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:

• 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 submit a request to Customer Support.
• 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 collect information through technology, such as cookies and other technologies (such as web beacons and pixel tags), including when you visit our sites and applications or use our applications on third-party sites or platforms. A cookie is a small string of data which often includes an anonymous unique identifier sent to your Internet browser from a website’s computers, which is stored on your computer’s hard drive and is used to customize your use of a product or online site, keep records of your access to an online site or product, or store information needed by you on a regular basis (e.g. password retention functionality). Manticore (itself or through third parties acting on our behalf) uses cookies for a number of purposes relating to our websites, applications and services, including to access your account information where you “login” to our websites, forums or other areas and to keep track of your website session data. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so consult the “Help” menu of your browser to learn how you change your cookie preferences. Please note that if you reject all cookies, you may not be able to use certain of our (or other companies’) web pages.
• We participate in ad and/or affiliate networks operated by various third-party companies. These companies collect and may use certain anonymous information about your visits to our Service as a function of referring Internet traffic to our Service. We do not permit these companies to collect any Personal Information about you, however, these companies may collect your IP address. These companies may set and use cookies, web beacons, pixels and other technologies to collect anonymous information about your visits to our Service, and may otherwise aggregate, analyze and anonymize that data. We may permit these companies to collect information from site visitors about their online activities over time and across other websites. If you would like to learn more about these specialized advertising technologies, the Network Advertising Initiative offers useful information about Internet advertising companies, including information about how to opt-out of certain information collection. You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com).
• 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.

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:

• 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.

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:

• 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 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

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:

• 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 privacy@manticoregames.com.  Once we receive your instructions we will cease sharing your information, but this will not affect previously shared information. For more information about our compliance with the California Privacy Rights Act (CPRA) please review our CPRA notice.
• 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 privacy@manticoregames.com with your name, postal address, telephone number and email address with “Nevada Do Not Sell” in the subject line.
• Colorado, Connecticut, Virginia and Utah residents: We are currently not subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future we will update this Privacy Policy accordingly.

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:

• 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).

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.