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EPIC ACTION LLC (“EPIC ACTION”) PRIVACY POLICY FOR USERS IN THE EUROPEAN ECONOMIC AREA

Effective Date: May 25, 2018

1.             INTRODUCTION

Epic Action develops and publishes social games for the web and mobile devices including Final Fantasy XV: A New Empire™ (the "Service"). Epic Action is a fully owned subsidiary of Machine Zone, Inc., (“MZ”) who is the controller for the purposes of the European General Data Protection Regulation (the “GDPR”) and in this policy, “we” or “us” refers to MZ. 

Machine Zone Germany GmbH (HR B 131970), with the contact email address MZ_Gmbh@mz.com, is our representative in the EU for purposes of the GDPR. Our data protection officer can be contacted at dataprotectionofficer@mz.com.  We have prepared this Privacy Policy to help you as the user of the Service (“you” or “user”) understand how we collect, store, use, and manage information, including personal data, that you provide to us or we collect about you when you use the Service.

When you use the Service, you agree to the collection, uses and disclosure of information (including recording and tracking) described in this Privacy Policy. Please read it carefully. The MZ group of companies develops and publishes other online and mobile games, products and services including websites, mobile applications and platform services. These other services are subject to their own specific privacy policy, and if you download, access, or use another service you agree to also be bound by its specific privacy policy.

This Privacy Policy describes:

·      The information relating to an identified or identifiable person (“personal data”) we collect and hold about you, how we do so and the purposes of our collection

·      How we use and with whom we share such personal data

·      How you can access and exercise your rights in respect of such personal data

·      The choices you can make about how we collect, use and share your personal data

·      How we protect the personal data we store about you

·      How long we retain your personal data

If you have questions regarding this Privacy Policy or our collection and use of personal data, please contact us as described in the Section “Contact Us”.

2.             INFORMATION WE COLLECT ABOUT YOU

The personal data we collect or have about you will either be provided by you directly, come from other sources or will be collected from your activity on our website or applications and use of the Service as set out below.  

(a)            Information we collect from you directly

When you interact with the Service, at www.finalfantasyxvapp.com, www.epicaction-online.com, any other Epic Action – owned website, or download the Service from a third-party app store, we will collect and store information from you directly as described below, to the extent it is available to us.

(i)             Registration information

You can register with us by using Facebook Connect or other application authentication options to create an account or profile within the Service. We also provide a more typical registration flow where we will collect the following information from you:

·      Age (for age screening and/or to better understand who our users are);

·      E-mail address;

·      Password;

 

We may also offer you the option to complete a user profile that is visible to other Service users. Your user profile may include: a profile image; one or more Service username(s); and an MZ user ID number that is created by MZ and used to identify your profile.

(ii)            When you access Epic Action games on a mobile device

If you access the Service on your mobile telephone or other mobile device, including iPads and tablets, we collect the following information about you, to the extent it is available:

·      Device advertiser ID;

·      MAC Address;

·      WiFi information;

·      IP Address; and

·      Geo-location.

We will create and assign to your device an identifier that is similar to an account number. We will also collect the following information about you, to the extent it is available:

·      Name you have associated with your device;

·      Device type;

·      Telephone number;

·      Country and geo-location;

·      User name, character name;

·      E-mail address; and

·      Your contacts to enable you to invite friends to join you in the Service.

(iii)          Through your participation in online gaming communities

When you use the Service, you will get access to the online gaming community within the Service which gives you the opportunity to communicate or share information not just with us, but also with other users of our Service through:

·      Participating in player forums and message boards;

·      Posting public comments to other users’ profiles or game boards;

·      Sending private messages or invitations to other users, either directly on our websites or to their e-mail accounts;

·      Chat with other users; and

·      Posting web links.

When you participate in online gaming communities in the ways described above, we access and store information about you. The information we store varies by application, and is affected by the privacy settings you and your friends establish in that application. You can control and find out more about these settings within the application. We will collect the following information:

·      Your in-Service username;

·      Your device advertiser ID;

·      Depending on how you log into the Services, Facebook User ID;

·      Fan Status;

·      The IP address of your access devices; and

·      If provided by you, your e-mail address and phone number.

(iv)           Payment information

We will also receive billing and payment information (which is comprised of transaction history, including what you have purchased, the price, and the date) that you provide when your purchase is processed by another party, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices), or Amazon (for purchases on Kindle devices).

(v)            Customer Support correspondence

When you ask for assistance from our Customer Support team, we will collect and store:

·      Your name and e-mail address;

·      Information about your activity on the Service;

·      Your user name or ID number; and

·      Any correspondence connected to the assistance provided to you

(vi)           Technical and usage information

When you access our Services, we collect your:

·      MAC Address;

·      WiFi information;

·      IP Address;

·      Geo-location;

·      Device type; and

·      Device advertiser ID.

We also collect pseudonymous usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files (“Log Files“), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how we utilize cookies and other tracking technologies, please refer to "Cookies and Automated Information Collection".

(b)            Information we collect from other sources

We will collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers such as digital advertising companies; and (iii) social networking sites.

3.             COOKIES AND AUTOMATED INFORMATION COLLECTION

When you access the Service, we collect certain technical information in order to (i) analyze the usage of our sites and Service; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf, such as Google Analytics, will use Log Files and other tracking technologies to collect and analyze certain types of technical information over time and across different websites following your use of the Service, including cookies, WiFi information, IP addresses, geo-location, device type, device identifiers, browser types, browser language, referring and exit pages, and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, Service state and the date and time of activity on our Services, and other similar information. In some cases, we will associate this information with your user ID number for our internal use. Our Service currently does not respond to “Do Not Track” (DNT) settings in your web browser and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy. For further details regarding DNT, visit donottrack.us.

We also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your in-Service preferences and speed up load times.

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality of playing our Services, as cookies are necessary to track and enhance your Service activities. Please note that companies delivering advertisements in our Services or on our websites may also use cookies or other technologies, and those practices are subject to their own policies.

We also use Google Analytics, who uses cookies to help the website analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data, go to google.com/policies/privacy/partners/.

The NAI (Network Advertising Initiative) allows for the central opting out of all its members’ cookies from a single opt-out page. If you prefer not to receive relevant advertising on web pages, please click on the following link: networkadvertising.org/choices/. If you delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice.

4.             HOW WE USE THE INFORMATION WE COLLECT

In general, we collect, store and use your information to provide you with a safe, smooth, efficient, fun, and customized experience, and we use it as necessary to provide you with the Service pursuant to the Terms of Use, for our legitimate interest to understand how our users navigate our websites and apps and to improve our services, including the Service, or on the basis of your consent.  In litigation or for other legal purposes involving us or a third party, we may also need to transfer your personal information to countries with a lower standard of data protection laws than is applicable in your country of residence.

 

We will use information collected from you in any one or more of the following ways:

·      To create your Service accounts and allow access to our Services;

·      To identify and suggest connections with other users;

·      To enable user-to-user communications;

·      To provide technical support and respond to user inquiries;

·      To prevent fraud or potentially illegal activities, and enforce our Terms of Use;

·      To deliver and target advertising;

·      To notify users of in-Service updates;

·      To provide in-Service leader boards and promote in-Service player achievements;

·      To solicit input and feedback to improve MZ group company products and services and customize your user experience;

·      To inform users about new products or promotional offers;

·      To engage in commonly accepted practices, such as contacting you at the email address we have on file if you are a potential winner in a sweepstakes; and

·      To improve and develop our products and Services.

One important use of your information is communication. If you have provided your e-mail address to us, we’ll use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-Service activity, including comments from friends, notifications about in-Service status and requests. Some messages, such as invites for friends to join you in a Service, may include your name and profile photo. We will also send promotional e-mail messages and promotional messages directly or in partnership with third parties only if you have provided your prior consent in accordance with the relevant laws and regulations for us to do so.

5.             SHARING OF YOUR INFORMATION

Epic Action shares your personal data with us (as the controller) and we will share your personal data with our affiliates including in the United States. Please be aware that the US and other jurisdictions may have a lower standard of data protection laws than your own jurisdiction. We will also share your personal data with third party recipients (i.e., parties other than the MZ group of companies) including outside the European Economic Area, in the following circumstances:

(a)            Third party service providers

We provide your information to third party recipients. These categories of recipients include:

·      Hosting providers to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;

·      Email delivery providers that provide us with email delivery services;

·      Provided you have consented, advertisers, ad exchanges and other adtechnology companies that require the data to select and serve relevant advertisements to you and others, and assist us in other marketing efforts;

·      Data analysis providers including Google Analytics that assist us in the improvement and optimization of the websites and apps, and data analysis.

We direct all such third party recipients to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on our behalf.

(b)            Sale or merger

In the event that Epic Action or MZ undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, we may transfer all of your information, including personal data, to the successor organization in such transition.  In such case, we will first notify you in accordance with local law requirements, if any, regarding those items of personal data that will be transferred, the name and contact details of the recipient, and inform you of how you can withdraw consent thereto.

(c)            Safety, security and compliance with law

Your information, and the contents of all of your online communications (including without limitation chat text, voice communications and IP addresses) may be accessed and monitored as necessary to provide the Service and may be disclosed: (i) when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations; (iii) where we believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect our rights or property.

6.             YOUR PRIVACY RIGHTS IN RELATION TO THIRD PARTY DIRECT MARKETING

We do not share personal data with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in“ to receive information from a third party that is participating in a sweepstakes or other promotion on one of our sites. If you do ask us to share your personal data with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers identified above) on a continual basis. To prevent disclosure of your personal data for use in direct marketing by a third party, do not opt in to such use when you provide personal data on one of our sites.

Your access to the Service will not be affected if you do not “opt in” to receive information from such third parties.

7.             OUR POLICIES CONCERNING CHILDREN

Our Services (including websites, games, and applications) are not intended for children (aged 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data from children and we do not knowingly allow children to register for or use the Services. Children should not use our Services or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records. If you believe that we might have information from or about a child, please contact us.

8.             HOW TO ACCESS AND UPDATE YOUR INFORMATION

(a)            Information we receive from a social networking site (“SNS”)

To manage the information we receive about you from an SNS where you use our Service, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Apple can be found here. The privacy management tools for Google can be found here. The privacy management tools for Amazon can be found here. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.

Once we receive your information from an SNS, that information is stored and used by us in accordance with this Privacy Policy, and you may access and update that information as described below. An account for the Service or other accounts created with us are considered active until we receive a user request to delete them or deactivate them.

(b)            Accessing and controlling your information

You have certain rights in relation to the personal data we hold about you, which we detail below, and which are subject to exemptions under applicable data privacy laws. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. We will respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please send an email to support@mz.com.

We may decline to process requests in certain circumstances, such as where requests are manifestly unfounded or excessive or requests that jeopardize the privacy of others.

                                                                                                                       

Find Out More

9.             PUSH NOTIFICATIONS & LOCAL NOTIFICATIONS

When you install our apps on your mobile device you can choose to receive push notifications. Where you opt to receive push notifications, will send push notifications to your mobile device to provide Service updates and other relevant messages. You can turn off push notifications by visiting the “options” or “settings” page within the relevant Service. You may also receive local notifications. You can turn off local notifications by visiting the “options” or “settings” page within the relevant Service.

10.         DATA RETENTION

We retain your personal data for the duration of your account, as long as reasonably necessary to provide you the services, and for such periods necessary to comply with the law.  

 

In the event you request deletion of your personal data in accordance with the process explained above, we will delete it as specified above.  Please note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints. For example, we may retain records pertaining to payments or customer service matters.  If you have sent or posted content on the Service, we may not be able to delete it. 

After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.

11.         PRIVACY POLICIES OF LINKED SITES

Our Service may contain links to third-party websites. We are not responsible for the privacy practices or the content of such websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.

12.         SECURITY OF YOUR INFORMATION

We implement security measures to protect the security of your information both online and offline, and we are committed to the protection of customer information. While we take reasonable precautions against possible security breaches of our Service and our customer databases and records, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Unfortunately, the transmission of information over the Internet is not completely secure. We cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access. We urge you to take steps to keep your personal data safe (including your account password), and to log out of your account after use. If your account is hacked, this may lead to unauthorized access to your Service, so be careful to keep your account information secure. If you have questions about the security of our Service, please contact us at support@mz.com.

13.         INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

As you are contracting for the Services with Epic Action, which is a US company, any information you provide to Epic Action (and therefore to us), or that we collect through your use of the Services that is necessary to provide you the Services, will be stored, processed, and transferred within, or to, the United States. As a result, your information could be accessed by foreign governmental authorities, or otherwise, in accordance with applicable local laws.

Please be aware that the US and jurisdictions other than the one in which you are located will not have the same data protection laws as your own jurisdiction. 

Your personal data is also processed by staff or service providers operating outside the EEA in the United States, who work for us.

14.         COMPLAINTS

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@mz.com and we will endeavor to deal with your request. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

15.         CHANGES TO OUR PRIVACY POLICY

If we decide to make material changes to our Privacy Policy, we will notify you and other users by placing a notice on www.mz.com or by sending you a notice to the e-mail address we have on file for you. We may supplement this process by placing notices in our Services and on other MZ websites. It is your responsibility to periodically check this Privacy Policy for updates.

16.         CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to support@mz.com.  Our data protection officer can be contacted at dataprotectionofficer@mz.com. We will seek to respond to any complaints within thirty (30) Days.