SQUARE ENIX, INC.
Revised: October 30, 2017
· We ask you for, and use technology to detect, information about you. Some of this information is shared with others, including advertisers. In addition, third parties, including advertisers and advertising services providers, may collect or be given information about you.
· We use technology to collect in-game behavior to improve game performance and backup in-game purchases should they need to be restored or accessed on another device.
· To provide relevant advertising, possibly including targeted and location-based advertising, we may share, and third parties may collect or share, certain information (such as the location of your device) about you.
· We track media performance, which requires that behavioral data be collected by and/or shared with third parties before and after the application or service is downloaded or used.
· Although we may ask for Personal Information (defined below), we will not share such information with unaffiliated third parties except as disclosed herein, as required by applicable law, or with your consent.
· EU data subjects may opt-out of the processing of their personal data for marketing purposes by following the instructions set out herein.
Square Enix participates in the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework. To learn more, click here .
You may give us Personal Information and other information when you register or use our Services.
We may use Tracking Technologies to collect your information. This helps do things like deliver preferred content, track game play advancement, and send you relevant ads.
Third parties may also use Tracking Technologies with our Services to collect information about you, and we are not responsible for the practices of these third parties. By installing and using the Services you consent to encountering first-party and third-party Tracking Technologies.
In addition to the information we collect from you directly, we may also receive information about you from third parties for various purposes.
If you interact with third-party sites (such as using Facebook to log in), those sites may send us information about you or we may send them information about you. You should review the applicable third-party privacy policies before using third-party tools on or in connection with our Services, and we are not responsible for these parties’ practices.
You may give us information about others, such as when you send a friend a message. We will not use their Personal Information to separately market to them unless they consent.
We may use your information for a variety of purposes, including to manage, improve and protect the Services, and to send you promotional and transactional communications.
We may update your existing Square Enix account, or create one for you, with information collected via the Services.
We provide your information to third parties under various circumstances. These include:
(e) Co-branded Areas
Posting content in public areas makes it available to us and to others.
You grant us the right to use your name, likeness and/or usernames in connection with your posting and activities.
We are not responsible for third-party websites or your interaction with third-party content.
We are not responsible for your interaction with third-party applications.
We and third parties may send you targeted or untargeted ads based on your location and behavior. We do not respond to “Do Not Track” signals we receive.
You may access and change certain account information, including Personal Information. You may also request access to the Personal Information we have collected from you, and we will make good faith efforts to accommodate such requests.
You may cancel or modify certain email communications you receive from us by following instructions contained within our promotional emails or, where applicable, logging into an account you have created for our Services and changing your preferences.
We may transfer data internationally, including to our facilities in the United States, Japan, Canada and the European Union. We participate in the E.U.-U.S. Privacy Shield Framework.
All of our Services are targeted towards users 13 years old and up. We do not knowingly collect and store Personal Information from a user(s) under 13 years old (“Child” or collectively “Children”) without verifiable parental consent. If you think we have unintentionally collected Personal Information from a Child, please let us know.
No data security is absolute, but we take reasonable and appropriate steps to help secure data.
On the Services, you may provide to us personally identifiable information, which is information that can reasonably be used to identify you personally, such as your first and last name, date of birth, email address, and address (“Personal Information”). We may collect Personal Information and other information, including demographic information such as gender, age, marital status, education level and occupation, through various forms and in various places on the Services, including account registration forms and “contact-us” forms.
Some of our Services may collect and transmit precise, real-time information about the location of your Device. For our mobile applications, you are made aware of this at the time you first open the Services with this functionality. Unless it is needed for operation or monetization of the Services, the Services may give you the option to turn location tracking on or off or otherwise manage location services. You can always terminate our location tracking by uninstalling our mobile applications.
We may use various current – and later – developed technologies to collect information about you (“Tracking Technologies”). A few of the methods that may be used to collect such data include, without limitation, the following:
Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code temporarily downloaded onto your Device from our web server or a third-party service provider is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Web Beacons: Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
ETag, or entity tag: A feature of the cache in browsers, an ETag is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner, ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and HTML5 cookies.
For more information on advertising and related Tracking Technologies, click here.
The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third-party web site or application. Here are two examples:
You may send someone else a communication from the Services, such as sending an invitation or message to a friend. If so, the information you provide about them (names, email addresses, etc.) is used solely to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any “send-to-a-friend” functionality on our Services, your Personal Information may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies, as further detailed in Section 1(d) above.
(a) When You Agree To Receive Information from Third Parties: You may be presented with an option on our Services to receive certain information and/or marketing offers directly from third parties. If you choose to do so, your Personal Information will be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. We are not responsible for such third-party privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from one of these third parties, you will need to contact that third party directly.
(b) Third Parties Providing Services on Our Behalf: We may use third-party agents, vendors, consultants, and other service providers to perform certain services on behalf of us or the Services, such as hosting the Services; developing, designing and/or operating the Services’ features; tracking the Services’ activities and analytics; performing surveys or other user research; and enabling us to send you or people like you special offers or perform other administrative services. These third parties may be granted access to your information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.
Third-party analytics, user research, and similar service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information.
(c) Administrative and Legal Reasons: We may access, use, preserve, transfer and disclose your information to third parties: (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (ii) to satisfy any applicable law, regulation, subpoena, or governmental requestor legal process, or any legal process in connection with a court proceeding or arbitration, if in our good faith opinion such is required or permitted by law; (iii) to protect and/or defend the Services’ SEA Terms of Service or other policies applicable to the Services, including investigation of potential violations thereof; (iv) to protect the safety, rights, property or security of the Services, our staff, or any third party; and/or (v) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP addresses or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright and trademark owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to such third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
(d) Business Transfer: We may share your information with our parent, subsidiaries and affiliates within and outside of the United States. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any related due diligence process.
(a) User Generated Content and Public Information: The Services may permit you to submit text, dialogue, ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions, content created using an in-game tool, or other content, including Personal Information (collectively, “ User Content”) on blogs, message boards, through gameplay or other channels. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or later developed) in perpetuity and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Services.
You may remove User Content you have posted on our forums by logging into your account, directly accessing your post, and using the editing tools in our forums (if available). Should you wish to edit or remove User Content you have previously posted publicly, you may contact us with your specific removal request. Please note that we are not required to remove your posted content or information if it has been rendered anonymous or if we are required by law to retain it.
(b) Name and Likeness: We may also publish your name, voice, likeness, username, profile image and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
The Services may contain content that is supplied by a third party, and those third parties may collect your information when you interact with the Services or when web pages from the Services are served to you. In addition, when you are on the Services, you may be directed to other sites or services that are operated and controlled by third parties that we do not control, which may collect your information. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites. For example, if you “click” on a link, the “click” may take you off the Services onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
Third-party applications may be available via the Services (such as in-game advertising for other applications that can be accessed by you). The owners of these applications (“Third-Party Owners”) may collect information from you and may have their own policies and practices. We are not responsible for how Third-Party Owners or their applications collect or use your information. These Third-Party Owners may have their own terms of service, privacy policies or other policies and may ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any information to a third-party application or otherwise interacting with it and exercise caution in connecting with these applications.
You may choose whether to receive certain interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, we currently do not alter our practices when we receive a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You have the right to access the Personal Information we have about you. You may review, correct or update Personal Information you have provided by logging in to your Square Enix Account or emailing us at firstname.lastname@example.org. We will respond to your access request within a reasonable time period. We may require additional information from you to allow us to confirm your identity.
Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Services, information that you remove may persist internally for Company’s administrative purposes. You can stop all prospective collection of information by our Services by uninstalling and/or ceasing to use the Services. With respect to our mobile applications, you may use the standard uninstall process available as part of your applicable Device or via the appropriate application or app marketplace.
You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or, where applicable, by logging into an account you have created for our Services. This will not affect subsequent access to the Services and your opt-out may be limited to certain types of emails.
Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and service announcements, and you will continue to receive these transactional account messages even if you opt-out from receiving our marketing communications.
Company participates in the E.U.-U.S. and Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from the European Union, European Economic Area and Switzerland. For the purpose of this Section 10, “Company” refers to the following legal entities only: Square Enix of America Holdings, Inc., Square Enix, Inc., Square Enix L.L.C., and Crystal Dynamics Inc. Company has certified that it adheres to the Privacy Shield’s Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. In accordance with its obligations under the Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, Company hereby affirms its commitment to subject to the Privacy Shield Principles all Personal Information received from the European Union, European Economic Area and Switzerland in reliance on the Privacy Shield. This means that, in addition to Company’s other obligations under the Privacy Shield Principles, Company shall be liable to you for any third-party agent to which we transfer your Personal Information and who processes such Personal Information in a manner that violates the Privacy Shield Principles, unless Company can demonstrate that it is not responsible for the resulting damages.
To learn more about the Privacy Shield Framework, and to view Company’s certification, please visit https://www.privacyshield.gov/welcome. A list of companies certified under the Privacy Shield Framework is available at the following link: https://www.privacyshield.gov/list.
We do not knowingly collect or store any Personal Information from Children without verifiable parental consent, as required by U.S. law. There may be instances, such as a sweepstakes, contest or promotion, in which we collect Personal Information from a Child in order to contact a parent and complete prize fulfillment.
We take reasonable measures to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk. We will notify users of a data breach involving their unencrypted Personal Information by sending an email and/or prominently posting notice to the applicable Service.
As previously mentioned, we are a licensee of ESRB’s Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at http://www.esrb.org/privacy/contact.aspx, or ESRB, Attn: Vice President, Privacy Certified Program, 420 Lexington Ave., Suite 2240, New York, NY 10170. You may also e-mail them at email@example.com.