Privacy Policy - Homeworld Mobile

LAST UPDATED 01.30.20

Welcome to Gearbox!

Privacy and transparency are important to us: accordingly, this Policy explains how we collect, use, and share information. In order to make Gearbox experiences as entertaining—and transparent—as possible, we have adopted the following Privacy Policy (“Policy”). Because the use of our website, its related sites and services (collectively, “Gearbox”) first requires acceptance of the Policy, please take a moment to familiarize yourself with it. Specifically, this Privacy Policy governs any personal information and non-personal information collected when you use Gearbox and its online services.

Gearbox is designed to foster a relationship between Gearbox members (“Members”) and Gearbox content. Ideally, the relationship between our content and our community will grow stronger and more robust as Gearbox matures. To help facilitate this process, information is exchanged between Members, their equipment and Gearbox. Gearbox respects that Members are trusting us with their information, and we’re committed to being reasonable custodians of Members’ information. The types of information collected are detailed below. The Gearbox Online Services (“Online Services”) themselves do not track Members through the use of “cookies” or collect personal information. Websites use cookies and are capable of tracking Members unless the Members block cookies and turn on the Do Not Track option.

Use of the Online Service is voluntary. This includes any channels provided for interacting with other Members. Some Members like to run with the pack, while some don’t; we understand both preferences. If you are uncertain about sharing data at all, please forego use of the Online Service entirely until you achieve whatever level of comfort you need. We have no desire to make the experience awkward or difficult.

Please don’t be bashful with your constructive compliments and criticisms—both are welcome. If you have any thoughts or ideas about where things are/aren’t working well, we want to know that. You can reach out to us directly to share your ideas at [email protected].

To foster the Member community, we intend to convey—and support—various promotions via emails to Members. We’re determined to keep this from becoming annoying; if we’re failing, please let us know. Members who wish to do so, may use the “unsubscribe from this list” or “update subscription preferences” links located at the bottom of any email you receive from Gearbox; or you can delete your account to stop such communications.

All Members must be over the age of 13 to use our Online Services, and at least 18 years of age to access certain games. Gearbox does not intentionally collect personal information from children under the age of 13, and any such information will be deleted upon discovery. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please do not allow your child to access the Online Services and contact [email protected].

To fully enjoy the services available from Gearbox®, individuals should create a Gearbox SHiFT® account, and must respect the rights of others throughout their use. Like a bad roommate, Members who detract from the Online Service will be promptly evicted from the Gearbox community. No Member is entitled to use of the Online Service or its content at the expense of other Members.

Links to other websites are provided for Member convenience and information; those links have their own terms, conditions, and privacy policies. Members may also be bound by the separate terms of their respective software, products, platforms, hardware and equipment. We recommend that you carefully review all such terms.

Members understand and agree that the Online Service is provided “AS-IS” and without warranties or duties of any kind.

Again, the official Policy is below…game on!

PRIVACY POLICY:

Gearbox Publishing, LLC, a United States company, its partners and affiliates (collectively “Gearbox”), respects the privacy rights of those who access and use its services and is committed to protecting the information collected through its online products, services, and websites accessed through any internet-capable hardware platform including gaming consoles, personal computers, mobile computers, or smart phones, or in-game applications or any software platform including third-party hosts (collectively the “Online Services”). We have adopted this Privacy Policy to explain how we collect, store, disclose, transfer, protect, and otherwise use the information collected in connection with our Online Services (the “Privacy Policy”).

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY. BY REGISTERING FOR OR USING OUR ONLINE SERVICES, YOU AGREE THAT (i) WE MAY TRANSFER, PROCESS, AND STORE YOUR ACCOUNT INFORMATION IN THE UNITED STATES OF AMERICA WHICH MAY HAVE DIFFERENT PRIVACY PROTECTIONS THAN YOUR COUNTRY; (ii) WE MAY PROCESS YOUR DATA IN ACCORDANCE WITH THE FOLLOWING PRIVACY POLICY; (iii) YOU ARE BOUND BY GEARBOX’S PRIVACY POLICY; AND (iv) YOU WILL ABIDE BY OUR TERMS & CONDITIONS AND ANY OTHER POLICIES THAT MAY APPLY. THIS PRIVACY POLICY SUPPLEMENTS THE PRIVACY DISCLOSURES PROVIDED TO YOU WITH YOUR SOFTWARE PRODUCT AND/OR BY YOUR CONSOLE MANUFACTURER.

This Privacy Policy will explain:

The scope of this Privacy Policy
Information Gearbox collects
Gameplay information Gearbox collects
The limitations, if any, resulting from you not wanting to share personal information
How we use cookies, track IP Addresses, or use other passive means to collect information
How we use information we collect
How we share information we collect
What choices you have with regard to the use of your personal information
Links to other parties
Children’s privacy
How we protect your information
Your California Privacy Rights
Where information is stored
How to contact us

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies only to information collected on or through the Services offered to you by Gearbox, and to information shared with Gearbox by certain third parties (as further described in this Privacy Policy). It does not apply to any other information collected by Gearbox through any other means.

Please note that this Privacy Policy applies only to information submitted and collected online through the Gearbox SHiFT service, and does not apply to information that may be collected by Gearbox from direct emails from you to individuals at Gearbox, offline, or by third party sites you use to connect to the Gearbox website.

We reserve the right to change this Privacy Policy. Please check back from time to time to ensure you are aware of any changes. If we make a material change to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page. If necessary, we will give you additional choices regarding such change in these notices. As permitted by applicable law, your continued use of our products and services signifies your acceptance of such changes.

You may choose to voluntarily provide us with various personal information and non-personal information through your use of the Online Services. We also may use “cookies” and other passive technologies including clear gifs to collect certain non-personal information from you in connection with your use of the Online Services, such as the pages you visit and the features you use. Our cookies are linked to your IP or MAC address.

INFORMATION GEARBOX COLLECTS

Personal information is information that identifies you and that may be used to contact you online or offline. Gearbox collects personal information from you on a voluntary basis. When you submit personal information to Gearbox, it will usually take the form of:

Registration for Online Services, websites, products, contests, and special events;
Subscribing to newsletters or alerts;
Posting in or commenting on our message boards, forums, news blogs, chat rooms, or other Online Services;
Purchasing products or services through our online stores;
Using “tell a friend,” “email this page,” or other similar features;
Requesting technical support;
Downloading demos, programs, or software;
Participating in polls, surveys, and questionnaires; or
Otherwise through use of our software, including console products, mobile products, and personal computer products, and through the use of our online products or Online Services where personal information is required for use and/or participation.

The types of information collected in connection with the activities listed above can vary depending on your activity. The information we collect may include:

first and/or last name;
e-mail address;
telephone number;
photographic images, if uploaded by user;
credit card number, if provided for purchases;
IP or MAC address;
game device identifier;
user/game name; or
demographic information (age, gender, date of birth), if provided by user in surveys or forums.

In addition, we may collect generalized geographic information about you or your systems, such as your hardware configuration, console ID, software products played, survey data, purchases, IP address and the systems you have played on. We may combine the information with your personal information. Prize winners may be required to provide additional information for prize fulfillment.

GAMEPLAY INFORMATION GEARBOX COLLECTS

When you use products or services on Internet-capable hardware, Gearbox may receive information regarding your gameplay without any additional notice to you or actions taken by you. Subject to the terms in this Privacy Policy, Gearbox will not receive personal information such as your name and address, but may receive other information such as a console ID, gaming service ID, game achievements, game scores and performance, IP address, MAC address, or other device ID, other console/device use information, or other information and statistics regarding your usage of the games. Information about gameplay may be collected while you are offline and transmitted to Gearbox when you next connect to the Internet whether or not you are currently logged into your Internet Connection from your console, handheld, mobile device, computer, or other gaming platform. Gearbox may combine the information with your personal information and use such information as set forth in this Privacy Policy whether or not you register for or use our services. Gearbox may also monitor gameplay information by automated means to ensure that software and services are used in accordance with applicable policies, including the Terms of Service and the End User License Agreement. Gearbox reserves the right to terminate any Gearbox license upon violating these policies.

SPECIAL NOTES ABOUT CERTAIN INFORMATION GEARBOX COLLECTS

Member Names & IDs/Gaming Consoles/Other Third-Party Services: Certain services offered by Gearbox, including multiplayer gaming and specialized websites, use third-party services to (i) provide authentication for the services; or (ii) associate a SHiFT account with a third-party account such as a gaming console ID, or gaming network service account. When you use a third-party authentication service or link your SHiFT account with a third-party account, you will be asked to provide account information associated with that third-party account. Certain membership information may be transferred automatically to Gearbox when you register to join SHiFT from a third-party gaming network system or link your SHiFT account with a third-party service, such as your friends list on that gaming network or social network service.

Public Information Including Message Boards, Forums, News Blogs and Comments: Whenever you give out personal information in public areas such as on a message board, chat room, comment field, or profile page, that information can be collected and used by other people. Information that you disclose in any of these forums is public information, for which no expectation of privacy or confidentiality exists. You should be aware that any personal 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 or identify you. If you post a video, image, photo, or other content through one of these services for public view, you should be aware that these may be viewed, collected, copied, and/or used by other users without your consent. If your screen name or an ID contains your real name, that name will be made publicly available on leaderboards and elsewhere. Therefore, you are strongly encouraged not to disclose personal information while using our services or use personal information to identify yourself while using our services. You are responsible for any public information or content you post using Gearbox’s services.

E-mail Correspondence: We may provide e-mail addresses or forms to which visitors can send us questions or comments, or which visitors can use to request customer support. In the process of receiving and responding to such requests, we may collect personal information about you, such as your e-mail address or any other personal data contained in the body of your e-mail message. By allowing you to send us these requests, we are not attempting to solicit personal information from you. We only use the information for the purpose of responding to your questions and/or comments or to provide customer support. In most cases, your message is deleted immediately after we’ve resolved your inquiry; however, in some instances, copies of your requests may be kept on file for our records, for legal and/or quality control purposes, or to provide ongoing support services you have requested. If we obtain actual knowledge that the person with whom we’re communicating is a child under the age of thirteen, we promptly delete the child’s e-mail address and messages.

In addition to responding to your email correspondence and sending you information you have requested via our email lists, we send activation emails and other transactional emails to your e-mail address as necessary. You may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive such messages, you have the option to deactivate your account.

Resumes: Gearbox allows for the online submission of resumes. Personal information collected from resumes will be used solely for the purpose of accepting and evaluating candidate submissions for job postings, and is therefore not governed by this Privacy Policy. Information obtained from resumes may be shared within Gearbox by parents, subsidiaries, or affiliates. You can view our job applicant privacy policy here: https://www.gearboxsoftware.com/applicantprivacypolicy/

WHAT HAPPENS IF I REFUSE TO PROVIDE MY PERSONAL INFORMATION?

Your refusal to submit personal information may limit your ability to participate in some activities, such as sweepstakes or the use of certain Online Services. As described above, regardless of registration we may publish gameplay boards and multiplayer match records containing certain information as a result of your use of the products, where they are essential components of the services we offer you and other users (e.g., your online ID).

DO YOUR ONLINE SERVICES USE COOKIES, TRACK IP ADDRESSES, OR USE OTHER PASSIVE MEANS TO COLLECT INFORMATION?

Gearbox uses cookies, web beacons, and similar tracking devices for certain Online Services to collect information. If you choose to provide us with personal information, it may be linked to the information collected by these technologies.

Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Our cookies are typically used to quickly identify a user’s computer, browser, or device and to “remember” things about prior visits (such as the user’s use of various features on the service). You can disable cookies or set your browser to alert you when cookies are being sent to your computer; however, disabling cookies may affect your ability to use certain Online Services.
Web Beacons: A “web beacon” is an electronic image that allows websites to count users who have visited certain pages or viewed certain advertisements.
Internet Log Files: Gearbox may also keep track of IP addresses used to access its Online Services for various reasons. An IP address is a number that is used by a networked device and will identify your point of connection to the internet. Depending on your network configuration, it may also identify your computer, or other device. A MAC address or other device ID identifies one specific piece of hardware. These log files are tied to your personal information in certain circumstances, such as if you have linked your console user account to Online Service accounts offered by Gearbox.
Analytic Metrics Tools and Other Technologies: Other information that may be passively collected by Gearbox includes log files that record information about your hardware, product use, service use, or website use, including website navigation and game telemetry activity. We also use these log file entries for our internal marketing, service design, technical support, and demographic studies, so we can constantly improve the Online Services we provide you.
Advertising Service Providers: Some of our Online Services are supported by advertising provided by Gearbox or various third-party advertising agents, such as ad networks, data exchanges, traffic management service providers and marketing analytics service providers (“Advertising Service Providers”). Such Online Services may place and use cookies, web beacons, and similar technologies to collect information about your device and your use of Online Services. The information such Advertising Service Providers may collect, or we may share with them, includes your device type, IP address, MAC address or other device ID, browser type, language, operating system and generalized geographic location; the types of pages, content and ads you, or others who are using your device, visited or viewed and the frequency of your visit/viewing; and information regarding your use of or activities in connection with a website or Online Service (e.g., time spent using a mobile application or your purchases). This information may be collected or shared when you use an Online Service, click on a webpage or an advertisement, or launch one of our game or other mobile applications that you have installed, and may be used: (1) to ensure that an Advertising Service Provider is accurately and properly paid for an advertisement it placed on our behalf (e.g., an ad that led you to purchase or download one of our games or other mobile applications); (2) to help prevent you from seeing the same ads over and over again; (3) to help select and display targeted ads or other content on your computer or other device (such as on a website you are viewing or a mobile application you are using) that may be of particular interest to you; (4) to measure and analyze advertising effectiveness and/or traffic in our Online Services and determine the popularity of certain content; and (5) to monitor and analyze the usage of our Online Services, so that we can continually enhance and improve them.
Third-party Advertisers: Gearbox works with various third-party advertising agents that use cookies, web beacons, and similar technologies to collect information. Because we cannot ensure access or control over third-party tracking technologies, Members are encouraged to learn more about these vendors, their privacy policies, and the ability to opt out of their tracking programs before disclosing any information. Additional information about individual opt-out programs is currently available on the World Privacy Forum website at https://www.worldprivacyforum.org/category/opt-out/. In addition to visiting the websites of each of the vendors listed above, Members are invited to visit the Network Advertising Initiative’s website at http://www.networkadvertising.org/managing/opt_out.asp for more information regarding various opt-out options.

DO NOT TRACK

Gearbox honors but does not respond to Do Not Track (DNT) signals. Gearbox uses personal information (as stated above in Information Gearbox Collects) for Gearbox’s own use to identify Members over time during online gaming. Gearbox does not track Members across other websites.

Members may choose to use the DNT option on their electronic devices used to access the Online Services provided by Gearbox. DNT may interfere with some gaming features relating to generalized geographic areas, personalizations on your account, and game play where you might have to re-enter your date of birth each time you login to play a game. Gearbox does not retain date of birth information; it is strictly used for appropriate age access to games.

HOW WE USE INFORMATION WE COLLECT

When you submit information to Gearbox via our Online Services, or information is collected as described in this Privacy Policy, that information is received by Gearbox. Gearbox uses this information to send you promotional materials, to provide you with access to our services, to fulfill product orders, send you promotional materials, to respond to questions or technical problems, and as otherwise described to you at the time of collection or with your permission. We also use your personal and other information for our internal marketing and demographic studies, so we can constantly improve the products and services we provide you and to better meet your needs.

Your participation in tournaments or other online game events is conditional upon our collection, use, storage, transmission and public display of statistical data (such as your scores, rankings, and achievements) generated through your participation.

Members of SHiFT may be automatically entered into sweepstakes as a result of their membership and/or use of certain services. Check frequently at www.gearboxpublishing.com for details regarding sweepstakes.

Online gaming and social networking services are by their very nature open communities where gameplay information including user name, game activity, and leaderboard rankings are publicly posted for other people to see. Therefore, Gearbox will automatically post certain information, such as your user/game name or ID and gameplay statistics, within the game, on Social Networking Services, on Online Services, or on specialized game websites. However, we will not post information that we know directly identifies you (such as your real name or email address) unless you provide that information voluntarily for such use. As with other gameplay information services, your gameplay, leaderboards, and multiplayer match information may appear nested in our games or third-party webpages via frames or widgets.

We may match and/or combine information collected in connection with various Online Services and display it publicly, including on our websites, in our games, or in multiplayer game lobbies. For example, if you associate your Company website account with a game console account, your in-game achievements may be displayed combining your website account name with your in-game achievements.

Some of our Online Services allow you to link your account to SNS services like Facebook and Twitter. Certain membership information may be transferred automatically to Gearbox when you link your Online Service membership with SNS account, such as your friends list. Some SNS services also give you the option to post information about the Online Services to their websites to share with others. If you choose to use these features, your actions are governed by the privacy policy of the company providing the feature. Please review each company’s governing policies before using their services.

Some of our Online Services offer SNS features and Widgets, such as the Facebook “Like” button, Google + button, or the Share This button. These third-party SNS features may set a cookie to enable the Feature to function properly and may collect information about you when you use them, such as your IP or MAC address and which page you are visiting on our site. SNS features and Widgets are either hosted by a third party or hosted directly by our Online Services. Your interactions with these Features are governed by the privacy policy of the company providing the Feature. Please review each company’s governing policies before using their services.

From time to time, Gearbox may use partners (including our publishing partners), affiliates, and vendors to perform services on behalf of, or in cooperation with, Gearbox. These partners, affiliates, and vendors provide support to Gearbox by operating some of the services we provide you such as contest entry collection, marketing, and email services. Although these partners, affiliates, and vendors, not Gearbox, may collect, use, or maintain the information in connection with the Online Services, for personal information and other information they use on our behalf or in cooperation with us, Gearbox still requires that they adhere to Gearbox’s stated privacy policies and that they not use the information for their own, or a third party’s, marketing purposes. The partners, affiliates, and vendors may communicate with you using the Gearbox name, the name of the Online Services, or the name of game.

HOW WE SHARE INFORMATION WE COLLECT

Gearbox may share your personal information with third parties as described in this Privacy Policy. Gearbox may share your personal information to fulfill a request you have made, such as signing up for an email list or requesting customer support, technical support, contest data, newsletters, and email fulfillment. In the event we offer services or promotions where your personal information is separately collected and used according to the privacy policy of a third party, we will inform you of that at the time of collection and you may elect not to participate in the service or promotion. Additionally, Gearbox may share your personal information and other information (including gameplay and analytics information) with select third parties such as our partners and affiliates for their marketing purposes. In addition, we may share aggregate and other information regarding Online Service usage statistics and user demographics with third parties.

We may share your personal and other information with third parties in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability, including as required by law enforcement or other government officials. We also may share your personal and other information with third parties 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, investigate, or enforce our policies, terms and conditions, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Gearbox.

In addition, your personal and other information may be disclosed to a potential or actual successor or assign in connection with a proposed or consummated merger, acquisition, reorganization, bankruptcy, or other similar event involving all or a portion of Gearbox, Gearbox’s customer information may be transferred to our successor or assign.

WHEN GEARBOX WILL ASK TO PROCESS YOUR INFORMATION

We may ask you for consent to collect or use your personal information for specific purposes, such as when we want to inform you by email about special offers or competitions or if you decide to link your account with us to a social networking service. We also process your information in order to fulfil your requests, such as to complete transactions with you and to allow you to play games online. We may also process your information in accordance with our policies or when required by law. We also process your information in accordance with law to support the interests of our business, operations, and services, such as to ensure the proaper function, security, or integrity of our services.

YOUR RIGHTS TO REVIEW, CONTROL, CORRECT & DELETE THE USE OR DISPLAY OF DATA

You have the right to withdraw your consent for processing of your personal information for marketing purposes at any time. If you do not want to receive certain communications such as newsletters or promotional offers, you may indicate your preference at the time your personal information is requested or later opt-out by using the methods listed below. In addition to the methods below, along with every communication sent to you, Gearbox gives you the opportunity to discontinue receiving future communications on each communication it sends by providing links at the bottom of the email communication.

If for any reason you wish to unsubscribe to Gearbox mailing lists, please log in to manage your account or use the “unsubscribe from this list” or “update subscription preferences” links at the bottom of any Gearbox email message. To delete your Gearbox account, sign into your SHiFT account at https://shift.gearboxsoftware.com, click the “Other” link, then click “Delete My Account”. If you do not want your gameplay information to publicly appear via the Gearbox site(s), then you should visit and follow the instructions to opt out of our gameplay information services. Please note that, even if you opt out of participation in SHiFT, your gameplay information may still appear on certain gameplay boards including those hosted by third parties such as console manufacturers (including copies of those boards hosted on the Gearbox website and SHiFT) and Gearbox will continue to collect and store information regarding your usage of its games for internal purposes.

In addition to the above methods, you may to request to delete, restrict, correct, or receive a copy of the personal information collected about you. To the extent these rights apply in your country, they may be limited in some situations, for example where Gearbox is under a legal requirement to retain certain information. Requests may be sent via e-mail to [email protected], or you may write to us at Gearbox Publishing, ATTN: Privacy Policy, 5757 Main St., Suite 500, Frisco, TX 75034. Please indicate your country of residence in your correspondence.

Data Retention: We will retain your personal information for as long as your account is active or as needed to provide the relevant services. After such time, we will either delete or anonymize your information or, if this is not possible (e.g., because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion occurs. If you wish to cancel your account or request that we no longer use your personal information to provide you services, please contact us as described herein. If your account is inactive for a period of time, it may be deleted. If information is changed or deleted, we may still retain some of your information in our files to resolve disputes, enforce our Terms of Service agreement, administer our services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Online Services.

In all cases for our Online Services, we will respond to your request for access to update, delete, or correct inaccuracies to your personal information.

LINKS TO OTHER SITES

You should be aware that while you are on our websites you could be directed to other sites that are beyond our control. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. Because we cannot guarantee that the privacy policies of these websites meet our high standards, we recommend reading the privacy policy of the website you link to before you submit any of your personal information.

CHILDREN’S PRIVACY

No one under the age of 13 is invited or eligible to become a user or Member. Gearbox does not knowingly collect personal information from children under 13 years old. If we become aware that a child under 13 has submitted information to Gearbox, we delete this information following its discovery. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.

WHAT SAFEGUARDS ARE USED TO PROTECT MY PERSONAL INFORMATION?

To protect your personal information, Gearbox follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. Gearbox has security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal information collected by Gearbox is stored in secure operating environments that are not available to the public (e.g., locked rooms). To prevent unauthorized electronic access to personal information, Gearbox maintains information collected online behind a firewall-protected server and uses SSL encryption for accounts and purchases made through the Gearbox online store. However, no system can be 100% secure and human errors occur, so there is the possibility that there could be unauthorized access to your information. By using our services, you assume all such risks.

CALIFORNIA PRIVACY RIGHTS

This section provides information for California residents. Gearbox may require proof of California residency before responding to requests made under this section.

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If this Privacy Policy states that any personal information may be shared with third parties for their direct marketing purposes, you may send inquiries (in English, please) regarding our disclosure policy to Gearbox Publishing, LLC, ATTN: Privacy Policy, 5757 Main St., Suite 500, Frisco, TX 75034.

CALIFORNIA CONSUMER PRIVACY ACT OF 2018

Categories of Personal Information Collected

In the chart below, we identify each category of personal information that we have collected about our users in the last 12 months using the categories enumerated in the California Consumer Privacy Act (“CCPA”). For each category of personal information we have collected, we also identify (i) the source(s) from which the information was collected; (ii) the purpose(s) for which it was collected; and (iii) the categories of third parties, if any, with which it has been shared.

Each category of information is collected for the purposes listed below and (1) to provide our games and services, (2) for fraud prevention and legal purposes, (3) to secure our services and users, including to prevent cheating and bad behavior, and (4) for audit purposes.

Categories of Personal Information	Sources	Purposes for Collection
Personal Identifiers, such as your account name, SHiFT ID, name, email address, phone numbers, social media handles	You, both directly and through your use of our games and services Our vendors Our affiliates and business partners Social media and other third-party accounts, if you choose to link them	Communicate with you Customer service Personalize and improve your experience on our systems and websites Newsletters, Marketing, Surveys
Protected Classifications, such as your age/date of birth	You, both directly and through your use of our games and services Our vendors Our affiliates and business partners	Make sure you are of an appropriate age to play our games Personalize and improve your experience on our systems and websites Newsletters and Marketing (to confirm you are of age to receive our promotional materials) Surveys (only anonymously)
Commercial Information, such as your order details/history, subscriptions, refunds, payments, shipping details	You, both directly and through your use of our games and services Our vendors Our affiliates and business partners	Communicate with you Customer service
Activity Information, such as your region, activity log, cookies, operating systems and versions, forum content	You, both directly and through your use of our games and services Our vendors Our affiliates and business partners	Communicate with you Customer service Personalize and improve your experience on our systems and websites Newsletters, Marketing, and Surveys
Inferences about a Person, such as your reputation, experience	You, both directly and through your use of our games and services Our vendors Our affiliates and business partners Social media and other third-party accounts, if you choose to link them	Communicate with you Personalize and improve your experience on our systems and websites Newsletters, Marketing, and Surveys
Geolocation Data, such as your geolocation based on IP address, IP address	You, both directly and through your use of our games and services Our affiliates and business partners	Customer service Personalize and improve your experience on our systems and websites Newsletters, Marketing, and Surveys
Customer Service, such as your account restriction history, case details, complaints and penalty histories, issue raised	You, both directly and through your use of our games and services	Communicate with you Customer service Personalize and improve your experience on our systems and websites Newsletters, Marketing, and Surveys
Tournament/Match Data, such as your match details, team profile, performance stats, tournament details, player handle	You, both directly and through your use of our games and services Our affiliates and business partners	Game rankings; leaderboards Newsletters, Marketing, and Surveys
Game Data, such as your purchased items in game, unlocks, social, progression	You, both directly and through your use of our games and services	Customer service Personalize and improve your experience on our systems and websites Newsletters, Marketing, and Surveys

Data within each of the categories of data above may be shared with third parties for the following purposes:

Rights of California Residents

Right to Know: If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:

If possible, we will provide this information to you in a readily usable format that allows transmission to another entity.

To submit a request, please email us at [email protected]. Email requests must include “Your California Privacy Rights” in the subject field. Within 10 days of receipt, we will let you know we received your request. We will provide a substantive response within 45 days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request, but if applicable, we will refer you to the applicable sections of this Privacy Policy that address our data collection and use practices. If we deny your request, even if only in part, we will explain the reason in our response.

Right to Delete: If you are a California resident, you may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please email us at [email protected]. Email requests must include “Your California Privacy Rights” in the subject field. Within 10 days of receipt, we will confirm receipt of your request. We will provide a substantive response within 45 days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request to delete. If we deny your request, even if only in part, we will explain the reason in our response.

Right to be Free from Discrimination: We may not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.

Right to Opt-Out: California residents may opt out of the “sale” of their personal information, as defined by the CCPA. This does not include when:

• You direct us to disclose your personal information or use us to interact with a third party and the third party does not sell the personal information;
• We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information;
• Your personal information is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
• We use or share your personal information under a written contract with a service provider necessary to perform a business purpose. Here, the service the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information for any purpose other than for the specific purpose identified in the contract.

In these cases, the disclosure of your personal information would not be considered a “sale” under CCPA. We use and share your information as described in this privacy policy and do not believe this use and sharing is a sale as defined by the CCPA. We have not sold personal information about you in the last 12 months and currently have no plans to do so in the future. However, we have provided you with a system to record your preference that your data not be sold in the future. You may make this request by following the instructions on this link or mailing it to us at Gearbox Publishing, LLC, ATTN: Privacy Policy, 5757 Main St., Suite 500, Frisco, TX 75034.

Exercising Your Rights: To submit a verifiable request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.

Children: Our Services are not directed to children, and we do not knowingly collect Personal Information from children under the age of 16. If you learn that a child has provided us with Personal Information, then you may contact us as indicated above.

TRANSFER OF YOUR INFORMATION TO THE UNITED STATES

All information collected or received by Gearbox in connection with the Online Services is collected in, processed in, or transferred to the United States of America. While your information is in another jurisdiction, it may be accessed by the courts, law enforcement, and national security authorities pursuant to the laws of those jurisdictions. If you are a consumer residing in the European Union, Gearbox relies on consent of the individual to transfer personal information from the European Economic Area (EEA) to non-EEA countries. By using our services, you expressly consent to such collection, transfer, and processing. Backup data, matchmaking data, and administrative data may also be stored on media or servers located in the United States of America.

OTHER TERMS FOR THIRD-PARTY PLATFORMS

You may be able to sign up for or access the Online Services through third-party platforms such as gaming consoles, mobile devices, other websites and social networking services. When you submit personal information to Gearbox via a third-party platform, your use of that platform is also governed by its terms of service, privacy policies and/or code of conduct. Please review each company’s governing policies before using their services.

HOW TO CONTACT US

For all questions or complaints about this Privacy Policy, contact our Privacy Policy Administrator via email (in English, please) at [email protected]; or, by regular mail at Gearbox Publishing, LLC, ATTN: Privacy Policy, 5757 Main St., Suite 500, Frisco, TX 75034. If you have a disability that makes exercising any of your rights in this Privacy Policy difficult, we want to help you through alternative means. Please contact us using the contact information above and let us know how we may best help you.

If you are a Gearbox Online Services user located in the European Union, please indicate that in your email or letter, with the understanding that you may also have the right to complain to an EU data protection authority.