PLAYWITH Interactive Privacy Policy

Thank you for your interest PLAYWITH Interactive Services and related resources (collectively "PLAYWITH Services") offered through the website portal.playrohan.com (PLAYWITH Game Portal Sites). PLAYWITH Services are owned, operated, licensed or controlled by PLAYWITH Interactive, Inc. (collectively "PLAYWITH," "we," "our", or "us").

We respect our users ("users", "you" or "your") privacy. This privacy policy, updated FEB.29 2020, lets you know how information that PLAYWITH receives or collects from you is processed, disclosed and used. In addition, we have incorporated a section to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning as used within this section.

This Privacy Policy only governs the PLAYWITH Sites and Services but does not govern third party websites or the off-line data collection, disclosure and usage practices of PLAYWITH, including information received from you other than through the PLAYWITH Sites. By using the Sites and/or the PLAYWITH Services, you acknowledge your consent to this Privacy Policy. If you do not agree with the terms, do not use the PLAYWITH Sites and/or the PLAYWITH Services.

• WHAT PERSONAL INFORMATION DO WE COLLECT?
• WHAT NON-PERSONAL INFORMATION DO WE COLLECT?
• HOW DO WE USE AND SHARE THE INFORMATION THAT WE COLLECT?
• CALIFORNIA CONSUMER PROTECTION ACT: CALIFORNIA RESIDENTS ONLY
• THIRD-PARTY WEBSITES AND ADVERTISEMENTS
• CHILDREN'S PRIVACY
• SECURITY
• NOTICE OF CHANGES TO THE POLICY
• CHANGE OF CONTROL
• QUESTIONS AND COMMENTS

1. WHAT PERSONAL INFORMATION DO WE COLLECT?

General
We do not collect any personal information from you, unless you provide it to us voluntarily. If you decide to provide us your personal information, we will only collect the personal information that is needed to fulfill your requests and our legitimate business objectives.

Registration
Some areas of the PLAYWITH Sites and certain PLAYWITH Services may allow you to visit as a guest and remain anonymous, but you may not be able to access all the content and features of PLAYWITH Sites and Services without registering. In order for you to register with PLAYWITH, we require you to provide us personal information that may include personal name, mailing address, e-mail address, birth date and gender.

User Name
In order to access certain PLAYWITH Services, You may be asked to choose a user name and password. Please note that your user name will be available to the other users of the PLAYWITH Services while you participate in some services, like chat rooms or message boards, so you should exercise discretion when using these services. Personal information disclosed by you within our chat areas, instant message service, message boards, or during game play can be collected by other users of such services and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our services. To the extent that you create a public profile that may be available to others on our sites and services, you are solely responsible for its content and accuracy at all times.

Billing Information
When you sign up for membership or make an online purchase from the PLAYWITH Sites and included services, we will also require that you provide us with the necessary billing information such as your name, credit card information, billing address, shipping address, phone number, CVV number, and expiration date, so that we may provide the service, or product to you. Issues related to customer service, billing questions, technical and computer support, etc. may also require you to provide us with some personal information so that we may resolve the issue properly.

Online Communications
When you communicate within any game or any other communication feature within the PLAYWITH Sites, even privately to another person, you do so with the understanding that those communications go through our servers and can be monitored by us. You have no expectation of privacy in any of those communications and, accordingly, you expressly consent to monitoring of communications including technical support and customer service communications that you send and receive.


TOP 2. WHAT NON-PERSONAL INFORMATION DO WE COLLECT?

General
In many cases, PLAYWITH will automatically collect certain non-personal information about your use of PLAYWITH Sites and Services. PLAYWITH might collect, among other things, information concerning the type of Internet browser or computer operating system you are using, the domain name of your Internet service provider, your click path through the PLAYWITH Sites, and the third-party web sites or advertisements linked to or from the PLAYWITH Sites that you visited. To do this, PLAYWITH may use cookies, clear gifs, frames, server log analysis and other technology. Personal information collected through the use of these technologies will be handled according to this Policy. Your visits to our web sites, and information provided through these technologies, will be anonymous unless you provide us with personal information or have provided such information in the past.

Cookies
PLAYWITH Sites and Services may contain cookies. Cookies are bits of electronic information stored on a users hard drive to provide information needed by the user on a regular basis. They are often used to save web site customizations and web site login information. Clear gifs (also known as web beacons) assist in the delivery of cookies. 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 to learn more about how to manage cookies. However, please note that if you block cookies, some portions of the PLAYWITH Sites and Services may not function properly. We use cookies to improve the quality of the PLAYWITH Sites and Services and to better understand how users interact with the PLAYWITH Sites and Services. We do not and cannot use cookies to retrieve individual personally identifying information about you from your computer unless you knowingly and willingly provide such information.

IP Addresses and System Specifications
When you use or visit the PLAYWITH sites, our servers log your IP address. We may collect IP addresses for the purposes of providing our products and services, including, without limitation, system administration, troubleshooting, user compliance with our terms of service, investigating security breaches, and compiling non-personal information such as how many visitors logged on to the PLAYWITH Sites and Services. When you log into one of our Services, your system specifications such as operating system, video card, monitor, system configuration, 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.


TOP 3. HOW DO WE USE AND SHARE THE INFORMATION THAT WE COLLECT?

General
Personal information which we collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Policy. We sometimes share non-personal information with third parties about our user base, but that information does not include any personally identifiable information. We may use the information we collect from you for the purpose of providing you with technical support, customer service, and account maintenance. We may also use information to learn what you like, tailor your experience accordingly, and to improve web sites and our other products.

Updates and Promotions
You must have a membership account in order to receive e-mails regarding updated and promotions from us. You can opt out of receiving future e-mailing from us by following the directions contained in the e-mail to unsubscribe.

Third-party Service Providers
When you have provided personal information to us for a particular purpose, we may disclose your information to third-party service providers that we have engaged to assist us in fulfilling your request. This may include, but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, and other third party service providers.

Law Enforcement
PLAYWITH may disclose your personally identifiable information or otherwise use such information to communicate with you if required or permitted to do so by law or in the good-faith belief that such action is necessary to: (i) conform to legal requirements or comply with legal process or any governmental request; (ii) protect and defend the rights or property of PLAYWITH or its affiliated companies, licensors or licensees; (iii) enforce the Terms of Service or any applicable agreements; or (iv) protect the personal safety or interests of PLAYWITH employees, users of PLAYWITH products or services, or members of the public in urgent circumstances. 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 law, or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of PLAYWITH.

Processing
Personally identifiable information may be stored and processed in the United States or any other country in which PLAYWITH or its affiliates, subsidiaries or agents maintain facilities, and by using the PLAYWITH Sites and Services, you consent to any such transfer of information outside of your country. PLAYWITH will take reasonable steps to protect the information users share with us.

Categories of Personal Information We Collect and Disclose (California Collection Notice)
Playwith Interactive Inc. may disclose your personal information to a third party for a business purpose.
When we disclose your personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.
In the chart below, we identify each category of personal information that we have collected in the last 12 months.
For each category of personal information we have collected, we also identify
(i) the category(s) of the information collected;
(ii) the source in which it has been collected from; and (iii) the purpose of the collection.
Each category of information is collected for the purposes listed below and
(1) to provide our games and services, alert of new products or services, features, or enhancements; handle/route our gamers for any issues or technical support questions; to send notification emails’ and/or notify you of upgrade opportunities, contests, promotions, or special events and offers so we can adapt our products and services to better suit your needs.
(2) to monitor fraud prevention and legal purposes,
(3) to secure our services and users, including prevention for cheating and bad behavior, and
(4) for audit purposes.

Category of Personal Information	What we collect	From whom we collect it	Purpose of Collection
IDENTIFIERS Personal information categories listed in Cal. Civ. Code § 1798.80(e)	Account Name (In-game ID), User Name, email address, Character Name, phone numbers, home address, social media handles, legal guardian details, any open field such as chat records / Information collected passively via cookies and similar technology / IP Address and application identifiers / Subscrition information	Directly from you and through your use of games and services / Our vendors / Our affiliated business partners / Social Media and other third party accounts if you choose to link.	Communicate with you / Customer Serivce / Personalize and improve your experience on our systems and websites / Newsletters, Marketing, and Surveys
PROTECTED CLASSIFICATIONS CHARACTERISTICS	Age, race, color, national origin, religion, marital status, gender if you choose to provide it.	Directly from you and through your use of games and services / Our vendors / Our affiliated business partners / Marketing companies	Make sure you are of an appropriate age to play certain games / Enhance and optimize an account for access to and use of the online services / improve your experience on our systems and websites / Verify your identity / Communicate with you
COMMERCIAL INFORMATION	Order details, histories, subscriptions, refunds, payment details	Directly from you and through your use of games and services / Our vendors / Our affiliated business partners / Marketing companies	For product development and research / For Fulfillment of you requests and purchases, transactional and other communications about our online services.
NETWORK ACTIVITY INFORMATION	Region, activity log, cookies, operating systems and versions, licenses details, forum contents, game file version, your “click path” through our website	Directly from you and through your use of games and services / Our vendors / Our affiliated business partners / Marketing companies	Communicate with you / Customer Service / Personalize and improve your experience on our systems and websites / Newsletters, Marketing, and Surveys
GEOLOCATION DATA	We collect geolocations by using various technologies to determine your location including but not limited to IP Address	Directly from you and through your use of games and services	To verify you identity / to enhance and optimize an account for access to and use of the online services / to communicate with you / for product development and research
CUSTOMER SERVICES and GAME DATA	Account Ban history, logs, Payment methods, in-game items, gameplay history, purchase history	Directly from you and through your use of games and services	Personalize and improve your experience on our websites, customer services, and marketing purposes.

TOP 4. CALIFORNIA CONSUMER PROTECTION ACT: CALIFORNIA RESIDENTS ONLY

California Consumer Protection Act Civil Code Section § 1798.83
Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what personal information we collect from you, delete that information if necessary, and opt-out of the sale of your personal information (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf.
This section describes how to exercise those rights and our process for handling those requests.
When we provide personal information to third parties, we are enabling them to provide relevant contents for users like you. If you opt out of the sales of your personal information with Playwith Interactive Inc. the companies we partner with may no longer be able to offer you the personalized experience you’ve come to expect. We want you to have the opportunities you deserve.
However, we fully support your right to opt out of the sales of your personal information and have developed a process for you to exercise this right.

Your Rights Under California’s Shine-the-Light Law.
Under California’s "Shine the Light" law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request via email to contact@playwithi.com Upon submission of a verifiable consumer request, we will provide you with the following information.
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.

If we provide this information to you electronically, the information will be in a portable format. To the extent that it is technically feasible, we will provide you the information in a readily useable format that you can easily transfer to another entity.

DO NOT SELL MY PERSONAL INFORMATION
The California Consumer Privacy Act (CCPA) gives users who resides in the state of California the right to prevent businesses from selling personal information.
CCPA allows California residents to opt out of any future sales of their personal information. If you would like to request any changes on how we collect, delete, or opt out from using your information, please contact us via email to contact@playwithi.com with subject of “California Consumer Privacy Act”. The request can be done free of charge twice in a 12-month period.

Deletion
If we collected personal information from you, you have the right to request the deletion of this personal information.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.
However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will use only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation;
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Non-discrimination.
The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA.
Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.


TOP 5. THIRD-PARTY WEBSITES AND ADVERTISEMENTS

Third-party web sites and advertisements with links to and from the PLAYWITH Sites and Services may collect personally identifiable information about users. You should be aware that these third-party web sites may have their own information collection practices and privacy policies. We do not control the privacy policies of third parties that have web sites linked to the PLAYWITH Sites and Services. If you click on a third-party advertisement or link, the privacy policies of the third-party web site that you link to will govern the use of your information by that web sites operator.
The advertisements appearing on PLAYWITH Sites may be delivered to you by other third-party advertising companies. These companies may use information about your visits to this and other web sites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you. PLAYWITHs Privacy Policy does not extend to these third-party web sites and advertisements. Please refer directly to these third-party web sites regarding their privacy policies. We assume no responsibility or liability for the actions of such third parties with respect to their use of your information or otherwise. Accordingly, please make sure you are aware of and comfortable with the privacy policies of any third-party web sites to which you follow a link. Also, PLAYWITH does not control cookies in third-party advertisements, and users are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology.

TOP 6. CHILDREN'S PRIVACY

PLAYWITH complies with the Children's Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet.

Children under the age of 13
Because PLAYWITH Sites and Services are not directed to children under the age of 13, PLAYWITH does not provide memberships to persons under age 13. If you are under the age of 13, you may not create an account on the PLAYWITH Sites, you may not sign up for any subscription service or buy anything through the online store, and you are not eligible to enter any of our sweepstakes or promotions. Except as may be required by law, PLAYWITH will not knowingly collect, maintain, or disclose any personal information from children under the age of 13.

Information for Parents/Guardians
If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, PLAYWITH will take reasonable steps to remove that information from the PLAYWITH database at your request. To request removal of your child’s information, please send us an e-mail at support@playwithinteractive.com and be sure to include in your message the same user name, security question, and e-mail address that your child submitted.


TOP 7. SECURITY

While PLAYWITH takes precautions against possible breaches in PLAYWITH Sites and customer databases, no web site or Internet transmission is completely secure. Consequently, PLAYWITH cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
While no computer is 100% safe from outside attacks, we believe that the steps we have taken to protect your information drastically reduce the likelihood of security problems to a level appropriate to the type of information involved. Whenever you give PLAYWITH sensitive or confidential information (for example, credit card numbers for purchases), PLAYWITH will take commercially reasonable steps to protect the information by establishing a secure connection with your web browser. We have established and maintain reasonable security procedures to protect the confidentiality, security and integrity of your personally identifiable information. We use encryption, Secure Socket Layers, and other technical measures (such as off-site backup, security testing, and password protection), and we implement off-line efforts to further protect this information, including limiting employee access to personal information and updating our employees regarding our security practices and privacy policies.


TOP 8. NOTICE OF CHANGES TO THE POLICY

PLAYWITH reserves the right to change this Policy at any time by notifying registered users via e-mail of the existence of a new Policy and/or posting the new Policy on the PLAYWITH Sites. All changes to the Policy will be effective when posted, and your continued use of any PLAYWITH Site or Services after the posting will constitute your acceptance of, and agreement to be bound by, those changes.


TOP 9. CHANGE OF CONTROL

In the event that another company acquires all or substantially all of the assets related to the PLAYWITH Sites or Services, or if we experience some other change of control event such as merger, insolvency, bankruptcy or receivership, we reserve the right to include any or all user-related information among the assets transferred to the acquiring company. We do not guarantee that any entity receiving such information in connection with any of these transactions will comply with all the terms of this policy. You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the PLAYWITH Sites or Services, of any personal information contained in the PLAYWITH database.


TOP 10. QUESTIONS AND COMMENTS

If you have any questions or comments about this Privacy Policy, please can contact us at contact@playwithi.com

PLAYWITH reserves the right to change this Policy at any time by notifying registered users via e-mail of the existence of a new Policy and/or posting the new Policy on the PLAYWITH sites. All changes to the Policy will be effective when posted, and your continued use of any PLAYWITH site or service after the posting will constitute your acceptance of, and agreement to be bound by, those changes.


Last Updated: February 29, 2020


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