Last Updated: 08 January, 2020
ZAM Network LLC, a company with principal offices at 12121 Wilshire Blvd. Suite 301 Los Angeles, CA 90025, USA, is the data controller for the purposes of data protection law. Our data protection officer can be contacted at firstname.lastname@example.org.
“Personal Information” means any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, address, email address, telephone number, an identification number, location data, online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that person.
What Information We Collect & How We Use It
We collect the following Personal Information:
Registration and Account Information
We collect this when you register to use the Services, so that we can fulfil our contract with you. You must register to use the Services. To register, you need to provide your name, email address and password. You can also provide other voluntarily disclosed optional information, such as address, phone number, language and gender.
Information from Using the Service
We collect information you provide through your use of the Services. For example, when you interact with other users by posting comments and messages, chatting with other users on the Services, posting videos and screenshots, participating in promotions, and otherwise submitting information to the Services, the Services will collect the information you provide in such submissions. Some Services will also collect your postal address, telephone number, and other Personal Information from you when you make purchases from us and when you respond to surveys, polls, contests, giveaways, and other promotional activities. We do this in order to provide you with the Services, and because it is in our legitimate interests to provide a well-functioning and user-friendly site.
Customer Support & Communications
We collect Personal Information through your communications with our customer-support team. We do this in order to provide you with the Services, and because it is in our legitimate interests to support you and respond to your communications. We will send email to the email address you provide to us and push notifications to your mobile device if they are enabled, to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, order purposes, notifying contest winners, and other Services-related purposes. This information is required to enable us to fulfil our contract with you and if you do not provide this information, we will not be able to communicate with you about the Services or provide you with all of our Services.
Social Media Information
We collect this when you log into the Services via social media sites, such as Facebook and Twitter. When you choose to connect your social media account to your profile on the Services, we collect Personal Information from that social media website. For example, when you connect your Facebook account, we collect certain Personal Information you have made publicly available in Facebook, such as your name, user ID, profile picture, and certain any other information you have made public. When you allow it, we also obtain other non-public information from these social media websites. We do this because it is in our legitimate interests to enable you to connect via your social media account and provide a well-functioning site that you can integrate into your online experience.
Partner Site Credentials
When you log in or authenticate your account on the Services using your credentials from other partner gaming websites and applications (such as Battle.net and Twitch), we collect Personal Information about you, including a unique user ID, information about your avatars or game characters, and other gaming information. We do not receive your name, email address, or your account log-in credentials from our partners. We do this because it is in our legitimate interests to enable you to connect via our gaming partners and to provide a well-functioning site that you can integrate into your online experience.
When you make payments through the Services, you will need to provide financial account information, such as your credit card number, to our third-party service providers. We do not collect or store Personal Information, though we receive summary information about transactions, but it does not include credit card or bank account numbers. We collect this information because it is necessary to fulfil our contract with you, if you elect to join a premium subscription.
The Services automatically collect information about your device, such as a device ID and the browser type you are using, so that we can provide functionality, such as push notifications, and improve the functioning of the Services. You can also permit the Services to access your device’s contact list and photo storage. We also collect Internet protocol (IP) address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, IDFA, AAID, click-through data, preferences and usage statistics to analyse how our Services are used, to optimize your ability to view and use the Services and to provide targeted advertising. When we associate such information with Personal Information, we will treat the combination as Personal Information. We use your technical information because it is in our legitimate interests to provide a well-functioning site that meets your technical requirements. We also use this technical information to serve targeted advertising to you.
In addition, we will use your Personal Information to do the following, as it is in our legitimate interests to run a successful business:
- to detect and prevent fraud and crime;
- for reporting and data analysis purposes;
- for insurance purposes;
- to comply with our legal and regulatory obligations;
- to monitor and assess the quality of our Service;
- to pass on feedback;
- to enforce our terms and conditions; and
- to provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).
We work with third parties to gather additional demographic information about our user population on an aggregate level. This information is not connected to individual users. This information helps us improve the Services and customize the content and advertising on the Services.
Cookies & Other Tracking Technologies
When you use the Services or receive emails from us, we and our third party partners, such as advertising networks, social media widgets, and analytics providers (see below for more details on these partners) use “cookies” and other similar technologies to collect information about how the Services or email is accessed. The types of cookies we use include:
Strictly necessary cookies
These are cookies that are required for the operation of our Services. They include, for example, cookies that enable users to log into secure areas of our Services.
Analytical / performance cookies
These allow us to recognize and count the number of visitors and to see how visitors move around our Services. This helps us to improve the way our Services work, for example, by ensuring that our users are finding what they are looking for easily.
We use Google Analytics to collect and process certain Services usage data. Google provides additional privacy options regarding cookie use described at www.google.com/policies/privacy/partners/. Google Analytics is a web analytics tool that helps us understand how users engage with our Services. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our Services. This information is used to compile reports and to help us improve our Services. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout
These are used to recognize users when users return to our Services. This enables us to personalize our content for you, greet users by name, remember a user’s preferences (for example, a user’s choice of language or region) and tailor our marketing outreach to our users based on their employment profile and engagement with our Services.
These cookies record a user’s visit to our Sites, the pages a user has visited and the links a user followed. We use this information to make the website more relevant to users. You are able to opt out of receiving personalized advertisements from advertisers or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out sections on the websites of each of those organizations. Links to those sites are on our advertising addendum and here: Network Advertising Initiative: http://www.networkadvertising.org/choices/ Digital Advertising Alliance: http://www.aboutads.info/choices/ European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
When you opt out of personalized advertising, you will continue to see online advertising on the Services and/or our ads on other Internet websites.
Our partners will also collect information about your online activities over time and on other websites or apps. When they provide such services, they are governed by their own privacy policies. You can change browser settings to block and delete cookies when you access the Services through a web browser. However, if you do that, the Services may not work properly.
How We Share Your Information
We share your Personal Information with third party vendors and service providers.
– data centers and cloud storage providers located in the U.S., that process your Personal Information to help us provide the Services; – payment providers located in the U.S., that help us facilitate payments for premium subscriptions; – ad networks, marketing providers and ad screening providers in the online advertising industry located in the EEA, Japan, Singapore and the US, that help us serve relevant ads to you and administer our advertising platform; – document management providers located in the U.S. and the geographical location of your account, to help us provide the Services; – social media providers located globally, to help us make the Services accessible; and – performance monitoring services located in the U.S., to help us improve the Service.
The Services are intended as public communities. Therefore, the information and content you provide to the Services will be displayed on them to other users. Other users of the Services will be able to see certain information about you, such as information in your posts and uploads. We are not responsible for the privacy practices of users who will view and use the posted information. Similarly, public posts, and any Personal Information in them, will be accessible via search engines or similar services.
Social networks or other partner websites
With your permission, the Services will allow you to share information, including Personal Information, with social networking websites, such as Facebook. We do not share your Personal Information with them unless you direct the Services to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.
We may share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: comply with legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).
We may also disclose your information to third parties: – in the event that we sell or buy any businesses or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets; or – if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
We implement and maintain reasonable administrative, technical and physical safeguards designed to protect the Personal Information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Services is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you can alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
International Data Transfers
We transfer your Personal Information from the EEA to the US using the following legal mechanisms: Contract: We are a US company with operation in the United States and as such we transfer your data to our data centres in those locations in order to provide you with our Service. Model Clauses: We also use the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decisions 2004/915/EC and 2010/87/EU within our group and with our service providers.
We will retain your information as follows:
Registration and Account Information: 7 years after your last active session
Game-Related Information: 3 years after last update
Survey Information: 1 year
Contests, Sweepstakes and Give-aways:
Social Media Information: 7 years after last active session
Partner Site Information: 7 years after last active session
Payments Information: 1 year after last usage
Usage Logs: 7 days;
After you have terminated your use of our Services, we may store your information in an aggregated and anonymized format.
Your Rights & Choices
If you are located in the EEA, you have rights in relation to the Personal Information we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at firstname.lastname@example.org. You have the following rights in relation to your Personal Information:
Access: to enquire and access Personal Information held by us and details about how we use it and who we share it with;
Portability: where we process Personal Information provided by you and processed by us based on contract or consent, you have the right to receive or ask us to provide your Personal Information (subject to any applicable law) to a third party in a structured, commonly used and machine-readable format;
Correction: to correct any Personal Information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the Personal Information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the Personal Information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below;
Erasure: that we erase your Personal Information in certain circumstances;
Restriction of Processing to Storage Only: to require us to stop processing the Personal Information we hold about you other than for storage purposes in certain circumstances; and
Objection: in certain circumstances, the right to restrict or object to our processing of your personal information (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered).
If you ask for the deletion of your account, we will delete your profile information. Prior posts will be de-identified.
In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at email@example.com and we will endeavour to deal with your request. This is without prejudice to your right to launch a claim with a relevant data protection supervisory authority.
Withdrawing Consent & Marketing:
To the extent provided by applicable law, you can withdraw any consent you previously provided to us at any time, including consent for electronic marketing communication. You can do this by emailing firstname.lastname@example.org. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your Personal Information will mean that you cannot take advantage of certain or all of our Services.
The entity responsible for the processing of your Personal Information is: ZAM Network, LLC 12121 Wilshire Blvd. Suite 301 Los Angeles, CA 90025 email@example.com
The California Consumer Privacy Act (“CCPA”) contains additional terms for California residents using the Services, which are set out in this section.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
- Identifiers, such as your name, IP address, email address, mailing address, cookie identifiers, device identifiers, payment processor user identifiers, ZAM and social media account usernames, and phone number. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
- Internet or other electronic network activity information, such as your language preference, information about your avatars or game characters, user preferences, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, IDFA, AAID, click-through data, browse and search history, and log-in and clickstream data. We also collect preferences and usage statistics to analyze how our Services are used, to optimize your ability to view and use the Services, and to provide targeted advertising. This information is collected directly from you and your device.
- Commercial information about any transactions within the Services, which you will provide to our payment processors—including credit card numbers, bank account numbers, and financial account information (including user tokens used to facilitate transactions and information collected to verify transactions). We will receive summary information about transactions from our payment processors without specific reference to individual credit card numbers of bank account numbers. This information is collected directly from you.
- Audio and visual information such as your profile pictures, photos, screenshots, and videos shared or posted through the Service. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
- Professional or employment-related information such as your employment profile. This information is collected directly from you.
- Other information described in subdivision (e) of Section 1798.80, including information about your gender (collected in the consumer context). This is collected directly from you.
We collect your personal information for the following purposes:
- To provide and improve the Services;
- To process surveys and administer sweepstakes;
- For security and verification purposes, including to prevent and detect fraudulent activity; and
- To address and remediate technical issues and bugs.
We disclose personal information to the following types of entities:
- Our affiliate companies within our corporate group who process your personal information in order to operate the Services
- Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us
- Other users of the Services with respect to personal information you publicly post through the Services
- Regulators and judicial authorities and law enforcement agencies
- Entities that acquire all or substantially all of our business
SALES OF PERSONAL INFORMATION
Rights under the CCPA
If you are a California resident and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
- Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.
We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to other data by contacting us at firstname.lastname@example.org or completing this form.