TABLE OF CONTENTS
Invictus Games Ltd. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from European Union member countries and Switzerland. Invictus Games Ltd. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Invictus Games Ltd.’s certification, please visit http://export.gov/safeharbor.
Invictus Games Ltd. collects both personal and non-personal consumer information. Personal information collected by Invictus Games Ltd. is discussed below in this section. Non-personal information is discussed below in Section IV.
Personal information is information that identifies you and that may be used to contact you on-line or off-line. Invictus Games Ltd. may collect personal information from our online visitors during:
Information collected will vary depending upon the activity and may include your name, email address, phone number, home address, birth date, mobile phone number and credit card information. Visitors to Invictus Games Ltd. Mobile may be asked to provide the name of their mobile service carrier, model of their mobile phone and a valid mobile number so that we may provide purchase instructions directly to their mobile phone. In that context, your mobile number will only be used to send you a text message with a link to download your game and will not be retained for any other purpose. Prize winners may be required to provide their Social Security or other identification number for tax purposes, and will be used only for prize fulfillment.
Non-personal information, alone, cannot be used to identify or contact you. Invictus Games Ltd. collects non-personal information about your use of our online and mobile products and services both on our website and in the course of game play and software usage (on PC, mobile and game system platforms).
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information contact email@example.com . There may be instances where we are legally required to retain your information.
When you use Invictus Games Ltd. online and mobile products and services or you play our games on your PC or game system, we may collect certain non-personal demographic information including gender, zip code, information about your computer, hardware, software, platform, game system, media, mobile device, including device IDs, incident data, Internet Protocol (IP) address, network Media Access Control (MAC) address and connection. We also collect other non-personal information such as username, user ID or persona, feature usage, game play statistics, scores and achievements, user rankings and click paths as well as other data that you may provide in surveys, via your account preferences and online profiles such as friends lists or purchases, for instance. We may also receive either non-personal or public information from third parties in connection with market and demographic studies and/or data that we use to supplement personal information provided directly by you.
We and other third parties may also use flash cookies, also known as “local shared objects,” on our sites that employ Flash technology. Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site. Like normal cookies, Flash cookies are represented as small files on your computer. One method of preventing Flash cookies from being placed is to adjust your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com.
Clear GIFs (a.k.a. web bugs, beacons or tags) are small graphic images placed on a web page, web-based document, or in an email message. Clear GIFs are invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the web page, document or email message. We do not use clear GIFs to collect personal information about you. However, we may use clear GIFs to capture statistical usage information for our web pages, features or other elements on a web page. We correlate this information to a user to personalize user experience and for statistical analysis of user experiences on our web pages.
We and third parties may also use tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation.
Invictus Games Ltd. and other third parties also may maintain log files which contain IP addresses. An IP address is a numeric address that may be assigned to your computer by your Internet Service Provider. In general, we use log files to monitor traffic on our websites and to troubleshoot technical problems. In the event of user abuse of our websites, however, we may block certain IP addresses or game system IDs provided by our licensed hardware manufacturers. If available, IP addresses and game system IDs may be used to personally identify you in order to enforce our Terms of Service.
Invictus Games Ltd. also uses its own proprietary analytic metrics tool and other third party analytics technologies to collect non-personal information when you use our online products and services and/or play our games on your PC, game system and/or mobile device. These tools and technologies use server log files, web beacons, cookies, tracking pixels and other tracking technologies to collect and analyze certain types of information, including cookies, IP addresses (including for purposes of determining your approximate geographic location), mobile or other hardware device ID, browser types, browser language, information passed from your browser (if any), referring and exit pages, and URLs, platform type, the number of clicks, information about your media, software and/or applications installed on your machine and/or device, domain names and types, landing pages, pages viewed and the order of those pages, the date and amount of time spent on particular pages, other Internet and website usage information, game state and the date and time of activity on our websites or games, information about how your game is used, including game metrics and statistics, feature usage and purchase history, as well as MAC Address, mobile unique device ID (if applicable) and other similar information.
The third party analytics companies who collect information on our sites and in the context of our online and mobile products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.
The advertising companies who deliver ads for us may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your web browser's activities across their network of websites. Many of these companies collect and use information under their own privacy policies.
For more information about the practices of other large ad serving companies that may collect information based on your interaction with ads on this site and others, or to "opt out" of targeted advertising delivered by National Advertising Initiative (NAI) member ad networks, you should visit www.networkadvertising.org.
These ad serving technologies are integrated into our sites, online or mobile products and services; if you do not want to use this technology, do not play.
Invictus Games Ltd. also obtains personal and non-personal information from third parties as discussed below. Invictus Games Ltd. only uses this data for purposes consistent with this policy.
We may receive other information from third parties, including in connection with the operation and distribution of our products and services as well as market and demographic studies that we use to supplement personal and anonymous information provided directly by you. Some third party services such as Twitter and Facebook may also provide us with information from your accounts there with your permission.
We may also collect or receive information about you from other Invictus Games Ltd. users who choose to upload their email contacts. This information will be stored by us and used primarily to help you and your friends connect.
Invictus Games Ltd. uses your information to fulfill your specific requests, purchase orders and to send you purchase confirmation and other account-related information. In addition, the personal information you provide will allow us to send you messages about things including new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest. You may also later opt out of certain of these communications.
Otherwise, Invictus Games Ltd. uses personal and non-personal information, both individually and combined together, to better understand the behavior and preferences of our customers, to troubleshoot technical problems, to serve static and dynamic advertising, to enforce our Terms of Service, to ensure proper functioning of our products and services as well as to help improve them. In addition, we combine non-personal information with personal information, such as an email address, to administer loyalty programs, tailor our offerings, web pages or game play experience to you.
If you choose to use our referral service to "Tell a Friend" about an Invictus Games Ltd. product or site, we will ask you for your friend’s name and email address. We will send your friend an email on your behalf inviting him or her to visit the site or check out our product. Invictus Games Ltd. stores your friend's name and email for a short period for the sole purpose of sending this email and for redundancy checking, to be sure that your friend does not receive multiple copies of the same email message. We do not keep or use this information for any other purpose.
Your participation in tournaments or other online game events is also conditional upon our collection, use, storage, transmission and public display of statistical data (such as your scores, rankings and achievements) generated through your participation.
Invictus Games Ltd. will never share your personal information with third parties without your consent. We may, however, share anonymous, non-personal, aggregated and/or public information with third parties. There may be circumstances where you may share information on your own. Please see section XI for more details about your rights to information you share publicly on Invictus Games Ltd. and other third party sites and forums. You may also opt in to allow Invictus Games Ltd. to share your personal information with companies and organizations that provide products or services that we believe may be of interest to you. To opt out of further communications from a marketing partner or sponsor with whom your information has been shared, please contact that partner or sponsor directly.
Invictus Games Ltd. does not disclose any personal information about children under 18 years of age who have registered on any of our websites to third parties, or share or disclose personal information other than as set forth in this policy, provided however, that in the event of a merger, acquisition, or the unlikely event of bankruptcy, management of Invictus Games Ltd. customer information may be transferred to its successor or assign regardless of age.
From time to time, Invictus Games Ltd. employs third party contractors to collect personal information on our behalf to provide email delivery, product, prize or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites. When requesting these services, you may be asked to supply your name, mailing address, telephone number and email address to our contractors. We ask some third party contractors, such as credit agencies, data analytics or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors' needs and preferences. To enrich our understanding of individual customers, we tie this information to the personal information you provide to us.
When our third party agents or service providers collect and/or have access any information other than non-personal, anonymous and/or aggregated data, Invictus Games Ltd. requires that they use data consistently with our stated privacy policies and protect the confidentiality of personal information they collect or have access to in the course of their engagement by Invictus Games Ltd.. These third parties are prohibited from using your personal information for any other purpose without your specific consent.
You will be notified before your personal information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
We may also access and disclose personal information, including personal communications, in connection with report abuse functions in our products and services, to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Invictus Games Ltd.. Note that certain publically available information you post and communicate on our and third party sites and services is public information for which you have no expectation of privacy. See Section XI for more details.
Invictus Games Ltd. encourages parents to spend time online with their children. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission when using the Internet. We recognize a special obligation to protect personal information obtained from young children. Therefore, with respect to children residing in certain jurisdictions, no information should be submitted nor posted to Invictus Games Ltd. online sites by children 12 years of age or under.
If children 12 years old and under in such jurisdictions wish to participate in online activities that require or permit the disclosure of personal information, we will request that they provide their parent or guardian's email address to notify the parent, obtain prior permission or other verifiable consent from the parent or guardian as may be necessary to participate in the activities of the site. In some other jurisdictions, notification, prior written permission or other verifiable consent may be required of a parent or guardian for children from 13 to 17 years of age.
Some Invictus Games Ltd. websites are especially targeted to children and may permit children to create a free account for which we collect username, password, date of birth and the parent’s email address. Because an email address is necessary to respond to lost password requests and account administration, in some circumstances we may also collect the child’s email address. In these instances we will send notice to the parent email address to provide an opportunity to opt-out and have the child’s email address and any other details removed. Newsletter subscriptions are handled similarly.
These websites may also offer parents the opportunity to upgrade their child’s account to a paid subscription that permits the child to participate in more activities on the site. These subscription services may also enable parents to manage their child’s account and create new player accounts.
Most of these websites permit children to create custom avatars, or virtual cartoon-like characters, for use in various activities on the website including mini-games and virtual worlds. The child may also use other features to “Tell a Friend” about the website, send eCards or give us feedback. “Tell a Friend” and eCard features allow children to send their friends a one-time email inviting them to visit the site. We will collect your child’s first name and/or email address and the friend’s email address for the sole purpose of sending them this one-time email. This information is not retained or used for any other purpose and we do not share your child’s email address with the recipient.
Feedback may also be provided to Invictus Games Ltd. through “Tell us what you think” features or surveys. “Tell us what you think” collects the sender’s email address and a brief description of their concern. Email addresses obtained through “Tell us what you think” are not used for any purpose other than to respond to the sender. If we determine that the child is under 12, we will delete their email address once we have responded to their inquiry. Survey information is anonymous.
Where chat is allowed for children, users type messages to other users in an open forum setting. In these circumstances, Invictus Games Ltd. uses Safe Chat which restricts children from entering any personally identifiable information by applying a filter to allow only acceptable words and phrases in an attempt to block offensive content as well as attempts to communicate personally identifiable information to other users. Safe Chat also provides users the option of selecting pre-approved common phrases. Where chat is provided, Report Abuse links are also maintained to further enhance the safety of the site.
Parents may delete previously registered players at any time by emailing through firstname.lastname@example.org .
Under no circumstances do we condition a child's participation in an activity—like contests—on the child's disclosure of more personal information than is reasonably necessary to participate in the activity. On certain sites, we may not permit children to participate at all regardless of consent. Where consent is granted, consent is applicable only to that site. Regardless of jurisdiction, Invictus Games Ltd. does not disclose any personal information about children less than 18 years of age who have registered on any of our websites to third parties, or share or disclose personal information other than as set forth in this policy.
You may choose to disclose information about yourself in the course of contributing user generated content to Invictus Games Ltd. sites or games or in our online chat rooms, blogs, message boards, user “profiles” for public view or in similar forums on our sites and/or on third party sites. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality there.
You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to make public in any of these forums.
Note also that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Invictus Games Ltd. has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.
If you post a video, image or photo on one of our sites for public view 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 the videos, images or photos that you choose to submit to Invictus Games Ltd.’s site.