Last revised: [6/17 /2020]
At CHANGYOU, we collect personal data to support our products and services, while respecting all applicable laws, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA), and regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, "General Data Protection Regulation", or "GDPR"). As defined in the GDPR, "personal data" means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1. WHEN DOES CHANGYOU COLLECT YOUR PERSONAL INFORMATION?
CHANGYOU collects and processes your personal information at different times when you interact with our Services. Generally, personal information is collected when:
Whatever the activity may be, we will only collect personal information to the extent necessary to provide you with the Services and fulfil your requests.
2. WHAT PERSONAL INFORMATION DOES CHANGYOU COLLECT?
2.1 When you use CHANGYOU services
2.1.1 While Browsing CHANGYOU websites
IP addresses. CHANGYOU also collects Internet Protocol (IP) addresses for safety and security reasons. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
Other passively collected information. While browsing our sites, CHANGYOU may, on its own, or with the help of third party tools, collect non-personally identifiable information concerning your gaming hardware, habits, behaviors and use of our Services. CHANGYOU collects such information to better adapt our Services to users’ interests, and for a better quality of our Services. The information collected may contain the following, without limitation: device unique identity, including MAC address, console, mobile, tablet and console unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.
2.1.2 Registering on a CHANGYOU service
To access certain Services, you will need a CHANGYOU Account. During the creation of your Account, we will ask you to provide your user name, password, email address, date of birth (or age) and country of origin. This information is mandatory to create an Account. On other Services, CHANGYOU may ask you additional personal information relevant to the Service such as your phone number, home address, or geo-location information (for example, you will be asked your home address when purchasing a product within our online shop, in order for CHANGYOU to deliver the product to your home address).
2.1.3 Creating a CHANGYOU account
By creating a CHANGYOU Account, you agree to receive newsletter or adverts about CHANGYOU products, services, and sales. You can unsubscribe at any time by:
(a) clicking the unsubscribe link contained in all CHANGYOU email marketing messages;
(b) changing your contact preferences on your CHANGYOU account page at [http://www.gamebox.com/ ]
(c) contacting [ http://www.gamebox.com/contact_us.shtml ] or [email@example.com ] with your unsubscribe request; or
(d) sending your unsubscribe request to CHANGYOU,. Attn: [12/F, Ruttonjee House, 11 Duddell ST, Central HK, Hong Kong, Central HK, Hong Kong ]
To access certain Services, you will need to give an additional consent to allow CHANGYOU to share some of your personal data with third parties, such as companies or organizations, which provide services and products you may be interested in. In this case, you can unsubscribe from third parties’ communications through the mechanisms provided by the third party.
2.1.4 Contacting CHANGYOU
2.1.5 Participating to contests and sweepstakes
CHANGYOU may offer you the opportunity to participate in online surveys, questionnaires. To participate, you may need to provide your first name, your family name, e-mail address, date of birth, your address and country of residence. If you choose to participate in surveys and questionnaires, your personal data may be processed to allow you to participate, and for internal statistical use.
2.1.6 Interacting on forums
Whenever you participate or interact with other users on a forum, CHANGYOU collects the content of your communications, the time and the location of your activities, as well as your online ID and your IP address.
2.1.8 Social media and other third parties’ platforms
2.2 Whenever you play CHANGYOU games
2.2.1 Registering when activating a CHANGYOU game
If you play CHANGYOU games on a third-party console, your ID for this console will be disclosed to CHANGYOU, in order to let CHANGYOU create your CHANGYOU Account. You must have a CHANGYOU Account in order to access certain online features. From your console, CHANGYOU receives your username and your password, your e-mail address, your date of birth, and your country of residence.
2.2.2 Creation of user generated content
Some Services give you access to tools in order to allow you to create and/or share unique content. This User-Generated Content may be collected by CHANGYOU; this content may also contain your personal information or the personal information of others (for instance, your name, or a picture of you). Please exercise caution: CHANGYOU is not liable for any negative consequences linked to your disclosure of User-generated content.
2.2.3 In-game data collection
2.3 Online payment
For some Services, you may make purchases, whether you shop on CHANGYOU websites or directly in-game.
When you do this, you agree that CHANGYOU may share your personal data with third parties, companies, or organizations, which may collect and process your personal data in order to effectuate online credit card transactions, delivery, discounts, and promotional gifts.
To make a purchase on CHANGYOU store and process your online payment, you may be asked to provide the following information to a payment provider: your first name, your family name, your address, your e-mail address, your country of residence and your banking details, i.e. your credit card number, the name of the credit card owner, the expiration date and security code.
You may be asked to give your telecommunications provider’s name, your cell phone model, and a valid phone number in order to provide you with purchasing instructions directly via your cell phone.
We comply with the Children’s Online Privacy Protection Act. We do not knowingly collect personal information on children under the age of 13. When a user identifies himself or herself as a child under the age of 13 through a support request or through any feedback, we will not collect, store or use, and will delete in a secure manner, any personal information of such user.
3. HOW DOES CHANGYOU USE MY PERSONAL DATA?
We also use your personal information for our internal marketing and demographic studies, so we can constantly improve the Services we provide you and to better meet your needs.
3.1 Legal basis for your personal data collection and processing
CHANGYOU processes your personal data, wherever necessary:
- To provide you with the Services (creation of your CHANGYOU account, bug detection, fighting fraud, online payment, etc.)
- To offer the best possible experience to users, and improve the Services (in-game data analytics, etc). It is in CHANGYOU’s legitimate interest to process your data for these purposes.
- To provide you with supplementary services (custom content, etc.). In such case, CHANGYOU will ask for your consent before processing your personal data for this purpose.
DESPITE OUR REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA.
4. FOR HOW LONG DOES CHANGYOU KEEP MY PERSONAL DATA?
5. WITH WHOM DOES CHANGYOU SHARE MY PERSONAL INFORMATION?
CHANGYOU does not disclose your personal data to any third party without your prior consent.
5.1 Sharing your personal data with CHANGYOU affiliated companies
5.2 Sharing your personal data with third parties
5.3 Sharing your personal data with government authorities
In accordance with relevant laws, CHANGYOU may have to disclose your personal data to a judiciary or administrative entity, whenever such disclosure is deemed necessary for protecting or enforcing the legal rights of CHANGYOU, its Users, or third parties. Unless required by law, CHANGYOU will not be required to notify you of any such disclosure.
5.4 Sharing your personal data in case of mergers
In the unlikely event CHANGYOU’s business activities or shares are transferred partly or totally to any third party, such third parties may access your personal data. In this case, CHANGYOU may also allow your personal data to be transferred to the acquiring third party.
5.5 Transfers of personal data to third countries or outside the European Union
Please be aware that your personal information may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or CHANGYOU partners, located in third countries/outside the European Union such as, but not limited to, United States, Canada and China. Some personal data recipients are located in countries that are not considered as ensuring an adequate protection level according to the EU Commission. In such case, CHANGYOU uses the strict framework of the EU Commission’s approved standard contractual clauses, which are available on the EU Commission website (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_fr/).
6. DOES CHANGYOU MAKE MY PERSONAL INFORMATION PUBLIC? WHO CAN SEE MY PERSONAL INFORMATION?
CHANGYOU Services may offer a public profile feature ("Public Profile") that allows you to publish information, including personal information, to the public Internet. Other than as stated on the applicable Public Profile site, the information you upload or input to your Public Profile will default to the privacy level you choose at sign-in, and you can choose to change the privacy settings at any time. By default, certain aspects of the Public Profile are set to "public". Those aspects of the Public Profile that are designated as "public" will be visible to everyone, potentially including people not registered within the CHANGYOU environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your personal information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent.
Once a child states that his/her age is under 16, he or she will be unable to register an account with us. We do not knowingly collect or store any personally identifiable information from children under the age of 16.
We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ or guardian's prior permission.
We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their state of residence.
If we consider that any of our Services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the Services or from providing information and/or limit the collection of information from such users as described below in more detail.
No personal information should be submitted to Gameloft by users under the minimum legal age required in their state of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their state of residence.
Such a user cannot:
With respect to such a user, we will prevent the collection and use of their precise geolocation data and display to them contextual advertising only (excluding any behavioral advertising).
Children can be invited to take part in testing our games (playtests) with their parents' or guardians’ authorization and/or their parents' or guardians’ physical presence being required depending on the state where the playtest is conducted.
9. WHAT ARE MY RIGHTS?
You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by logging in and clicking the Edit Profile section. Additionally, You have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by CHANGYOU, as well as the right of data portability. You can exercise these rights or terminate your CHANGYOU account by writing to CHANGYOU customer support, via the following website: [https://www.facebook.com/gameboxcom ] or send an e-mail to [firstname.lastname@example.org ]. CHANGYOU will answer your request within a month following the receipt of your demand. CHANGYOU reserves the right to extend this delay up to three months if it necessary regarding the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand. For any data processing activity requiring your consent (cookies, behavioral advertising…etc), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing.
Do not Track: CHANGYOU does not currently respond to Do Not Track (DNT) settings in your browser.
You can also write us at the address below:
CHANGYOU Attn: [12/F, Ruttonjee House, 11 Duddell ST, Central HK, Hong Kong, Central HK, Hong Kong ]
Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.