic. None of the information collected by Google Analytics consists of or is linked to Personal Information belonging to you. You may opt-out of the service by installing the Google Analytics opt-out add-on found here https://tools.google.com/dlpage/gaoptout.
By using our Sites, you agree that we can place these types of cookies on your device and use clear GIFs.
Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Sites may not function properly.
DISCLOSURE REGARDING MONITORING
You acknowledge that any and all data that is stored and is resident on our servers, and any and all communications that you make within the Sites or any Games (including, but not limited to, messages solely directed at another player or group of players) traverse through our servers, may or may not be monitored by us or our agents (to the extent permitted by applicable law), you have no expectation of privacy in any such communications and expressly agree to such monitoring of communications you send and receive. You expressly agree to waive any rights of confidentiality that you may have in and to your communications (if any) when using any of the Sites’ communication features, you agree you have no expectation of privacy in any of those communications and, accordingly, and you expressly agree to such monitoring of communications (including technical support and customer service communications) that you send and receive.
8. HOW WE USE AND SHARE THE INFORMATION WE COLLECT FROM YOU
HOW WE USE INFORMATION WE COLLECT FROM YOU
We may use the Personal Information we collect from you to enable us to:
- provide you with technical support, customer service, and Account maintenance;
- learn what you like and tailor your experience accordingly;
- improve the Sites and its subsites and our other products and services;
- provide services or products you request;
- allow you to participate in or use the Trion communication features;
- allow you to play one of our fee-based Games, or free Games and download any other Game;
- allow you to benefit from any other services, as the case may be, such as sweepstakes, contests and promotions;
- manage your Account and respond to your potential orders, requests and online purchases;
- inform you of any changes made to the Sites and its subsites; and
- inform you of products, services, promotions and offers which you may find interesting.
INFORMATION WE PROVIDE TO THIRD PARTIES
Where and to the extent required by the applicable laws, you hereby expressly agree to your Personal Information being shared with or otherwise transferred by Trion to third parties.
When you have provided Personal Information to us for a particular purpose, we may disclose your information to other companies that we have engaged to assist us in fulfilling your request and who we subject to confidentiality requirements. This may include, but is not limited to, billing and payment services, customer relationship management services and other third party service providers. A very limited number of these third party billing and payment service providers may then further use the Personal Information to provide targeted marketing and advertising services. We may also disclose any of your Personal Information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable laws, or, as we deem necessary in our sole discretion, in order to protect the rights, property or safety of Trion, our customers or others. Note that we may be required to release Personal Information in response to lawful requests from public authorities including to meet national security and law enforcement requirements. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the Site, of any Personal Information contained in the Trion database for such Site, if Trion or one of its companies assigns all of its rights and obligations regarding the use of your Personal Information at the time of a bankruptcy, merger, acquisition, sale of all or substantially all of the Site’s assets to a subsequent owner or operator, or similar event.
9. INFORMATION ABOUT LINKS AND THIRD PARTIES RELATED TO THE SITE
You have the right to access information held about you by Trion. Your right of access can be exercised in accordance with applicable data protection and privacy laws.
We are not responsible for the content of any third party websites, expressly disclaim any statements or assertions made on such websites, and deny all liability associated with your use of, and the content on, such other sites or advertisements contained therein.
INFORMATION ABOUT CO-PUBLISHED GAMES
INFORMATION COLLECTED BY THIRD PARTIES
Trion may employ the use of third party service providers in order to facilitate the usability and functionality of the Sites and/or services. These third party service providers may collect data about you through your use of Trion’s Sites and/or services. It is your responsibility to review the privacy policies and practices of these third party service providers, particularly those linked below. Your use of the Sites and/or services indicate your agreement to such collection of your data.
Trion may use third party software from companies who are members of the Network Advertising Initiative (“NAI”) and/or the Digital Advertising Alliance (“DAA”). Each of these organizations offers a single location to opt out of receiving tailored ads from its member companies. To opt out of information collection by NAI member companies, or to obtain information about the technologies they use or their own privacy policies, visit the NAI consumer opt out page located at http://www.networkadvertising.org/choices. To opt out of information collection by DAA member companies, visit the DAA consumer opt out page located at http://www.aboutads.info/choices/. Please note that we strive to adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising.
10. HOW YOU MAY ACCESS, CHANGE OR DELETE THE INFORMATION YOU HAVE PROVIDED TO US
At the time that you provide Personal Information, Trion may give you the option of declining any future offers or information about new products, promotions or services. In addition, many of the mailings that Trion may send you, such as newsletters, have procedures within them to cancel the receipt of any future promotional mailings.
Subject to security and privacy concerns (e.g., regarding your password and credit card number), you will have the ability to access, change, transfer, delete and/or update your information and communications preferences through your Account. If, for any reason, you are concerned with the way we are using your Personal Information, or would like to correct or request that we delete such Personal Information, please contact Trion Worlds, Attention: Privacy Officer, 2400 Bridge Parkway, Redwood City, CA 94065 or firstname.lastname@example.org. If you choose to have your Personal Information removed from our active databases, we will do so within a reasonable time after your request and we will take reasonable steps to ensure that your Personal Information is not used (except as may be required by law) by Trion after your notification to us. Please note that the deletion of your data will lead to the termination of your Account and applicable services.
11. PRIVACY DISCLOSURES FOR CALIFORNIA RESIDENTS
RIGHT TO OPT OUT
Under California law, our customers that are California residents may request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. As detailed above, we do not share our customers’ Personal Information with unaffiliated third parties for direct marketing purposes without such customers’ approval. If, at any time, you wish to learn more about our disclosure policy, opt out of having your Personal Information shared with third parties and/or receiving promotional materials from Trion (via email or postal mail), you may contact us at: Trion Worlds, Attention: Privacy Officer (Opt-Out), 2400 Bridge Parkway, Redwood City, CA 94065 or by email at email@example.com. If you are contacting us with the intention of opting out, please indicate which publications or services you no longer wish to receive so that we may better address your needs.
CALIFORNIA DO NOT TRACK DISCLOSURES
12. PRIVACY DISCLOSURE FOR RESIDENTS OF THE EUROPEAN UNION
For persons in the European Union (“EU”), terms such as “Personal Information” refer to “personal data” as defined by the General Data Protection Regulation 2016/679 (“GDPR”) and applicable local laws.
Pursuant to the requirements of the GDPR, the following charts summarize (1) the categories of personal Information we collect from you and process, (2) the purpose and lawful basis for the collection and (3) Third Parties with whom we share Personal Information:
Categories of Personal Information we process:
|Category of Personal Information collected||What this means|
|Identity Data||Your first name, last name, account ID, username or similar identifier and year of birth.|
|Contact Data||Your mailing address, billing address, email address and telephone numbers.|
|Financial Data||Your payment card and/or payment method details.|
|Transaction Data||Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data as part of your transactions with third parties.|
|Marketing and Communications Data||Your preferences in receiving marketing from us and our third parties and your communication preferences.|
|Behavioral Data||Data inferred from your activities and choices, as it relates to our Games.|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
Purposes for which we process Personal Information and the legal basis relied on:
|Purpose||Category(ies) of Personal Information involved||Why do we do this||Our legal basis for this use of data|
||To register you as a new customer or allow you login to an existing account.||When registering, you agree to provide this information in order to fully access the content and features available on our Site.|
||For system administration, to report aggregate information, Site tracking, security purposes or to prevent our servers from attacks.||When you login to your account, you agree to provide this information for the purpose of analyzing and optimizing your Game experience.|
|Process payments for purchases and/or services||
||To process and deliver your order, purchase and/or services, including manage payments, fees and charges.||This information is necessary so that we may provide content, Game(s), Virtual Item(s), service and/or products to you.|
|Sweepstakes, Contests and Surveys||
||To allow you to participate in some of our sweepstakes, contest, surveys or other promotions.||This information is necessary so that we may contact potential winners, for the purpose of verifying eligibility, for awarding prizes and for tax purposes.|
|Customer Service, Technical Support or Consumer Complaints||
||To resolve issues related to customer service, billing questions, technical and computer support, etc.||This information is necessary so that we may look up your Account and resolve issues properly.|
||To keep our website, our services and associated systems operational and secure.||We process this information to ensure the ongoing security and proper operation of our services, website and associated IT services and networks.|
||To track issues that might be occurring on our systems.||This information is processed so that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.|
||To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||This information is processed to provide you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.|
||For account verification, to link your account with a Digital Distribution Service with your Trion account and/or to link your console account with your Trion account.||This information is processed to provide content, online Games, purchases and/or services through our Site and associated systems and services.|
Third Parties with whom we share your Personal Information:
|Recipients||Categories of Personal Information we share||Why we share it||Location(s)|
|Billing and Payment Services||
||To process and deliver your order, purchase and/or services, including manage payments, fees and charges.||
|Customer Relationship Management Services||
||This information is collected for customer service or technical support and/or customer complaints.||
|Targeted Marketing and Advertising Services||
||To serve and measure the effectiveness of our advertising, provide Game experiences that may be of interest to you,||
||We may share this information with our auditors or legal advisors in order to obtain professional advice.||
|Regulators and other authorities||
||Authorities may require reporting of processing activities in certain circumstances including in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable laws.||
Note that we may be required to release the Personal Information of EU and/or Swiss individuals in response to lawful requests from public authorities including to meet national security and law enforcement requirements. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
At any time, an individual residing in the European Union may submit a complaint with a supervisory authority, in the Member State in which the individual resides.
13. INFORMATION FOR PERSONS OUTSIDE THE UNITED STATES
14. NOTICE TO MINORS
Trion’s Sites offer online services that allow you to post content to share with others. You may remove your posted content at any time using the deletion removal options within our services. If you require assistance with deletion of your posted content or information or have additional questions, you may submit a request to Trion’s Support Center at https://support.trionworlds.com/hc/en-us . You should be aware that removal of the content or information from our service does not ensure complete or comprehensive removal of the content or information posted on the online service.
After your removal request has been honored, we may retain copies of the content or information you have previously posted on our servers. We are not required to remove your posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted this information.
15. SECURITY OF PERSONAL INFORMATION COLLECTED
Trion has made an effort to ensure that all information collected will remain secure and in its original form (i.e. free from any alteration). As such, access to all Personal Information is strictly controlled by limiting access to Personal Information to employees performing a legitimate business function. When payment information is transmitted, for example, Trion employs an industry standard security technology known as a secure-socket-layer (“SSL”) encryption. Unless otherwise specified herein or on the Site where you make a purchase, credit card numbers are used only for payment processing and are not retained for marketing purposes. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of Personal Information.
While Trion takes reasonable precautions against possible breaches of the Site and customer databases, no website or Internet transmission is completely secure. Consequently, Trion cannot and does not guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, but we have in place reasonable technical and organizational security measures to protect your Personal Information against accidental or intentional manipulation, loss, destruction, or against unauthorized disclosure or access to the Personal Information we collect online. We will notify users of a data breach involving unencrypted Personal Information by email and/or by posting a notice to the affected Site(s).
Trion urges you to take steps to keep your Personal Information safe by memorizing your password or keeping it in a safe place (separate from your Account information), logging out of your user Account and closing your web browser when you are finished using the Sites.
16. CONTACT US
- Email: firstname.lastname@example.org
- Mail: Trion Worlds, Attention: Privacy Officer, 2400 Bridge Parkway, Suite 100, Redwood City, CA 94065
- Phone: 650.631.9800 (ask for the Privacy Officer)
- Pour les utilisateurs qui ne parlent pas anglais, veuillez-vous reporter à nos Conditions Générales d’Utilisation pour en savoir plus sur comment contacter Trion.
- Für den deutschsprachigen Raum stehen in unseren Nutzungsbedingungen weitere Kontaktinformationen für Trion zur Verfügung.
- For Individuals in European Union member countries, you may contact our EU-based reprentative via email at email@example.com or by phone at 0203 797 1289.
As previously mentioned, we are a licensee of ESRB’s Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified directly at http://www.esrb.org/privacy/contact.aspx or by regular mail at 420 Lexington Ave, Suite 2024, New York, NY 10170.