PRIVACY POLICY

May 27, 2021

INFORMATION WE COLLECT AND OUR LAWFUL BASES FOR PROCESSING

You provide us with information directly, such as when you set up an account with us. We also collect information about you and your activity when you use our Services – whether through gaming consoles, computers, mobile devices, in-game applications, software platforms, third party social or gaming networks. We may use online tracking, such as cookies and similar technology, to collect information, when you share in-game content with friends, or connect to our Services, and we collect information from third parties (such as advertising networks and external business partners).

The types of information that we collect depend on how you use the Services and interact with us. You can control the personal information we collect from you unless we need it for the requested activity (e.g., to provide the Services you’ve requested or purchased, to confirm who you are, or to participate in an event). We will let you know when information is necessary.

Information You Provide

You provide us with information when you use the Services, such as when you:

create an account, or register for or use the Services;
subscribe to newsletters and communications;
comment on our message boards, forums, chat rooms, feeds, sites, or other Services;
download, install, or access demos, programs, or other software;
contact us for support or other purposes;
use our email / share features;
participate in an activity where you can provide, or need to provide, your information.

Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, hardware configuration, console ID, software products played, survey data, IP address, geolocation, and the systems you play on. We combine this information across computers or other devices that you use.

When you use the Services on hardware connected to the Internet, we receive information about your gameplay even if you are not specifically notified at the time or do not take any actions to actively give us this information. Gameplay information includes your console ID, gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device ID, other console / device information, and other information and statistics regarding your Service use. We collect gameplay information even if you do not register for the Services and we may collect gameplay information while you are offline. Offline gameplay information is transmitted to us when you next connect to the Internet. We may combine gameplay information with other information we have about you.

We collect information when you use third-party platforms like a gaming console account, gaming network service account, or social networking service account to connect to or engage with our Services. When you use these third-party platforms or link your Rockstar account, the third-party platforms provide us with information about you. For example, depending on your use of, or activity on the third-party platform, we receive your user name, your friends list, or account information necessary to provide a purchased in-game item. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.

We receive information from third parties to update the information that we collect about you. For example, we receive information from public databases, console manufacturers, analytics providers, game developers, and other business partners that includes demographic information and information about your interests. We obtain information from social media and other publicly available sources, which we may use to better understand our users or to seek intelligence about breaches of our Terms of Service. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on our message boards, forums, chat rooms, or other Services, or an individual sends us a direct message, for example, about an alleged breach of our Terms of Service.

We collect, use, and otherwise process your information when we have a lawful basis, as follows:

Consent: We ask you for consent to collect or use your personal information for specific purposes, such as when we want to send you emails about special offers or competitions, or if you decide to link your LanyGames account with a third-party service.

Contract Performance: We process your personal information when we need to perform and manage a contract with you, such as our Terms of Service, or to take steps at your request before we contract with you, such as to complete transactions with you and to allow you to play our games online.

Legal Requirement: We process your personal information when required by law.

Legitimate Interest: We process your personal information when necessary for our, or others', legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our products and services; performing analytics and using surveys to better understand our users; conducting direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; ensuring the proper function, security, and integrity of our services; dealing with user questions; enforcing our Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of our EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement.

Legitimate Interest: We process your personal information when necessary for our, or others', legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our products and services; performing analytics and using surveys to better understand our users; conducting direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; ensuring the proper function, security, and integrity of our services; dealing with user questions; enforcing our Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of our EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement.

Legitimate Interest: We process your personal information when necessary for our, or others', legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our products and services; performing analytics and using surveys to better understand our users; conducting direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; ensuring the proper function, security, and integrity of our services; dealing with user questions; enforcing our Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of our EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement.

COOKIES AND SIMILAR TECHNOLOGY

Cookies are very small text files that companies place on your device when you visit or use some sites, applications, or other web-based services to help identify a computer, browser, or device. We use cookies, web beacons, Internet log files, and similar tracking technologies (ours and from third-party providers) to allow our Services to function; maintain your preferences and settings; provide enhanced features; analyze how users use our Services; combat fraud; prevent violations of our EULA and policies; and to provide you with targeted advertising based on your interests. If you choose to provide us with information, it may be linked to the information collected by cookies and similar technologies including advertising cookies. Our system may not respond to Do Not Track requests or headers from some or all browsers. The Manage Your Account, Communications, and Data section below provides additional information about our use of cookies and similar technologies and your ability to manage cookies You may also use the cookie preference tool, where available, or visit the cookie policy posted on the Service for more information.

Cookies are used to identify a computer, browser, or device. Certain cookies are necessary for the Services to function and others let us to provide you with an enhanced experience. You can disable cookies on your device or set your browser to alert you when we or others send cookies to your device but disabling cookies may affect your ability to use certain Services. For more information, including details of specific cookies we use, applicable for the Service, see the cookie preference tool or visit the cookie policy posted on the Service you are visiting. You can find more information and make choices about third-party cookie providers in the following sections of this Privacy Policy: When We Share Information, Advertising and Manage Your Account, Communications, and Data.

We may collect Internet log files when you use the Services. These log files can include IP addresses, MAC addresses or other device IDs, depending on your network configuration. Depending on the Service you use or the activity you engage in, we associate these log files with your information.

HOW WE USE INFORMATION

We use the information we collect from and about you within Lany Games for a variety of business purposes including to: provide the Services; fulfill orders and requests; analyze and improve our Services and our business; communicate with you; respond to questions or technical problems; develop internal marketing and demographic studies; provide support and security for our products; and as more fully described in this Privacy Policy.

We also use your information within Lany Games for commercial purposes, including: send you and similar consumers direct marketing and online / social media advertising from Lany Games and our business partners, including use of demographic information; for other purposes identified when you provide your information; or otherwise with your permission. We may further use your information as permitted by law.

If you participate in open communities, such as online gaming sessions and social networking services, we automatically post certain information, such as your user name or ID and gameplay statistics, within the game, on social networking services, on our Services, or on specialized game sites. If you participate in tournaments or other online game events, we must publicly post your information. We also use automated means to monitor gameplay to ensure that you and others use our Services in accordance with applicable policies, including our EULA and Terms of Service. If we find that you have breached our Terms of Service or other applicable policies, this could lead to your temporary or permanent exclusion from the Services.

We use information we collect from and about you for business purposes including to:

Provide the Services;
Fulfill product orders and other requests, respond to your questions, and communicate with you;
Enhance your experience on the Services, including to recognize you, maintain your preferences and settings, and link to your third-party console, gaming, and social networking platforms;
Provide technical and other support;
Review the use and operations of the Services, develop new products or services, and conduct analyses to enhance or improve our software, content, internal marketing, support, and Services;
Conduct internal marketing and demographic studies;
Analyze our users, in combination with other data, to assess our user base and target marketing at other similar groups;
Address issues with the Services or other business needs;
To protect the security or integrity of the Services and our business such as by protecting against and preventing violation of our EULA and policies, including combating fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and managing risk exposure; and
Interact on your behalf with the third-party console, gaming and social networking platforms you connect with our Services.

We use information we collect from and about you for commercial purposes, including to:

Provide you and other users like you with customized content on the Services, targeted offers and advertising on the Services, via email and text message, or on other sites, mobile applications, or social media on behalf of Lany Games or our business partners; and
Contact you with information, newsletters, and promotional material.

We also use information we collect from and about you to:

Participate in other processing that we inform you about when you provide your information or when you consent to such processing; and
As permitted by law.

HOW WE USE INFORMATION

As detailed in this Privacy Policy, we share your information with our vendors that perform support and other services in connection with the Services; advertising service providers and advertising partners that enable us to conduct and display advertising on the Services and third-party sites, mobile applications, or social media services; and with third parties for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, for use in aggregate or anonymous form, and for other purposes with your permission.

DATA RETENTION

We retain your information while your account is active, as needed to provide you Services, or to administer our Services. If you wish to cancel your account or request that we no longer use your personal information to provide Services to you, contact us as identified in the Manage Your Account, Communications, and Data section above. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our Services. After such period, we will delete personal information, including your email address and log-in credentials, and you may no longer be able to access your account. We will notify you before we delete your account information so that you have the opportunity to keep your account active.

DATA SECURITY

We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.

CHANGES TO PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to ensure that you are aware of these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.