LIMBIC SOFTWARE, INC. PRIVACY POLICY NOTICE

Effective Date: February 4, 2014
(Last Updated February 4, 2014)

We respect the privacy rights of its customers and protect the personal information collected, stored and used in connection with our products, services and websites. Your privacy is important to us. To further this commitment, we have adopted this Privacy Policy to guide you on how we collect, store, and use the information you may provide to us.Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

Table of Contents

  1. Protecting Your Privacy
  2. What Personal Information Do We Collect?
  3. How Do We Use Your Information?
  4. Who Do We Share Your Information With?
  5. Is My Information Secure?
  6. Does My Information Go Across Borders?
  7. Is Sensitive Information Collected?
  8. What Choices Do I Have Regarding The Collection, Use, and Distribution Of My Personal Information?
  9. What Happens When I Remove A Game or Unsubscribe From A Newsletter?
  10. Children’s Privacy
  11. California Residents: Your California Privacy Rights
  12. Changes to the Policy
  13. Contacting Us

1. Protecting Your Privacy

Limbic Software, Inc. (“Limbic”) provides interactive software products (“Games”) via online services such as Apple iTunes App Store, Google Play Store, Facebook, Steam, Bandcamp, Zazzle, Amazon Appstore for Android, Samsung Appstore, PlayStation Network, Xbox Live Arcade and OnLive. We own and operate various websites and their subdomains including but not limited to www.limbic.com, and www.towermadness.com, (our “Sites”) to provide access to information about Limbic, the Games and Products, message boards, head to head match play or provide technical support to Limbic customers (collectively, our “Content”).

We are committed to protecting the privacy of all people who interface with our products and our website. Your privacy is important to us. We comply with COPPA, the United States Children’s Online Privacy Protection Act, and CAN-SPAM, which covers the transmission of commercial email messages with the primary purpose of advertising or promoting a product, as well as the laws of the State of California, including the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579). For European residents, we seek to follow the E.U. Data Protection Directive (95/46/EC).

By registering or accessing this website and/or any of our Games, you agree that we may collect, use and process your data in accordance with the following this Privacy Policy Notice and that you will abide by our Terms of Use (located at: www.limbic.com/terms-of-use). BY ACCESSING THIS WEBSITE AND/OR USING ANY GAMES, YOU AGREE THAT YOU HAVE READ AND UNDERSTAND AND ACCEPT THE TERMS OF THIS PRIVACY POLICY AND YOU AGREE AND UNDERSTAND THAT YOU ARE BOUND BY ALL TERMS, POLICIES AND GUIDELINES INCORPORATED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE AND/OR ANY GAME.

2. What Personal Information Do We Collect?

Personal information is information that identifies you and that may be used to contact you online or offline. We collect personal information from you on a voluntary basis as described below. Our primary goals in collecting and using information is to create your account, provide Services to you, improve our Services, contact you, conduct research and create reports for internal use and for use with our partners.

Our Sites

While you are browsing our Sites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may use this information to monitor and analyze your use of the Services. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age or birthday, links to your profiles on social networking websites and other third party sites, user names and e-mail and mail addresses. We may use this information to create a user profile. We may use your email address to contact you about your experience with our Sites and notify you about company news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions. Your mail address may be used if we have merchandise or other physical promotional materials that we want to send to you.

Forums

We may at times offer you the ability to post content to a blog, message board, chat room or within our applications or other forums such as our Facebook page (“Forums"). You should be aware that any visitor to the Forums may read your postings on the Forums. Furthermore, any information that you may post to a Forum, including your username or other account profile information, will be disclosed and available to all users and viewers of that Forum, and will therefore no longer be private. We cannot guarantee the security of such information that is disclosed or communicated online in public areas such as the Forums, and you provide such information at your own risk. We do not author, edit, endorse, or monitor any Forum. You acknowledge and agree that we have no responsibility for the accuracy or availability of information provided on any Forum. We reserve the right at any time, in our sole discretion, to remove any content that a user may post on any Forum and restrict user access to any Forum.

iOS and Android Platforms

When you use any of our Games or applications on a mobile platform, we may collect and record certain information such as your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address (if you have connected to Facebook or Google+), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends. In addition, we create a unique user ID to track your use of our Services. This unique user ID is stored in connection with your profile information to track the Games you are playing.

Facebook Connect, Game Center and Google+

You may connect your Limbic user account to your accounts on the following social networking services “SNS”): Facebook, Google+ and Apple’s Game Center. We may collect and record information through an SNS in accordance with the policies and terms of that SNS. The information we collect when you connect your user account to an SNS may include: (1) your name, (2) your SNS user identification number and/or user name, (3) profile picture or its URL, and (4) the SNS user identification numbers for your friends that are also connected to our Games.

During the process of playing our Games through social networking sites you may choose to share personal information about yourself through the Game. Please be careful to use discretion, as personal information shared with other players is visible to the public and will not be kept private. Based on the related terms of use on your social networking site account, actions that are designated visible for “everyone” may be collected by us. When friends invite you to play one of our social networking site Games, or vice versa, we may collect the email addresses, content and other data from those messages in order to send invitation reminders.

If you want us to delete the data we receive from Facebook, Game Center or Google+ about you, please contact us at privacyofficer@limbic.com

Invite a Friend

Limbic may offer you the opportunity to invite your contacts from an SNS (such as your Facebook friends) so that those contacts can be located in our Games and/or you can invite them to join you in playing our Games. Such contact information will be used only for the purpose of sending communications to the addressee. You or the third party may contact us at privacyofficer@limbic.com to request the removal of this information from our database to the extent we store any of this information.

Customer Service

We may collect your name, email addresses, postal addresses, and/or telephone calls with names and numbers to return calls when you contact our customer service group and we may use that information to contact you about your gaming experience with our Games and notify you about company news and promotions.

Game Data Collection

Whenever you play our Games, we collect data about all of your interactions with the Game and with the other players inside the Game via server log files. We use this information to help improve your game experience and monitor the performance of the game.

Other Collection

We may also acquire information from you through your access and participation in message boards on the Service, your participation in surveys regarding the Service or your participation in a sweepstakes or contest through the Service.

Cookies and Web Beacons

A cookie is a small text file that we transfer to your computer and/or device, to identify a user's computer/device and to "remember" things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our Service, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, although by doing so, you may not be able to access or use all of the features of the Service.

We may feature advertisements served by third parties that deliver cookies to your computer/device so the Content you access and advertisements you see can be tracked. Since the third party advertising companies associate your computer/device with a number, they will be able to recognize your computer/device each time they send you an advertisement. These advertisers may use information about your visits to our Service and third party sites and applications in order to measure advertisement performance and to provide advertisements about goods and services of interest to you. This Policy does not apply to, and we are not responsible for the data collection practices of these third party advertisers, and we encourage you to check their privacy policies to learn more about their use of cookies and other technology.

You may click on the following link: http://www.networkadvertising.org (or such other URL as may be specified by us from time to time) for information on how to opt-out of the use of cookies for the delivery of more relevant advertising.

We (or our partners) may also collect information using Web beacons. Web beacons or "gifs", are electronic images that may be used on our Site, in our Games, or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.

Please note that this Privacy Policy covers the use of cookies and web beacons by us only and does not cover the use of cookies and web beacons by any advertisers who may link to our website or Games.

Third Party Services and Third Party Sites

Our services may contain third party tracking tools from our service providers, examples of which include tracking tools from Google Analytics, and [any others?]. Such third parties may use cookies and other software tools in our services to enable them to collect and analyze user information on our behalf. These third parties may have access to information such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, and IP address.

You can opt-out of Google Analytics with this browser add-on tool: https://tools.google.com/dlpage/gaoptout

We encourage you to review the privacy policies of any other service provider from whom you request services. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement, authorization or representation of affiliation by any such third party with us. If you click on a link to a third party site, including on an advertisement, you will leave our website or the Game you are playing and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices to which we adhere. We encourage you to review the privacy policies of any other service provider from whom you request services, because by visiting a third party website that is linked to the Sites or Game, you will be governed by such party’s terms of use and privacy policy and should consult that site’s terms of use and privacy policy before providing any personal information.

Ad Networks

We may feature advertising within our Service. The advertisers may collect and use information about you, such as your Service session activity, device identifier, MAC address, IMEI, geo-location information and IP address. They may use this information to provide advertisements of interest to you. You can opt-out of personalized ads/recommendations from iAds by clicking here.

In addition, you may see our Games advertised in other services. After clicking on one of these advertisements and installing our Game, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser.

3. How Do We Use Your Information?

We use information collected through our Sites for purposes described in this policy or disclosed to you in connected with our Sites. For example, we may use your information to:

4. Who Do We Share Your Information With?

We do not share your personal information except as approved by you or as described below. We do not sell or rent your personally identifiable information to any third party, although non-personally identifiable information may be used to assist advertisers in targeting their services to specific user demographics. For example, we may provide third party advertisers with the aggregate number of males of a certain age in a specific country who are playing one of our Games.

5. Is My Information Secure?

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

6. Does My Information Go Across Borders?

We use third party servers in the United States to host some or all of our Games and we use our own servers at our facilities in California to store information and archives. These third party servers may be located in diverse geographic areas located outside of the United States and outside your country of purchase and such countries may have different data protection laws and/or privacy laws than the laws identified at the top of this Privacy Policy. By downloading or using our Games, you consent to having your General Information and non-personally identifiable user activity data transferred and processed as described herein.

7. Is Sensitive Information Collected?

We do not ask you to provide any “sensitive information” as a requirement to use our website or any of our Games. “Sensitive Information” means any personal information related to health, race, ethnicity, political views, religion, professional status, philosophical view, and trade or union affiliation. Sensitive Information that you disclose to “everyone” on a discussion forum or through a social networking site in connection with a Game may be collected and held by us in accordance with this Privacy Policy Notice. We do not use or share Sensitive Information with third parties. Please contact us if you have any questions or concerns about any Sensitive Information that you may have disclosed to us or to other users during your use of a Game that we may have collected. We do collect non-personally identifiable information regarding Game usage including but not limited to the top country, city and language by aggregate usage as provided by the social networking sites.

8. What Choices Do I Have Regarding the Collection, Use, and Distribution of My Personal Information and How Can I Check What Personal Information is Held About Me?

You have the right to see what personally identifiable information we hold about you if you request it. If your request is particularly complex or requires detailed searching of our records, there may be a cost to you in order for us to provide you with this information.

Information We Receive From an SNS Where You Play Our Games

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

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

Other Methods of Accessing and Controlling your Information

If you no longer want us to make active use of your information, you may send an e-mail to privacyofficer@limbic.com. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and user ID number for the SNS from which you access our Games (if applicable) in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content on the Service, We may not be able to delete it.

9. What Happens When I Remove A Game or Unsubscribe From A Newsletter?

You have the ability to opt-out of: receiving information and marketing emails from us; publishing your recent Game activity to your SNS site page; bookmarking or displaying the Game page to others, and of course the ability to delete our Game and rescind any permissions required to operate such Game, at any time.

It is our responsibility to keep accurate, complete and up-to-date records, so any changes you make in the Game regarding your personally identifiable information will go into effect as quickly as technically possible. We reserve the right to retain the non-personally identifiable data collected during your use of the Game.

We also reserve the right to delete messages, content and accounts in whole or in part, at our discretion, that we find offensive to the general public, uses profanity, causes complaints from other users, is not suitable for a general audience or infringes the intellectual property rights of any third party. For example, talk of drugs, alcohol, violence, strong language, gambling, crude humor, sexual themes or is suggestive in nature is prohibited.

10. Children’s Privacy

We recognize the need to provide further privacy protections with respect topersonal information we may collect from children on our Sites and Games. Some of the features on our Sites and Games are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features.

When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

If you wish to review or change the information we have about your children, e-mail us at privacyofficer@limbic.com.

11. California Residents: Your California Privacy Rights

Under the laws of the State of California (US), California Residents who have an established business relationship with us may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email privacyofficer@limbic.com.

In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the web sites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning out collection and use of personally identifiable information will continue to operate as described in this policy.

12. Changes to the Policy

We reserve the right to change this Policy at any time. If we decide to change this Policy, we will post those changes on this page and update the date at the top of the page. The changes will be effective when posted. Please check this page on a regular basis so that you remain aware of what information we collect and how we use it.

13. Contacting Us

For enquiries regarding this Privacy Policy Notice and personal information, please contact:

By Email
privacyofficer@limbic.com
By Mail
Limbic Software, Inc.
Privacy Officer
615 Arastradero Road
Palo Alto, CA 94306
By Phone:
650 861 5374