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PRIVACY POLICY AND NOTICE AT COLLECTION
EFFECTIVE DATE: JULY 1, 2023
Below is our Privacy Policy. It is long, but worth the read as it explains how
we use your personal information. At a high-level, we wanted to explain what
personal information we process for Among Us and our website.
Among Us:
* To protect our child users, we use your date of birth, country, and IP
address to verify whether you are a child.
* To create an account, we will collect your username, IP address, and email
address. If you are a child user, we will send your parent’s email to
SuperAwesome, so your parent can set your permissions regarding personal
information for our game.
* To link your account with another game platform account, we will use your
username and online IDs, and in some cases, your IP address and email
address.
* If you buy something in-game, we may receive additional personal information
to fulfill those purchases such as your name, address, and payment
information.
* If you are in a lobby when another user reports you for violations of our
Terms of Use or other inappropriate conduct, your username, IP address, and
gameplay information may be stored for moderation purposes.
* If you reach out to us directly, we may use that information to help fix the
problem you reported.
* We do not collect any sensitive information from you, such as your precise
geolocation, or sell or share your personal information for ads or profiling
purposes.
* Please do not put private information in your username or chat. Someone may
use or save it even if we do not.
Website:
* If you buy something on our website, we will use your name, postal address,
telephone number, email address, payment information, and purchase history to
fulfill those orders.
* If you sign up for our marketing newsletter, we will use the email address
you provide.
* If you reach out to us directly, we may use the information provided to help
fix the problem you reported.
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Innersloth LLC, a Washington limited liability company (“we,” “us,” “our,” and
their derivatives) provides websites, including www.innersloth.com and its
subdomains (collectively, the “Website”), the videogame known as “Among Us” (the
“Game”), and other online services (collectively, with the Website and the Game,
the “Services”).
1. What does this Policy cover?
This Privacy Policy and Notice at Collection (this “Policy”) sets forth how we
collect, use, protect, store, disclose, and otherwise process your Personal
Information (defined below). Because we do not process any Personal Information
for our videogames known as “Dig2China,” “Henry Stickmin Collection,” and “Among
Us VR,” those games are not covered by this Policy. You should review Schell
Games’ Privacy Policy for more information about how it collects, uses, and
shares the Personal Information it obtains and uses for “Among Us VR.”
This Policy also does NOT apply to information you provide to any third party or
is collected by any third party (except as otherwise provided below).
By using our Services, you are confirming that you understand English well
enough to understand this Policy. Should you have questions about this Policy,
please contact us by emailing us at privacy@innersloth.com or mailing your
questions to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.
2. How do we process Children’s Personal Information?
A “Child” is a person under the age needed to consent to the processing of
Personal Information in their country of residence (for example, 13 years old in
the United States and between 13 and 16 years old in the European Union). Please
see below for a summary of our practices with respect to the collection of
Personal Information from Children and the use and disclosure of such
information.
Quick-Chat Mode
If a user of our Game self-identifies or is identified by us as being a Child
(each, a “Child User”), their gameplay experience will automatically be set to
“Quick-Chat Mode,” unless the parent or legal guardian of the Child permits
otherwise. Child Users in Quick-Chat Mode are restricted from communicating with
or otherwise making their Personal Information publicly available to other users
of our Game. Child Users will only be able to use a set of fixed phrases to
communicate with other users in Quick-Chat Mode and will not have links to
social media in our Game. Each of these features is designed to limit our access
and the access of other users of our Game to the Personal Information of Child
Users in compliance with the Children’s Online Privacy Protection Act of 1998
and its rules (“COPPA”).
Accounts
Child Users may register an account with us using a registration process similar
to the one adults go through; however, in compliance with COPPA, Child Users
will first be subject to a parental notice and verified parental consent
process. To initiate the registration and consent process for a Child User, we
collect a parent or legal guardian’s email address. We will automatically
generate randomized usernames for registered Child Users, unless the parent or
legal guardian grants the Child User permission to create a custom username.
Child Users using an Apple or Google family sharing account are not permitted to
register another account with us and are subject to the most restrictive privacy
settings in the Game.
Use and Disclosure
The Personal Information we collect from or about Child Users is used to give
them access to certain features of our Game and communicate with a parent or
legal guardian about the Child User’s registration, including for the purpose of
verifying their information in connection with the registration. We do not share
or otherwise disclose Child Users’ Personal Information, except (1) as may be
necessary to protect the safety of a Child, including by disclosing their
Personal Information, where appropriate, to law enforcement agencies or for an
investigation related to public safety; (2) to enable us to take precautions
against liability; (3) to protect the integrity, safety, and security of our
Game; or (4) where required to do so by law or legal process.
We and the third-party service providers listed below may collect or maintain
Child Users’ Personal Information through our Game. You should review their
privacy policies linked below.
* SuperAwesome Trading Limited (a parental and legal guardian consent
management provider);
* Zendesk, Inc. and Keywords Studios Plc (each a player support service
provider);
* ModSquad, Inc. (a moderation service provider); and
* Epic Games, Inc. (in its capacity as a backend service provider (for example,
for account management and linking)).
When a parent or legal guardian consents to permitting their Child User’s
account to be linked with any of the below third party digital content stores
and game platforms, we may receive such Child User’s Personal Information
through our Game. You should review their privacy policies linked below.
* Itch Corp.;
* Epic Games, Inc.;
* Google LLC;
* Microsoft Corp.;
* Apple Inc.;
* Valve Corp.;
* Sony Interactive Entertainment LLC; and
* Nintendo of America Inc.
Please contact us with questions about our service providers’ privacy policies
and our collection and use practices by emailing us at privacy@innersloth.com
with the subject line “Children’s Privacy” or mailing your request to Innersloth
LLC, PO Box 2532, Redmond, WA 98073, USA.
At any time, a parent or legal guardian may review their Child’s Personal
Information retained by us, require us to correct or delete such Personal
Information, request that we delete their Child’s account, and/or refuse to
permit us from further collecting or using their Child’s Personal Information by
contacting us using the email or mailing address provided above. To protect
parents and legal guardians’ privacy and security and the privacy and security
of Child Users, we may require a parent or legal guardian to take certain steps
or provide additional information, which we will keep strictly confidential, to
verify their identity before we provide any information about the Child or take
the requested actions.
SuperAwesome
Our Game is provided and operated by us. However, some functionalities of our
Game, including the parent portal and contact with parents for purposes of
obtaining verified parental consent and informing parents of their Child User’s
online activities, are operated by Kids Web Services (“KWS”), a product of
SuperAwesome Trading Limited of 2-4 Packhorse Road, Gerrards Cross,
Buckinghamshire, SL9 7QE, England, United Kingdom. You may contact SuperAwesome
directly at privacy@superawesome.com for any questions related to their use of
Personal Information. SuperAwesome’s privacy policy for KWS can be found here.
SuperAwesome’s KWS is designed specifically to power kid-friendly registrations
and digital experiences, as well as parental management tools, across the web
and mobile ecosystem in compliance with the COPPA and Regulation (EU) 2016/679
of the European Parliament and of the Council of 27 April 2016 (General Data
Protection Regulation). KWS is certified as COPPA-compliant by the kidSAFE Seal
Program, an FTC-Approved COPPA Safe Harbor Program. The kidSAFE Seal Program is
an independent safety certification service and seal-of-approval program
designed exclusively for children-friendly websites and technologies, including
child-targeted game sites, educational services, virtual worlds, social
networks, mobile apps, connected products, and other similar interactive
services and technologies. Click on the seal or go to www.kidsafeseal.com for
more information. To learn more about COPPA, you may also consult this simple
one-page informational guide from the kidSAFE Seal Program:
www.kidsafeseal.com/knowaboutcoppa.html.
SuperAwesome is also a valid licensee, and participating member, of the
Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy
Certified”). To protect your privacy, SuperAwesome has voluntarily undertaken
this privacy initiative, and its services have been reviewed by ESRB Privacy
Certified to meet established online information collection, use, and disclosure
practices. As a licensee of this privacy program, SuperAwesome’s services are
subject to audits and other enforcement and accountability mechanisms
administered independently by ESRB Privacy Certified.
3. What categories of Personal Information do we collect?
We may collect different types of information from you depending on how you use
our Services, including Personal Information. “Personal Information” means
information that relates to an identified or identifiable natural person. The
categories of Personal Information we may collect are listed below. Certain
types of Personal Information may fall under more than one category.
CategoryPersonal InformationPurposes (see Section 6 below for additional
purposes)IdentifiersFirst and last name– To fulfill merchandise purchases on our
Website
– To respond to your or a parent or legal guardian’s inquiriesPostal address– To
fulfill merchandise purchases on our WebsiteUsername– To create an account for
our Game
– To play our Game
– To link your Game account with another game platform account
– To monitor and respond to inappropriate or reported conduct in-Game
– To improve our Game
– To display your friends list in-Game
– To send invites to your friends to play our GameUnique or online ID (such as
an account ID, support ticket ID, or third party ID)– To respond to your
inquiries
– For parent or legal guardian verification
– To identify your permissions as a Child User
– To link your Game account with another game platform account
– To link your Game account to your other IDs
– To send invites to your friends to play our GameInternet Protocol address– To
create an account for our Game
– To play our Game
– For key purchases
– To verify whether you are a Child User
– To respond to your inquiries
– To monitor and respond to inappropriate or reported conduct in-Game
– To respond to law enforcement requests
– To link your Game account with your Apple account
– To improve our Game
– To provide Game analyticsDevice IDs and device information– To provide an
account for our Game
– To provide Game analytics
– To respond to your inquiries
– To improve our GameEmail address– To create an account for our Game
– To fulfill merchandise purchases on our Website
– To market our Services when you sign up on our Website
– To respond to your inquiries
– For key purchases
– To support Itch Corp. users
– To allow a parent or legal guardian to manage privacy settings for their Child
UserProtected classification characteristics under California or federal lawDate
of birth– To verify whether you are a Child UserCommercial informationPayment
information– To fulfill merchandise purchases on our Website
– For key purchasesPurchase history– To fulfill merchandise purchases on our
Website
– To fulfill in-Game purchases across game platforms
– To respond to your inquiries
– To improve our Game
– To provide Game analyticsInternet or other similar network activityInteraction
with our Website– To improve our WebsiteGameplay information– To improve our
Game
– To play our Game
– To monitor inappropriate conduct in-GameGeolocation dataNon-precise
geolocation– For key purchases
– To provide Game analyticsZip code– To fulfill in-Game purchases
– To respond to your inquiriesCity– To fulfill in-Game purchases
– To respond to your inquiriesState or country– To fulfill in-Game purchases
– To respond to your inquiries
– To improve our Game
– To verify whether you are a Child UserPersonal Information categories listed
in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))First
and last name– To fulfill merchandise purchases on our Website
– To respond to your or a parent or legal guardian’s inquiriesPostal address– To
fulfill merchandise purchases on our WebsiteTelephone number– To fulfill
merchandise purchases on our WebsitePayment information– To fulfill merchandise
purchases on our Website
– For key purchasesOtherInformation from the content that you share publicly in
our Game through public functions or on our social media accounts (such as
Discord, Twitch, TikTok, Twitter, Facebook, and Instagram)– To play our Game
– To monitor inappropriate conduct in-Game
– To respond to your inquiries
– For community outreachInformation from the content that you send to us
directly when you contact us or report a problem with our Services (including if
you report a problem with another user)– To respond to your inquiries
– To troubleshoot a problem with our Services
We do not knowingly or intentionally process any sensitive Personal Information.
We may also collect information that does not generally identify you but may
become associated with your account. We may use information that does not
identify you for any permissible business or operational purpose under
applicable law.
4. From what sources do we collect Personal Information?
Directly From You
We may collect your Personal Information when you provide it to us directly,
including the examples below.
* When you open our Game, we may collect your date of birth.
* When you create an account for our Game, we may collect your username and
email address.
* When you use the public functions in our Game or on our social media accounts
(such as Discord, TikTok, Twitch, Twitter, Facebook, and Instagram), we may
collect the information you choose to disclose.
* When you sign up for our newsletter, we may collect your email address.
* When you contact us or report a problem with our Services, we may collect
your email address, first and last name, and records and copies of your
correspondence.
* When you respond to a survey or questionnaire, we may collect the information
you provide.
Automatically From You
We may collect your Personal Information automatically as you use our Services.
For example, we may collect your Personal Information as you interact with our
Website or as you play our Game. For more information about our and third
parties’ use of cookies and other automatic data collection technologies, and
certain choices we offer to you with respect to them, please see Section 5
below.
From Third Parties
We may receive your Personal Information from or through third parties that help
us provide or facilitate your access to our Services, including those listed
below.
* E-commerce and merchandising service providers such as Shopify Inc.: For
example, when you purchase merchandise from our merchandise Website, we may
receive your first and last name, postal address, email address, phone
number, purchase history, and payment information.
* Player support service providers such as Zendesk, Inc.: For example, when you
contact us or report a problem with our Services, we may collect your email
address, support ticket ID, and records and copies of your correspondence.
* Digital content stores and game platforms such as those operated by Itch
Corp., Epic Games, Inc., Google LLC, Microsoft Corp., Apple Inc., Valve
Corp., Sony Interactive Entertainment LLC, and Nintendo of America Inc.:
Examples below.
* When you link your account, we may receive your username from Epic Games,
Google, Microsoft, Apple, Valve, Sony, or Nintendo, and your platform ID
from Itch, Epic Games, Google, Microsoft, Apple, Valve, Sony, or Nintendo.
In addition, we may receive your Internet Protocol address from Apple and
your email address from Itch.
* If you purchase in-Game content or features after linking your account, we
may receive your purchase history from Itch, Epic Games, Google, Microsoft,
Apple, Valve, Sony, or Nintendo. In addition, we may receive your zip code,
city, and state or country from Google.
* When you send invites to your friends to play our Game, we may receive your
platform ID from Itch, Epic Games, Google, Microsoft, Apple, Valve, Sony,
or Nintendo.
* If you leave a review about our Game in the Microsoft Store, we may receive
your device type, username, and country.
* When you contact Google regarding a problem with our Game, we may receive
your purchase history, zip code, state or country, and city.
* To display your friends list or accept an invite from a friend to play our
Game, we may receive the usernames of your friends from Epic Games, Google,
Microsoft, Apple, Valve, Sony, or Nintendo.
* Payment service partners such as Xsolla (USA), Inc.: For example, when you
purchase a key through https://buy.among.us/, we may receive your email
address, non-precise geolocation, and payment information.
* Backend service providers such as Epic Games, Inc.: For example, when you
create an account, we may receive your online and device IDs from Epic Games.
* Analytic service providers such as Unity Technologies: For example, when you
install our Game, we may receive an online ID from Unity, excepting Child
Users.
* Diagnostic service providers such as Functional Software, Inc. d/b/a Sentry:
For example, when you install our Game, we may receive an online ID from
Sentry, excepting Child Users.
* Parental and legal guardian consent management providers such as SuperAwesome
Trading Limited: For example, if you are a Child User, we may receive your
platform ID and date of birth from SuperAwesome.
* Other users of our Game: If a user reports to us that you are violating our
Terms of Use by using offensive language in the public functions of our Game
or are attempting to hack our Game, for example, we may collect the
information provided by that user about you and create a report of your
actions. If you are a parent or legal guardian of a Child User, we may
receive your email address from your Child User.
We abide by this Policy when we use Personal Information provided to us by third
parties. However, we may not control the Personal Information that third parties
collect or how they use that Personal Information. You should review the third
parties’ privacy policies for more information about how they collect, use, and
share the Personal Information they obtain and use.
5. How do we and third parties use cookies and other automatic data collection
technologies?
Cookies are small data file identifiers that are transferred to your computer or
mobile web browser that allow us and third parties to recognize your browser or
mobile device and transfer information about you and your use of our Services.
Our Cookies and Other Automatic Data Collection Technologies
We may use cookies and other automatic data collection technologies on our
Services to collect Personal Information, including the examples below.
* When you visit our Website, we may collect information regarding your
interaction with our Website, including pages viewed.
* When you create an account for our Game or play our Game, we may
automatically collect your Internet Protocol address.
* When you contact us or report a problem with our Services, we may collect
your Internet Protocol address and device information.
* When you are reported by another user in-Game, we may automatically collect
your chat logs and past sanctions.
Third Party Cookies and Other Automatic Data Collection Technologies
Cookies and other automatic data collection technologies on our Services may
come from third parties as listed below. These cookies and other automatic data
collection technologies improve your experience by helping us better tailor our
Services to you.
* Shopify Inc.: We may use Shopify, an e-commerce service offered by Shopify
Inc., a Canadian corporation, with offices located at 151 O’Connor Street,
Ground floor, Ottawa, Ontario, K2P 2L8. Shopify may use automatic data
collection technologies to collect your Personal Information on our behalf to
help us improve our merchandise Website (such as your interaction with our
merchandise Website and Internet Protocol address). For more information
about Shopify’s privacy practices, you can review its Cookies Policy.
* Unity Technologies: Excepting Child Users, we may use Unity Analytics, an
analytics service offered by Unity Technologies SF, 30 3rd Street, San
Francisco, CA 94103, and Unity Technologies Finland OY, Kaivokatu 8 B, 00100
Helsinki, Finland. Unity may use automatic data collection technologies to
collect Personal Information directly from your device and use this Personal
Information to help us analyze your use of our Game. You should review
Unity’s Cookies Policy, which includes instructions on how to restrict the
collection of your Personal Information (such as your purchase history,
Internet Protocol address, non-precise geolocation data, and certain gameplay
information).
* Functional Software, Inc. d/b/a Sentry: Excepting Child Users, we may use
Sentry, a diagnostics service offered by Functional Software, Inc. d/b/a
Sentry. Sentry may use automatic data collection technologies to collect your
Personal Information on our behalf to help us improve our Game (such as your
Internet Protocol address, device information, purchase history, and game
play information). For more information about Sentry’s privacy practices, you
can review its Privacy Policy.
* Xsolla (USA), Inc.: We may use Xsolla, a payment service offered by Xsolla
(USA), Inc. Xsolla may use cookies to collect your Personal Information on
our behalf to help us with key purchases for our Game (such as your Internet
Protocol address). For more information about Xsolla’s privacy practices, you
can review its Cookies Policy.
Choices about Cookies
You may set your browser to refuse all or some browser cookies or to alert you
when cookies are being sent. Please note that, if you disable or refuse cookies
or other automatic data collection technologies, some aspects of our Services
may be inaccessible or not function properly.
6. For what purposes do we collect your Personal Information?
In addition to the purposes described above, we may collect your Personal
Information for the below purposes.
* To provide or improve our Services: We may use your Personal Information to
process your requests to access our Services and certain of their features
and to generally present and improve our Services. For example, we may use
your Personal Information to improve our Game.
* To administer our Services: We may use your Personal Information for any
lawful business or operational purpose in connection with administering our
Services. For example, if you reach out to us, we may use your Personal
Information to respond to you or to troubleshoot a problem you reported
having with our Services.
* To market our Services: We may use your Personal Information to market our
Services to you. For example, with your prior consent, we may send you news
and updates about our products and our Services.
* In furtherance of legal and safety objectives: We may access, use, and share
with others your Personal Information for purposes of safety and other
matters in the public interest. We may also provide access to your Personal
Information to cooperate with official investigations or legal proceedings
(e.g., in response to subpoenas, search warrants, court orders, or other
legal processes). We may also provide access to your Personal Information to
protect our rights and property and those of our agents, users, and others,
including to enforce our agreements, policies, and our Terms of Use. For
example, we may use your Personal Information to respond to inappropriate or
reported conduct in-Game and to enforce user bans for our Game.
* In connection with a sale or other transfer of our business: In the event all
or some of our assets are sold, assigned, or transferred to or acquired by
another company due to a sale, merger, divestiture, restructuring,
reorganization, dissolution, financing, bankruptcy, or otherwise, your
Personal Information may be among the transferred assets.
* As we may describe to you when collecting your Personal Information: There
may be other situations when we collect your Personal Information and
simultaneously describe the purpose for that collection.
Lawful Basis
We only collect, use, or store your Personal Information for a lawful basis such
as:
* you voluntarily provide it to us with your specific, informed, and
unambiguous consent (for example, when you sign up for our newsletter);
* it is necessary to provide you with a Service that you have requested (for
example, providing you access to our Game);
* we have a legitimate business interest that is not outweighed by your privacy
rights (for example, to respond to your inquiries); or
* it is necessary to protect your vital interests or the vital interests of
others (for example, where necessary to protect the safety of one of our
users or someone else).
7. In what situations do we disclose your Personal Information?
We may disclose your Personal Information to a third party, such as a service
provider or contractor for a business or operational purpose, or with your
consent. When we disclose Personal Information for a business or operational
purpose, we enter into a contract with the service provider or contractor that
describes the purpose and requires the service provider or contractor to both
keep that Personal Information confidential and not use it for any purpose
except performing the contract. These service providers and contractors include
our:
* backend service providers such as Epic Games, Inc.;
* e-commerce and merchandising service providers such as Shopify Inc., Dual
Wield Studio LLC, and Penny Arcade, Inc.;
* parental and legal guardian consent management providers such as SuperAwesome
Trading Limited; and
* player support and moderation service providers such as Keywords Studios Plc
and ModSquad, Inc.
We may also disclose your Personal Information:
* to our subsidiaries and affiliates;
* to our lawyers, consultants, accountants, business advisors, and similar
third parties who owe us duties of confidentiality;
* to a buyer or other successor in the event of a sale, merger, divestiture,
restructuring, reorganization, dissolution, or other transfer of some or all
of our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which Personal Information retained by
us pertaining to the users of our Services is among the assets transferred;
* to comply with any court order, law, or legal process, such as responding to
a government or regulatory request;
* to enforce any contract we may have in effect with you;
* if we believe disclosure is necessary or appropriate to protect the rights,
property, or safety of us, our users, or others; and
* if you have consented to such a disclosure.
We do not sell, rent, or share your Personal Information for cross contextual
behavioral or targeted advertising, automated decision-making, or profiling
purposes.
8. How is my Personal Information protected?
Our Retention, Purpose Limitation, and Security Policies
We protect your Personal Information through a combination of collection,
security, and retention policies.
* Limited retention: We retain each category of Personal Information only for
as long as necessary to fulfill the purposes for which the Personal
Information was provided to us or, if longer, to comply with any legal
obligations, to resolve disputes, and to enforce contracts. For example, we
may retain Personal Information collected about you to prevent repeated
violations or suspected violations of our Terms of Use if your account has
been banned or your access to our Services has been disabled for any reason.
To determine the appropriate retention period for Personal Information, we
consider the amount, nature, and sensitivity of the Personal Information, the
potential risk of harm from unauthorized use or disclosure of the Personal
Information, the purposes for which we process the Personal Information and
whether we can achieve those purposes through other means, and the applicable
legal requirements. For example, subject to the foregoing considerations, it
is our policy to delete your Personal Information if we stop operating our
Game or the feature through which the Personal Information was acquired.
* Purpose limitation: We will use your Personal Information only for our
Services you choose to access and for the purposes notified to you, unless we
otherwise obtain your consent. We limit the collection of Personal
Information to what is adequate, relevant, and reasonably necessary for those
purposes.
* Security measures: We use reasonable security measures to ensure a level of
security appropriate to the volume and nature of Personal Information
processed and risk involved, considering the size, scope, and type of our
business, and have implemented contractual, technical, administrative, and
physical security measures designed to protect your Personal Information from
unauthorized access, disclosure, use, and modification, including
industry-standard encryption for the transmitting of Personal Information
(e.g., DTLS, TLS 1.2+, HTTPS) and industry-standard hashing techniques for
the retention of Personal Information (e.g., SHA256+Salt). As part of our
privacy compliance processes, we review these security procedures on an
ongoing basis to consider new technology and methods as necessary. However,
please understand that our implementation of security measures as described
in this Policy does not guarantee the security of your Personal Information.
In the event of a security breach, we will notify the proper regulatory
authorities and any affected users of the breach within 72 hours after we
become aware of the breach to the extent required by applicable law.
Your Practices and Activities
Your practices and activities are likewise very important for the protection of
your Personal Information. You should take certain steps to help protect your
Personal Information, such as being mindful of what you share publicly in our
Game, including the below.
* Do not use your real name when selecting a username.
* Do not share your real name or anything private about yourself or anyone else
with other users of our Game.
* Do not pick a password that is easy to guess, and do not share your
password.
Please remember that we have no control over what other users do with the
content of your communications and no responsibility or obligation regarding
other users.
9. How do we treat Personal Information transferred to the United States?
Place of Business
We may store or process your Personal Information outside of the country where
we collect the information or the country in which you reside. Our primary place
of business is in the United States. You should understand that we may transfer
some or all of your Personal Information to the United States to carry out
certain operational and processing needs as described in this Policy.
Transfer Mechanisms
When transferring Personal Information out of foreign countries, we implement
technical, organizational, and physical safeguards to protect your Personal
Information. We use European Commission approved standard contractual clauses
and implement related measures where required by applicable law. Please contact
us if you have questions related to the relevant transfer mechanism for your
Personal Information.
10. What rights do you have to your Personal Information?
Right to Access, Correct, Delete, or Restrict Processing
Subject to any limitations and exceptions under applicable law, you have the
right to request access to your Personal Information and exercise the below
rights.
* You have the right to correct or update certain types of Personal
Information. In many cases, you can review or update your account information
by accessing your account online.
* You have the right to request deletion of your Personal Information. If you
choose to have your Personal Information removed from our Services, we will
carry out your request within 30 days of account verification, subject to
extension, and we will only retain minimal Personal Information to document
your request and the actions we took to carry out your request.
* You have the right to restrict certain processing of your Personal
Information and the right to object to some types of processing of your
Personal Information.
* You have the right to withdraw your consent at any time.
* You have the right to lodge a complaint regarding our collection, storage, or
processing of your Personal Information with a data protection supervisory
authority in the country where you live or work.
We will comply with your requests in accordance with, and subject to, applicable
law. For example, we are not required to delete your Personal Information if we
have an overriding legitimate ground for retaining that information, such as to
prevent fraud. Please note that we are legally prohibited from carrying out
requested actions in some instances, including (1) when we are unable to confirm
your identity or (2) where doing so would adversely affect the rights or
freedoms of others. Further, we are not required to carry out a requested action
in some instances, including where the request is considered excessive.
We are Here to Help
Please email us at privacy@innersloth.com with the subject line “Privacy
Request” or mail your request to Innersloth LLC, PO Box 2532, Redmond, WA 98073,
USA if you would like to exercise any of the rights described above or if you
have questions regarding your rights.
11. Additional Notice for California, Colorado, Connecticut, Utah, and Virginia
Residents
California Online Privacy Protection Act
The following applies to California residents:
* We do not track users of our Services over time and across third party
websites or online services and therefore do not respond to Do Not Track
signals. We are not aware of any third party that tracks users of our
Services over time and across third party websites or online services. Please
note that Do Not Track is a different privacy mechanism than the Global
Privacy Control, a legally recognized browser-based control that indicates
whether you would like to opt out of the processing of your Personal
Information for certain purposes.
California Shine the Light Law
The following applies to California residents:
* California residents may request information from us concerning any
disclosures of Personal Information we may have made in the prior calendar
year to third parties for direct marketing purposes. If you are a California
resident and you wish to request information about our compliance with this
law or our privacy practices, please email us at privacy@innersloth.com with
the subject line “California Shine the Light Law” or mail your request to
Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.
State Privacy Laws
The following applies to California, Colorado, Connecticut, Utah, and Virginia
residents (in the event of a conflict between this Section 11 and any other
section in this Policy, this Section 11 controls):
* Right to Know and Access: You have the right to request that we disclose
certain information to you about our collection and use of your Personal
Information. Once we receive and confirm your verifiable consumer request, we
will disclose to you the following, to the extent retained by us:
* the categories of Personal Information we collected about you;
* the categories of sources for the Personal Information we collected about
you;
* our business or commercial purpose for collecting, selling, or sharing that
Personal Information;
* the categories of third parties with whom we disclose that Personal
Information;
* the specific pieces of Personal Information we collected about you (also
known as a data portability request); and
* if we sold or shared your Personal Information, two separate lists
disclosing (1) sales, identifying the Personal Information categories that
each category of recipient purchased, and (2) disclosures for a business or
operational purpose, identifying the Personal Information categories that
each category of recipient obtained.
* Right to Deletion: You have the right to request that we delete any of your
Personal Information that we collected from you and retained, subject to
certain exceptions. Once we receive and confirm your verifiable consumer
request, we will delete (and direct our service providers and contractors to
delete) your Personal Information from our records, unless an exception under
applicable law applies. We may deny your deletion request if retaining the
information is necessary for us or our service providers or contractors to:
* complete the transaction for which we collected the Personal Information,
fulfill the terms of a written warranty or product recall conducted in
accordance with federal law, provide our Services that you requested, take
actions reasonably anticipated within the context of our ongoing business
relationship with you, or otherwise perform our contract with you;
* help to ensure the security and integrity of our Services to the extent the
use of your Personal Information is reasonably necessary and proportionate
to those purposes;
* debug our Services to identify and repair errors that impair existing
intended functionality;
* exercise free speech, ensure the right of another user to exercise their
free speech rights, or exercise another right provided for by law;
* comply with the California Electronic Communications Privacy Act;
* engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics
and privacy laws, when the Personal Information’s deletion may likely
render impossible or seriously impair the research’s achievement, if you
previously provided consent;
* enable solely internal uses that are reasonably aligned with user
expectations based on your relationship with us and compatible with the
context in which you provided the Personal Information; or
* comply with a legal obligation.
* Right to Correction: You have the right to request that we correct inaccurate
Personal Information. Once we receive and confirm your verifiable consumer
request, we will use commercially reasonable efforts to correct the
inaccurate Personal Information, taking into account to the nature of the
Personal Information and the purposes of the processing of the Personal
Information.
No Discrimination
We will not discriminate against you for exercising any of your privacy rights
under applicable law. Unless permitted by applicable law, we will not:
* deny you our Services;
* charge you different prices or rates for our Services, including through
granting discounts or other benefits, or imposing penalties;
* provide you a different level or quality of our Services; or
* suggest that you may receive a different price or rate for our Services or a
different level or quality of our Services.
Verifiable Consumer Requests
To exercise your rights described above, please email us at
privacy@innersloth.com with the subject line “State Privacy Rights” or mail your
request to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA. Only you, or
someone legally authorized to act on your behalf, may make a verifiable consumer
request related to your Personal Information. The verifiable consumer request
must:
* provide sufficient information that allows us to reasonably verify you are
the person about whom we collected Personal Information or an authorized
representative; and
* describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we
cannot verify your identity or authority to make the request and confirm that
the Personal Information relates to you. We will only use Personal Information
provided in a verifiable consumer request to verify your identity or authority
to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its
receipt. If we require more time, we will inform you of the reason and extension
period in writing. If you have an account with us, we will deliver our written
response to that account. If you do not have an account with us, we will deliver
our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the
receipt of verifiable consumer request, unless you request a longer period of
time for Personal Information we collected about you after January 1, 2022. The
response we provide will also explain the reasons we cannot comply with a
request, if applicable.
To appeal a decision regarding your verifiable consumer request, please submit
your appeal using one of the two methods above. Your appeal should include an
explanation of the reason you disagree with our decision. Within 60 days of
receipt of an appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions.
For data portability requests, we will select a format to provide your Personal
Information that is readily useable, easy-to-understand, and should allow you to
transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
12. How will we notify you of changes to this Policy?
We reserve the right to change this Policy from time to time consistent with
applicable law. If we make changes to this Policy, we will notify you by
revising the date at the top of this Policy and provide you with additional
notice such as an in-Game notice or email notification.
In the event that any changes we make to this Policy affect Child Users in a way
that requires prior parental consent under COPPA, we will obtain such prior
parental consent.
13. How can you contact us?
If you have questions, you may email us at privacy@innersloth.com or mail your
questions to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.
If you are a law enforcement agency, please email us at privacy@innersloth.com
with your request for Personal Information with the subject line “Law
Enforcement Request” or mail your request to Innersloth LLC, PO Box 2532,
Redmond, WA 98073, USA.
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