Effective as of: September 3, 2013
Gazillion respects individuals’ privacy, and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy European Union (“EU”) law requiring that Personal Data transferred from the EU to the United States be adequately protected (the “U.S.-EU Safe Harbor”). The European Economic Area (the “EEA”), which includes all member states of the EU, Iceland, Liechtenstein and Norway, has recognized the U.S.-EU Safe Harbor as providing adequate protection of Personal Data (2001 O.J. (L 45) 47). Consistent with its commitment to protect personal privacy, Gazillion adheres to the Safe Harbor privacy principles of notice, choice, onward transfer, security, data integrity, access and enforcement as set forth in the U.S.-EU Safe Harbor. To learn more about the U.S. – EU Safe Harbor program, please visit http://www.export.gov/safeharbor/.
Table of Contents
- The Information We Collect
- How We Use the Information
- When, How and with Whom We Share Information
- Internet Protocol and MAC Addresses
- Collection of Information by Third Party Sites
- When We Delete or Block Information
- Choices You Have Regarding Information about the Collection, Use, and Distribution of Your Personally Identifiable Information (“PII”) and Access to, Correction and Deletion of your PII
- Contact Us
- Updates & Effective Date
- A Final Note to Parents
“Child” or “Children” — A person or persons under the age of 13.
“Closed Beta Test” — The time when any part of the System or any Gazillion Game is open for testing but not open to the public (and not open to Minors).
“Gazillion Account” — Refers to the account you may open on the System for Gazillion Games.
“Gazillion Account Holder” — Refers to any individual that has opened a Gazillion Account on the System.
“Gazillion Game” — Refers to any online game offered by Gazillion.
“Minor” or “Minors” — A person or persons 17 years of age or younger.
“Open Beta Test” — The time when any part of the System or any Gazillion Game is open for testing by the public but not deemed operational by Gazillion.
“Parent” — This also includes legal guardians, whether or not a Minor lives with them.
“Personally Identifiable Information” or “PII” — This is any information concerning the personal or material circumstances of an identified or identifiable natural person (“data subject”), i.e. information that can be traced directly back to an individual. PII includes without limitation: first and last names, e-mail addresses, home addresses, telephone numbers, IP addresses, MAC addresses, and Instant Messaging (“IM”) screen names when associated with a particular messaging service (e.g., AIM).
“Site” or “Sites” — Refers to the Gazillion site (http://www.gazillion.com), and the Gazillion studio or Game sites, including, but not limited to http://www.marvelheroes.com, http://www.HeroUp.com and http://www.amazingsociety.com.
“System” — Refers to the Sites, social networking features, and all interactive features, forums, chat rooms and services associated with Gazillion and Gazillion Games.
“Teen” or “Teens” — A person or persons between the ages of 13 – 17; inclusive.
P.O. Box 6594
135 W 25th Ave.
San Mateo, CA 94403
United States of America
Phone: +1 800 574 7030
3. The Information We Collect
3.1 Information Collected When You Provide It
At Gazillion, we collect PII on our Site when our visitors voluntarily provide it to us. For some activities, such as online polls or surveys, we may ask visitors to provide information that is not personally identifiable. This might include first name only, city or country of residence, age, gender, or a favorite color.
In connection with registration for a Gazillion Account, we may ask users to provide certain information such as city or country of residence, date of birth, and gender. We collect and store an e-mail address to use in the case of forgotten passwords and to send newsletters and/or marketing information for which the individual has consented. We also collect Parent email addresses when they register accounts on behalf of Children or other Minors.
For other activities, such as sending an electronic postcard or e-mail to invite a friend to join Gazillion, we may also ask for personal information about other people. Gazillion stores the email addresses and first name that you provide and uses them solely to contact the owner of the email address. For these Site activities, Gazillion sends only one initial invitation email; for other email-based communications, Gazillion sends an email specific to that communication. Gazillion does not share, sell or rent these email addresses with any third parties. Recipients of invitations who are not registered Gazillion Account Holders can contact Customer Support to request that their emails be added to a “black list” to which Gazillion sends no further invitations.
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 may 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 may 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.
For some limited activities, campaigns, or offers, we may ask you to provide your name, address, e-mail address, telephone number, fax number, credit card information, cable or satellite provider, and/or information about interests in and use of various products, programs, and services.
3.2 Information Collected Automatically
3.3 Information Collected in Connection with Closed Beta Tests
Special rules apply to Closed Beta Tests. Closed Beta Testers must be 18 years or older, or have verified permission from the parent/legal guardian. In order to become a Closed Beta Tester, you, or your parent/legal guardian, will have to provide certain Personally Identifiable Information (“PII”), and also agree to enter into a Non-Disclosure Agreement (“NDA”) that will severely restrict your ability to discuss anything about the Site.
Closed Beta Tester information that you may have to disclose to us includes, but is not limited to: First and last name, e-mail address, MAC and IP addresses, demographic information such as sex, city/state/country, and age.
4. How We Use the Information
We use visitors’ PII collected for internal purposes only, such as creating and administering accounts, providing our services, responding to customer inquiries and enabling visitors to enter our online contests or sweepstakes or to subscribe to an online newsletter. If you grant us permission to do so, we may also use PII to send e-mails regarding special offers, new partners, or other reminders. We may also use a Parent email address for sending updates, and information about a Child’s or other Minor’s account.
We use certain PII, like your age and country of residence, to determine what content we can show you when you log into your account and to comply with the different legal requirements in different countries.
We use information we collect about others to enable visitors to our Site to communicate with those other people, for example, by sending them electronic greeting cards or invitations to join Gazillion or play Gazillion Games. We routinely purge that content from our database, and do not store it for any purpose other than the one time usage.
We do not keep any PII we obtain through a contest or sweepstakes beyond when we have successfully selected a winner(s), awarded the prize(s), and administered the contest or sweepstakes.
We reserve the right to retain any PII you provide us, even if you request that we remove that information, up to the maximum length of time allowed under applicable law in order to fight fraud or abuse in Gazillion Games, or for other purposes allowed under applicable laws.
We sometimes use non-personally identifiable information that we collect to improve the design and content of our Site, and to improve our visitors’ experience on the Site. We also may aggregate this information to analyze Site usage, as well as to offer products, programs, or services.
We also store and use the e-mail addresses of subscribers to our Site’s e-mail newsletters to send them the requested newsletter(s). Each newsletter also includes instructions for subscription removal via return e-mail. Customers will receive e-mail newsletters only when they opt-in during the registration or other newsletter subscription process; we will not send commercial e-mails to customers or Parents who do not opt-in to newsletters during the registration process or who opt out of newsletters later.
6. When, How and with Whom We Share Information
We never sell, rent, or otherwise share our visitors’ PII with third parties unless permitted or required by law or with appropriate consent. Sometimes, we use agents or contractors to provide services, such as helping us conduct a sweepstakes, sending prizes to winners, shipping customer orders made on the Site, processing customer payments or providing customer service related to activities on the Site. In these cases, we require the agent or contractor to keep the information confidential and to use it only for the specific services they are performing.
We may disclose PII in response to legal process, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service (TOS) or End User License Agreement (EULA), to verify or enforce compliance with the policies governing our Site and applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. In addition, we may transfer PII about you if we or one of our business units are acquired by, sold to, or merged with another company to such company. Gazillion will ensure that any such transfer is operated in accordance with applicable data protection laws.
We will not use or transfer PII in ways that are different from the ones described above without also providing notification of such practices and obtaining consent for any different uses.
Please note that any information, including personally identifiable information that you reveal in a bulletin board, chat room, news group or other public forum is publicly viewable on the Site. Please refer to the Terms of Service (TOS) if you wish to learn more about the information you choose to share within the Gazillion Service and Gazillion Games.
8. Internet Protocol and MAC Addresses
An Internet Protocol (“IP”) address is the unique number assigned to your server or Internet Service Provider (“ISP”). The Media Access Control (“MAC”) address is a hardware address that uniquely identifies each node of a network and is normally assigned to the network interface card (NIC) or other network adapter that you use to connect to the internet. Gazillion may track such IP and MAC addresses for system administration, to report aggregate information, Site tracking, or to prevent our servers from being abused, but Gazillion will not store such IP and MAC addresses in full; it will only store truncated IP and MAC addresses that cannot be linked to an individual user or device.
9. Collection of Information by Third-Party Sites
We have taken steps to assure that all information collected will remain secure and in its original form, i.e. free from any alteration. As such, access to all PII is strictly controlled. We have put in place appropriate physical, electronic, and managerial procedures in an effort to help safeguard and prevent unauthorized access, maintain data security, and correctly use the information we collect online.
We are particularly sensitive to visitors’ security concerns regarding the use of credit cards in connection with some services on our Sites, including playing Gazillion Games. For orders placed on our Site, we use a technology that automatically encrypts credit card data while information is being transmitted over the Internet, provided that the visitor’s browser supports the Secure Socket Layer protocol (SSL).
To verify the security of your connection at our Site, check the lower left corner of your browser window after accessing the server. If you see an unbroken or a closed lock, then SSL is active and the server is secure. You may also check by looking at the URL line of your browser. When accessing a secure server, the Site address will change from “http” to “https”.
11. When We Delete or Block Information
To the extent applicable law requires us to store any PII beyond such time, the PII will be blocked. These data are then unavailable for any further use.
In the event that you request that we no longer collect or maintain your PII, your access to the Site and the Services offered by Gazillion may be limited and you may not be able to participate in certain activities offered either free, or at a fee, by Gazillion, including participating in any Beta Test programs.
12. Choices You Have Regarding Information about Collection, Use, and Distribution of Your PII and Access to, Correction and Deletion of Your PII
You have the right to request access to the information we store about you. You also have the right to have incorrect information corrected and to request deleting or blocking information.
If you want to exercise any of these rights or for any reason you are concerned with the way we are using your PII, or would like to change the way we use it, please send a letter or postcard to our Privacy Manager at the mailing address provided below and indicate which of the following you would like to do:
- learn what information we are storing about you
- correct factual errors in such information,
- request to have this information deleted or blocked, or
- request that we no longer collect or maintain such information.
Alternatively you can send an e-mail to email@example.com. In order to help us process your request as quickly as possible, please use the subject field: “Collection of Personal Information.”
Please be sure to include your e-mail address and a telephone number where we can reach you.
If you are a California resident, California Civil Code Section 1798.83 permits you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you do not want your name and contact information to be shared with any company or organization, you may notify us at any time by writing to us at the email and or regular mail address below.
13. Contact Us
Mailing Address (Letters or Postcards only, please):
P.O. Box 6594
135 W 25th Ave.
San Mateo, CA 94403
Gazillion is a licensee of ESRB’s Privacy Online Program. If you believe that we have not responded to your privacy inquiry or your privacy inquiry has not been satisfactorily addressed, please contact ESRB at http://www.esrb.org/privacy/contact.jsp, or contact:
Attn: Privacy Online Program
317 Madison Avenue, 22nd Floor
New York, NY 10017
14. Updates & Effective Date
15. A Final Note to Parents
We recognize a special obligation to protect PII about young children. We urge parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when on- line. Minors should encourage their parents to review this policy and to contact us if they would like to evoke our opt-out policy or to raise any concerns. Children are not allowed to create Gazillion Accounts without parental permission. Please see the Terms of Service for further information.