Pathea Inc., a Delaware corporation (“Pathea”, “we”, “our” or “us”), is committed to maximizing your experience on our Services. This Pathea Privacy Policy explains how we collect, protect, use and share information gathered about you online through our Services. We hope this disclosure will help increase your confidence in our Services to enhance your experience.
Please note that this Privacy Policy applies only to information submitted and collected online through our Services. It does not apply to information that you may submit to us offline, or to websites maintained by other companies or organizations to which we may link, or third-party platforms from which you access the Services (such as PlayStation, Xbox, Steam, or Switch) (the “Third Party Platforms”).
Remember that your use of Pathea’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
“Personally Identifiable Information” is information that can be used, either on its own or together with other information, to uniquely identify you or from which you can be identified such as your name, email address, certain demographic information (such as age, gender and ZIP code), or credit card number.
Pathea will only use your Personally Identifiable Information to provide you with Pathea products and services, or to communicate with you about such products and services. If you choose to make content or a document public, we recommend you redact any and all references to people and addresses, as we can’t protect public data and we are not responsible for any violation of privacy law you may be liable for. The following information is automatically collected when you use our game services: IP address, unique platform-specific identifier, unique identifier specifically for your Services account. We also may collect additional information including, the type of operating system, gameplay attempts, progression and results, country of your device, and identification of crashes and defects. We process the data to operate, improve, understand and personalize our Services. Specifically, we use the data to, create and manage user accounts, provide support and assistance for the Services, fulfill user requests, comply with our legal or contractual obligations, and protect against or deter fraudulent, illegal or harmful actions. We employ industry standard techniques to protect against unauthorized access of data about you that we store, including Personally Identifiable Information. This information is collected during game registration, or other online information service we may offer, or when contacting us. Our Services contain links through which an online user can contact us. We collect Personally Identifiable Information contained in this communication for the purpose of responding to a user’s questions and/or comments. No matter what method we use to collect Personally Identifiable Information and no matter how we use that information, we will only collect the information deemed reasonably necessary to fulfill your online requests and our legitimate business objectives (provided that, on balance, these legitimate business objectives do not prejudice your own privacy) or otherwise permitted by applicable law.
We do not knowingly collect or solicit personally identifiable information from a child under 13 (or older, if applicable law provides for different protections). If you are a child under 13 (or older, if applicable law provides for different protections), please do not attempt to send any Personally Identifiable Information about yourself. If you believe that a child under 13 (or older, if applicable law provides for different protections) has provided us with Personally Identifiable Information, please contact us as set forth below in Section 9. Please note that children under 13 (or older, if applicable law provides for different protections) may be required to provide certain Personally Identifiable Information to a Third Party Platform; we do not have access to that Personally Identifiable Information and do not control the practices of Third Party Platforms. We may collect unique device identifier information about users, without knowledge of their ages, as described in more detail below.
If you choose not to submit Personally Identifiable Information when requested, you may not be able to access certain areas or portions of our Services and you may limit the products and services we can provide you or they may not be personalized based on your preferences.
We may collect some information about you by using data collection technology, so that it may not be readily apparent to you that it is being collected. For instance, when you come to our websites, your IP address is collected so that we know where to send information you are requesting. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. We may also transfer to your browser or device a “cookie,” which is a small file or record-keeping device that may be stored on your device and that allows Pathea to recognize your device and that tells us how and when pages and features in our Services are visited and by how many people. You can disable cookies or set your browser to alert you when cookies are being sent to your computer. This information may be used to make our Services more interesting and useful to you. Additionally, we may combine this information with other information to identify a user in order to enforce compliance with our Terms of Use, or to protect our Services or other users of the Services. We do not collect information about your online activity after you leave our Services. We may collect technical information about your use of the Service through the use of tracking technologies and analytics. By way of example, data we may collect includes the following analytics:
Except as described in this Privacy Policy, we do not share information we have collected about you, in personally identifiable form, unless:
We do not share your Personally Identifiable Information with third parties except as we expressly state below: We may aggregate and/or anonymize data about you (such that it no longer specifically identifies you as an individual identifiable person), and we may use that information and share it with third parties to help improve the Services and such third parties’ products and services. From time to time, we may employ and share your Personally Identifiable Information with vendors who use it solely to provide support and services to us (e.g., technical support and network delivery). We only authorize these entities to use your Personally Identifiable Information for the purpose of providing services to us, and these entities have agreed to maintain the confidentiality, security, and integrity of the Personally Identifiable Information they obtain from us. Further, Pathea may sell, transfer or otherwise disclose user information, including Personally Identifiable Information, in connection with a corporate merger, consolidation, the sale of substantially all of its assets related to the Services you use, or other fundamental corporate change. Any such transfer shall continue to be subject to this Privacy Policy, and you will be notified via account message or other prominent notice. You may request a copy of the Personally Identifiable Information held by us by contacting us as set forth below in Section 9.
If you wish to review, change, correct, update, or delete any Personally Identifiable Information that we may have collected about you, please contact us as set forth below in Section 9. Certain information may not be editable or deleteable.
We maintain appropriate safeguards that ensure the security, integrity and privacy of the Personally Identifiable Information we collect from all users. Personally Identifiable Information collected by us is stored in secure operating environments that are not available to the public and are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse and alteration of the information under our control.
If you are a resident of the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the E.U. General Data Protection Regulation (the “GDPR”) with respect to your Personal Data processed in connection with the Services, as outlined below. For clarity, the term “Personally Identifiable Information” as used in this Privacy Policy includes “Personal Data” if, and to the extent, this section 8 applies to you.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
Where applicable, this section is intended to supplement, and not replace, the rest of this Privacy Policy. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.
If you have any questions about this section or whether any of this section applies to you, please contact us as set forth below in Section 9.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, to prevent fraud and illegal activity (including reserving the right to disclose your identity to any third party claiming violation of intellectual property, and working with console operators to assist with fraud prevention), and other processing grounds such as complying with a legal obligation, or necessary for a task carried out in the public interest. as further described below:
OTHER USES OF YOUR INFORMATION:
We keep your information confidential, but we may disclose it to group members, personnel, suppliers or subcontractors; in relation to a merger or acquisition, as required by law; or as necessary to enforce or apply the terms of agreements and protect our rights, property or safety of Pathea, our customers or others.
AUTOMATED DECISION MAKING
We use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.
We process your personal information via automated decision-making methods in order to identify users who are in violation of our Terms of Service. Our automated decision-making methods are designed to detect violations by looking out for excessive, unusual, or negative behaviors related to activities such as using inappropriate language, bullying, and cheating.
If users are determined to be or suspected of being in violation of our Terms of Service, actions may be taken and we may block or suspend users from the Service. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision.
How long we retain your Personal Data: We may retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services and for 24 months after you close your account, or for longer periods, where we may retain such Personal Data according to applicable law. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
Your rights regarding Personal Data: Under the GDPR, you have certain rights with respect to your Personal Data, including access, rectification, erasure, objection and right to file a complaint. For more information about these rights, or to submit a related request, please contact us as set forth below in Section 9.
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it violates the rights of others, or if it is not required by law. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Pathea reserves the right to make changes to this Privacy Policy at any time. If Pathea changes its Privacy Policy, we will post those changes on our websites so that you and other users are always aware of what information is collected, how it is used, and under what circumstances, if any, it is disclosed. You should also check back from time to time to ensure you are aware of any changes. If we are going to use Personally Identifiable Information in a manner different from that stated at the time of collection, we will notify you and others via email or by placing a prominent notice in our Services. By using the Pathea Services, you signify your consent to the Pathea Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services. Your continued use of our Services will signify your acceptance of these changes.