CHANGYOU PRIVACY POLICY
Last revised: [6/17 /2020]
Welcome to CHANGYOU. This Privacy Policy explains our privacy commitment to our players and users of our Services (hereinafter "Users"). This Privacy Policy is incorporated as part of the CHANGYOU Terms of Use, accessible at [http://www.gamebox.com/privacy_policy.shtml ] .
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.
By using CHANGYOU’s services, you authorize CHANGYOU and its affiliated companies (collectively, "CHANGYOU" or "we"), to process your personal data according to this Privacy Policy. If you do not accept the terms of this Privacy Policy, please refrain from using our online games or our games’ online functionalities, our websites, our mobile apps and any other online CHANGYOU products and services (hereinafter "Services").
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
Cookies. CHANGYOU uses cookies on the Services. A "cookie" is a small bit of record-keeping information that web sites often store on a user's computer. Cookies are not intended to include people's names, or other information that is directly identifiable; rather, they are typically used to quickly identify a user's device and to "remember" things about the user's visit. CHANGYOU may set cookies for your web browser as you visit our websites, use our products, or visit a website where CHANGYOU provides ads, content or analytics. For example, CHANGYOU uses cookies to keep track of selected items in your shopping cart on our online store, and to remember your Account identifier. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to shop online or to access certain features of our Services. Each browser is different, so check the "Help" resources for your web browser to learn how to change your cookie preferences. In addition to CHANGYOU using cookies on our network of websites, CHANGYOU may allow certain partners to set and access their cookies on your computer. These companies’ use of cookies is subject to their own privacy policies, not the CHANGYOU Privacy Policy. Please review them carefully.
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 [support@gamebox.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
CHANGYOU may ask for your first name, family name, e-mail address and your date of birth to answer your demands to the CHANGYOU Customer Support, to confirm any information or transaction on your CHANGYOU account, and to give you information regarding the Services (for instance, if you lose your password or if we make changes to the Terms of Use).
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.
2.1.7 Advertisements
CHANGYOU uses third party ad-serving technologies that may collect information to provide behavioral and non-behavioral advertisements within our Services. The information collected and used for the targeted advertising may contain the following, without limitation: age and gender, number of views of an advertisement, device unique identifier or other device identifiers and settings, information about your use of the products and Services, other sites (including third party web pages and mobile Internet sites) you have viewed (as well as date and time viewed), advertisement(s) served, the advertisement(s)’ in-game location and length, and your response to the advertisement(s) (if any). The analytics tools and ad serving technologies may use server log files, web beacons, cookies, tracking pixels and other technologies to collect this information, and may combine the information collected on other CHANGYOU Services with information collected from other third party websites, products and services and with demographic, advertisement, market and other analytics surveys. Standing alone, this information is not personal data; however, if CHANGYOU combines any of this information with personal data, CHANGYOU will treat this information as personal data pursuant to this Privacy Policy.
2.1.8 Social media and other third parties’ platforms
CHANGYOU may also collect personal information on third party social networks, platforms or services. By playing a CHANGYOU game through a social network or other third party platform, or by connecting to such a third party network, platform or service via one of our products and/or Services, you authorize CHANGYOU to (1) collect, store, and use, in accordance with this Privacy Policy, any and all personal information that you agreed the social network or third party platform could provide to CHANGYOU based on your settings on the social network or platform, and (2) share any and all of your personal information with the social network or other third party platform, through the social network/third party platform’s Application Programming Interface (API). You agree to this sharing when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, "accept" or "allow" (or similar terms) one of our applications through a social network, or other third party platform or service.
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
Whenever you use the Services, CHANGYOU may collect, store and process your in-game data, including but not limited to: your game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information. CHANGYOU will use this information to improve the Services, to personalize them to your interests, and otherwise upgrade your gaming experience. Any information collected by CHANGYOU in accordance with Article 1 of this Privacy Policy may also be used in an aggregated form to identify specific patterns regarding the use of our Services.
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.
This information may be stored in CHANGYOU’s premises, or, when relevant, in the third parties’ premises. Such storage is necessary to allow CHANGYOU to manage internal accounts, checking, accounting, compliance, and for legal purposes, in accordance with Article 3 of this Privacy Policy.
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.
2.4 COPPA
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?
The information you submit to our Services is collected and used by CHANGYOU as set out in this Privacy Policy. In addition, CHANGYOU may use the submitted information to answer your demands, to send your order confirmations and other information regarding your CHANGYOU Account, to send you advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on your preferences.
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.
CHANGYOU may have to duplicate some of your personal data within its databases for technical reasons, or for any other reason indicated in this Privacy Policy. CHANGYOU may use your IP address and Console ID to enforce the CHANGYOU Terms of Use . In case of misuse of the Services by any User, CHANGYOU reserves the right to block such User’s CHANGYOU Account, IP address or console ID, as provided by licensed console manufacturers. CHANGYOU may use your date of birth or your age to control access to its forums and live chats, in accordance with the relevant laws. CHANGYOU does not monitor all chat communications on its services. However, CHANGYOU reserves the right, at its sole discretion and without notice, to modify or delete any communications on its service. CHANGYOU may use all data collected in the forums and chat logs to enforce its Terms, to carry out its legal obligations, and to protect its rights and the rights and safety of its affiliated companies, users, and employees. Your information may be disclosed to any relevant judiciary or administrative entity, in accordance with the relevant legal provisions.
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.
3.2 Security
We take your privacy and the security of your personal information very seriously. To protect your personal information, CHANGYOU maintains appropriate safeguards to ensure the security, integrity and privacy of the information you have provided. We use robust security measures to protect personal information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. In addition, we take reasonable steps to assure that third parties who collect personal information on our behalf provide sufficient protection of personal information, in addition to requiring their compliance with this Privacy Policy at all times. Please note, we will notify Users of a data breach pursuant to applicable law.
However, please note that no existing data transmission method on the web, or electronic storage, can guarantee the absolute security of your personal data. If your CHANGYOU accounts and personal data are protected by a password, you are responsible for ensuring this password’s confidentiality. Please do not disclose this password. If you share a computer with other people, please consider disconnecting from your accounts before allowing others to use your computer. Services may contain links leading to third party websites, such as but not limited to social media sites. Whenever you click on a link leading to a third party’s website, you agree to leave CHANGYOU Services as governed by this Privacy Policy, and you understand and agree that CHANGYOU does not control such third party’s website. CHANGYOU cannot guarantee that third parties’ websites will be governed by the same security and confidentiality obligations. CHANGYOU is not liable for the use of your personal data by these third parties. Please consider checking privacy policies of any service provider you transfer your personal data to.
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?
Unless relevant legal provisions mandate a different data retention period, CHANGYOU will store your personal data only as long as necessary to process it according to this Privacy Policy. For instance, we may retain certain information after you close your account for a period of time needed to protect CHANGYOU from legal claims. In this case, we will archive your personal data during the relevant statutory period of limitations.
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
CHANGYOU may share your personal information among the CHANGYOU group of companies. To the extent that our corporate affiliates and/or technical partners have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy.
5.2 Sharing your personal data with third parties
While browsing on CHANGYOU websites, or while using CHANGYOU Services, external providers may collect your personal data for and on behalf of CHANGYOU, and CHANGYOU may share some of your personal data with these partners to allow the functioning of the Services (such as Facebook, Google, Twitter, Yahoo and Windows). For example, these third parties may help deliver your purchases, provide discounts or offer products, promote the Services, perform electronic payment processing, and any other service that may be required by CHANGYOU. External providers must comply with this Privacy Policy when collecting your personal data. These external providers will share your personal data with no one other than CHANGYOU, and they may not use your data for their own independent marketing purposes, unless you consent to their privacy policy and terms directly.
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.
We are not responsible for disclosure by other users of your Personal Information, including without limitation, videos, images or photos that you choose to make public on the CHANGYOU Services. Also, please remember that the Personal Information you provide to us as part of your Public Profile may reveal or allow others to identify aspects of your life that you may not choose to state on your Public Profile directly (for example, your picture may reveal your gender). Certain Services may feature a friend finder tool. By using our friend finder tools, you acknowledge that these tools will help you find your contacts, and will also allow your contacts to associate your CHANGYOU Account, other CHANGYOU accounts (if any), and related gaming entitlements, including games played on PC, mobile and console platforms with your social networking profile and/or email address. Your resulting friends' list, which may be accessible across CHANGYOU’s sites, will be subject to this Privacy Policy. Note that the friends that you choose to include on your friend list may be able to find and/or identify you in the context of different CHANGYOU products and Services, and may see the profiles and information you have made visible to them or to everyone. Similarly, CHANGYOU may also collect or receive information about you from other CHANGYOU users who choose to upload their emails and other contacts. This information will be stored by us and used primarily to help you and your friends connect.
7. MINORS
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.
8. Children
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.
Parents must exercise their privacy rights for their children. Please refer to the "Your rights" section of this Privacy Policy.
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 [support@gamebox.com ]. 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.
Users under 18. If you are under 18 (eighteen) years old and desire that your information you have posted to a CHANGYOU public facing site be removed from such site, please contact us at [https://www.facebook.com/gameboxcom] or at [support@gamebox.com ] or at [support@gamebox.com ]. You may be required to provide additional information in order for us to verify your request. Please note, if information is deleted from our commercial databases and/or view by members of the public, CHANGYOU may still retain your information in our files, to resolve disputes, enforce our Terms of Use or other User agreements, and due to technical and legal requirements and constraints related to the security, integrity and operation of our Services. Your request will be processed within thirty (30) days of the date of which we receive it.
10. PRIVACY POLICY CHANGES
CHANGYOU reserves the right to modify this Privacy Policy at any time. As a result, please consider checking this Privacy Policy from time to time.
Your use of the Services after CHANGYOU changed this Privacy Policy shall signify that you agree with these changes. If you do not accept changes made to this Privacy Policy, please refrain from using the Services.
11. CONTACTS
For any question related to your personal data processing and this Privacy Policy, please contact CHANGYOU data protection officer at the following address: [support@gamebox.com ].
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.
