Privacy Policy

Last Updated: July 21, 2015
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Our Privacy Commitment

Level-5 International America (“Level-5” or “we”) respects the privacy rights of its online visitors and recognizes the importance of protecting all information that our users may choose to share with us. To further this commitment, we have adopted this Online Privacy Policy (“Privacy Policy”) to guide how we collect, use, and disclose the information you provide us.

This Privacy Policy and the ESRB certification seals shown on our websites confirm that Level-5 is a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had all of our websites and mobile applications (collectively, “Services”) where this Privacy Policy is posted reviewed and certified by ESRB Privacy Certified to meet established online information collection and use practices. As a licensee of this privacy program, we are subject to frequent audits of our Services and other enforcement and accountability mechanisms administered independently by the ESRB.

By using and submitting personal information to any of our Services, you signify your consent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.

Table of Contents
Q1. What information does this Privacy Policy cover?

A1. This Privacy Policy applies only to information collected on the Services where this Privacy Policy is posted, and does not apply to any other information collected by Level-5 through any other means. This Privacy Policy does not apply to any of Level-5’s non-English Services. This Privacy Policy applies only to Services maintained by Level-5, and not to our international affiliates, or any websites or mobile applications maintained by other companies or organizations to which we link. We encourage you to review the privacy policies of all third-parties and exercise caution in connection with them.

This Privacy Policy applies to use and sharing of personal information collected on and after the date that this Privacy Policy is posted. The terms of this Privacy Policy are subject to all applicable laws.

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Q2. What types of personally identifiable information do we collect?

A2. Personal information is information that can be used to directly identify and contact you (e.g. first and last name, email address, phone number, etc.). We do not collect any personal information about you unless you choose to provide it to us, and do not require personal information to access our Services. However, if you prefer not to disclose personal information, you will not be able to access certain features of our Services.

Children
We do not knowingly collect personal information from users under the age of 13. We take children’s privacy seriously, and encourage parents to take an active role in protecting their children’s privacy and online experience at all times. If it is discovered that we unintentionally have collected information from a child user under the age of 13, we will delete the child’s information. If parents believe that we have collected their child’s personal information, they may contact us at privacy@level5ia.com to request the deletion of the information.

Personal Information You Provide to Us
All of the personal information we receive comes directly from our guests. Depending on the activity, the personal information we collect via our website includes:

  1. First name, sometimes accompanied by last name
  2. Email address
  3. Phone number
  4. Photo, if connecting with us via social media

For information regarding our mobile applications, please refer to the section of our Privacy Policy entitled How is information collected, used, and shared via mobile applications?”.

Social Media Interaction
You also can engage with our content on or through third-party social networking sites, such as Facebook and Twitter (or third-party social media plug-ins and applications). When you engage with our content on or through third-party social networking sites, plug-ins and applications, you allow us to have access to certain information from your social media profile (e.g., name, e-mail address, photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the ‘likes’ you make) to deliver the content or as part of the operation of the application. We also obtain non-personally identifiable information (e.g., content viewed, game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on) from your interaction with our content.

When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside our websites, and (3) contact you through the social networking sites or directly by sending you the latest news, special offerings, and rewards. By doing so, you consent to the use of this information in accordance with our privacy policy. When you provide personal information to us through our websites or on social networking sites, it may be publicly viewed by other members of these sites and we cannot prevent further use of the information by third parties.

Through some social networking sites’ privacy settings, you can control what data you share. For more information about how social networking sites handle your personal information, please refer to their privacy policies and terms of use.

Demographic Information You Provide to Us
We collect demographic information, such as region (city, state, and country), which is anonymous information that cannot be used alone to directly identify and contact you. If demographic information is collected at the same time as your personal information, we combine the demographic information with your personal information. Demographic information is not considered personal information unless it is linked to personal information about a specific user. If you choose not to provide certain demographic information, you may not be able to access certain features on our website.

Please note that we will only collect that information which is reasonably necessary to fulfill your request. Once we have responded to or resolved your inquiry, your information is deleted and automatically removed from our databases after a reasonable period of time.

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Q3. Are cookies and other tracking technologies used to collect information?

A3. Cookies are pieces of information that a website sends to your computer while you are viewing the website. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser’s (e.g. Internet Explorer or Firefox) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your web experience smoother, and some of our services may not function properly.

We use cookies and other tracking technologies that are useful in order to assess the performance of our websites, including as part of our analytic practices or otherwise to improve the content and services on our websites. When log files are generated for this purpose, your Internet Protocol (IP) address is collected. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. This information is not combined with your other personal information.

In order to gather statistical data about our website visitors, we use Google Analytics. If you wish to download the Google Analytics opt-out browser add-on, you may do so here: https://tools.google.com/dlpage/gaoptout.

Once you’ve clicked on a third party link and have left our Services, our Privacy Policy no longer applies. If you decide to provide any personal information to a third party website linked from our Services, the sharing of such information will be subject to the privacy policy of that company, not our Privacy Policy. Be cautious before providing personal information to any third party company.

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Q4. How is your personally identifiable information used and shared?

A4. We do not share, sell, or rent your personal information to third parties without your consent. We do not require personal information to access all of our Services. However, if you prefer not to disclose personal information, you will not be able to access certain features of our Services.

Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.

Information collected from those who voluntarily submit it to us is used to provide services like updates on special events, game news, and email announcements of interest to our users.

We will only retain personal information about you for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law and/or regulations.

Operational Uses
We also use your personal information for other purposes such as “Operational Uses”. For example, we will use your information to send you administrative communications either about your account with us or about features of our Services, including any future changes to this Privacy Policy.

We occasionally use other companies, agents or contractors to perform services necessary to our operations. For example, we have partnered with other companies to personalize our web pages and analyze customers’ interaction with our website. In the course of providing such services, these companies have contact with your personally identifying information. These entities have agreed to securely store and maintain the personal information received from us.

Aggregate Information
Finally, we take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, no restrictions apply under this Privacy Policy on our right to aggregate or de-personalize your personal information, and we will use and share in any way with third parties the resulting non-personally identifiable information.

Business Information
For practical reasons, we treat personal information submitted to us in a business capacity different from information we receive in a non-business capacity. Personal information submitted to us in a business capacity (e.g. resumes, event sponsorship, etc.) will be shared with third parties, depending on the nature of the inquiry. Although personal information collected in this capacity will be used solely for the purpose specified, such information is not subject to the terms of this Privacy Policy.

Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Services and Others
We do not sell or rent personal information to third parties. We share personal information with vendors who help us perform various internal functions necessary to operate our business. We disclose personal information (a) in the good faith belief that we are required to do so by law; (b) if doing so is reasonably necessary to comply with legal process; (c) to respond to any claims; (d) to enforce the terms and conditions of our Services; (e) to protect the rights, property, or personal safety of Level-5, its users, or the public; or (f) in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock. Any vendors or partners with whom we share personal information are permitted to obtain only the personal information they need to deliver the services requested. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

Purchase or Sale of Businesses
In the event of a merger, sale of assets, acquisition, dissolution, reorganization, bankruptcy, change of control or other similar event, your personally identifiable information will be transferred to our successor or assign, if permitted by and done in accordance with applicable law, or if we sell one or more of our businesses, your personally identifiable information will be transferred as a part of the sale. If we purchase a business, the personally identifiable information received with that business will be treated in accordance with this Privacy Policy, if it is practicable and permissible to do so.

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Q5. How is information collected, used, and shared via mobile applications?

A5. Please note that the “Liberation Maiden” (iOS) and “Layton Brothers Mystery Room” (Android, iOS) mobile titles have been discontinued; therefore, they will no longer be updated. However, they will remain available for users to download and install.

We only collect a user’s ID when our “Liberation Maiden” mobile application is purchased or when an in-app purchase is made through either of our mobile titles. When making a purchase, your credit card or other payment information is collected and processed by a third-party service provider (e.g. Google Play, Apple, PayPal) on our behalf. This information is only used for the purpose it was collected for – to process your purchase(s). Your payment information is not shared with us. To learn more about how your information may be used and shared, please review the previous section of this Privacy Policy, “How is your personally identifiable information used and shared?”.

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Q6. Do California residents have special rights?

A6. Since 2005, California Civil Code Section 1798.83 permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. However, as previously stated, we do not share information with third parties, for their direct marketing purposes or otherwise, unless you affirmatively agree to such disclosure. For inquiries regarding our disclosure policy, please send us an email or write us:

Level-5 International America
Attn: Privacy Policy Administrator
2101 Rosecrans Ave., Suite 5284
El Segundo, CA 90245
privacy@level5ia.com

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Q7. How is information treated when it is collected from non-US residents?

A7. Personal information collected on our website(s) is stored and processed in the United States. By using our website(s) you consent to any such transfer of information outside of your country.

EU and Switzerland Residents
Level-5 complies with the U.S.-E.U. 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 personal information from European Union member countries and Switzerland. Level-5 has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. As of the date of this Privacy Policy, our application to the Safe Harbor program covers only that data collected on and through our websites; our mobile apps collect only user ID. To learn more about the Safe Harbor program, and to view Level-5’s certification, please visit http://www.export.gov/safeharbor/.

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Q8. What kinds of security measures do we take to safeguard your personally identifiable information?

A8. The security and confidentiality of your information is extremely important to us. We use robust security measures to protect user information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. We will notify users of a data breach involving unencrypted personal information by email or by posting a notice on the affected Service(s). We also strive to limit access to personal information to employees performing a legitimate business function. We review our security procedures regularly to consider appropriate new technology and updated methods. However, despite our efforts, no security measure is ever perfect or impenetrable.

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Q9. How can you review, update or delete your personal information?

A9. You can request to review, update or delete personal information you have provided to us by emailing us at privacy@level5ia.com.

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Q10. How can you ask questions or send us comments about this Privacy Policy?

A10. If you have questions or wish to send us comments about this Privacy Policy, please contact us at:

Level-5 International America
Attn: Privacy Policy Administrator
2101 Rosecrans Ave., Suite 5284
El Segundo, CA 90245
privacy@level5ia.com

As aforementioned, Level-5 is a licensee of the ESRB’s Privacy Certified Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at https://www.esrb.org/privacy/contact.jsp, or:

ESRB
Attn: Privacy Certified Program
420 Lexington Ave., Suite 2024
New York, NY 10170
privacy@esrb.org

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Q11. How will you know if we amend this Privacy Policy?

A11. We may amend this Privacy Policy at any time. If we make any material changes in the way we collect, use, or share your personal information, we will notify you by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the Services covered by this Privacy Policy. You can always verify the date that the Privacy Policy was last updated via the “Last Updated” date at the top of the Privacy Policy.

Please note that, at all times, you are responsible for updating your personal information to provide us your current email address. If the last email address you provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice.

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