Last Revised: May, 2015
This Privacy Statement and the certification seal located to your right confirms that BRG is a valid licensee and participating member in the Entertainment Software Rating Board’s Privacy Online Program: ESRB Privacy Online. To protect your privacy to the maximum extent possible, we have undertaken this privacy initiative and our websites have been reviewed and certified by ESRB Privacy Online to meet established online information collection and use practices. As part of the privacy program, we are subject to frequent audits of our sites and other enforcement and accountability mechanisms administered independently by ESRB.
ESRB Privacy Online is a third-party seal provider whose mission is to protect consumers’ online privacy and make the Internet a secure, reliable and private place to share information and conduct business. ESRB Privacy Online promotes and enforces established principles and guidelines for fair information collection practices that include requirements of full disclosure, notice and informed consent.
Whenever you visit a website that displays the ESRB Privacy Online certification seal, you can expect to be notified of:
What personal information may be collected and by what means
Who, if anyone, is collecting your personal information
How this information may be used, including who, if anyone, it might be shared with
The consequences, if any, resulting from your refusal to provide personal information
How you can access and, if necessary, change the personal information a company maintains
How a company ensures data security, quality and integrity
Where and how to ask questions or file complaints
THIS POLICY APPLIES TO:
THIS POLICY DOES NOT APPLY TO:
WHAT WE COLLECT:
Collection of Personal Information through our Websites
We do not require that website visitors reveal any personally identifying information in order to gain general access to our websites. However, visitors who do not wish to, or are not allowed by law to share personally identifying information, may not be able to access certain areas of our websites, participate in certain activities, or make purchases. Although personally identifying information may be required to participate in certain promotions or features offered through our websites or to make purchases, participants provide this information on a voluntary basis only. Collection of personal information required to access certain website services may include the collection of date of birth, name, email address or credit card information.
We collect personally identifying information in connection with the following:
Questions or comments sent through our websites to Consumer Services
Subscription to a marketing program
Some of our website activities require that the user log in using a site-based account.
BRG may require a site account in connection with:
Participation in online contests, sweepstakes or other promotions
Inclusion in our email newsletter program
Participation on our message boards
Access to special sections of official game websites
Passive Information Collection
BRG may collect information such as our website visitors’ IP address, IP address-related information, system Media Access Control (“MAC”) address, network configuration information, network device information, browser plug-in types and versions, operating system, and platform. We also may collect information about your download activity, browser activity, forum postings and session information.
Dynamic advertisement serving technology enables advertisements to be temporarily loaded or cached to a users account system for display only in games that incorporate this technology. If an account holder plays a game that utilizes this feature, BRG will log information about his or her system and game play to ensure that advertisements are being appropriately served to him or her and to track information about the advertisements displayed during his or her gaming session. Logged data may include: Online ID, system IP address, system MAC address, in-game advertisement location, the length of time an advertisement was visible, relative size of advertisements, the angle of view and other information related to each advertisement visible during the gaming session.
“Log files” are files that log actions that have occurred on a website. We may use log files to gather statistics about consumers’ browsing habits and to assess overall website activity, including how many “hits” a particular web page is getting. These entries are generated anonymously, and enable us to track interest in specific promotions, troubleshoot technical concerns, and provide consumers with content that may be of interest to them. We also use the log file entries for our internal marketing and demographic studies, so we can constantly improve the online services we provide to consumers. Log files are used internally only, and are not associated with any particular user, computer, or browser.
We also use these technical methods to analyze the traffic patterns on our websites, such as the frequency with which consumers visit various parts of our websites. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML emails that we send our guests to determine whether our consumers have opened those emails or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is personally identifiable.
HOW WE USE YOUR INFORMATION
Personally identifying information that we collect for a particular promotional purpose through one of our websites or to make purchases is saved and used only for that purpose, unless the participant chooses to opt-in to one of our marketing programs. Visitors to our websites may be given the opportunity to “opt-in” to two different programs. The first option is to receive marketing content from BRG. The second is to have personal information shared with BRG’s third party partners so that they may send you marketing materials.
Consumers who voluntarily provide personally identifying information via our website for purposes of receiving marketing materials or who opt-in to receiving marketing materials when they register a Network Adaptor (Ethernet/Modem) or with integrated network and line connectors for online gaming through the Online Start-Up Disc, become members of our marketing program.
By logging in as an account holder on our websites, consumers consent to having information regarding their activities added to their customer profile, whether information regarding those activities comes from BRG internal sources, BRG-related entities or affiliated sources. We may give account holders the opportunity to provide information about themselves and will from time to time conduct surveys or questionnaires for members to provide feedback and additional information. This information allows us to provide those account holders with information about our products that best suits their interests and to customize their experience.
Data that we have collected about a account holder via dynamic in-game advertising may be used to provide him or her with future advertisements that we believe will be of particular interest.
Email addresses collected from consumers during the use of the E-Cards or “Send-to-a-Friend” email feature on our websites are not retained by us, and are only used to send a one-time email notification on a consumer’s behalf.
BRG may use personally identifying information for marketing and demographic studies. These studies help us improve our websites, products and services to better meet our users’ needs.
BRG’s consumer services department maintains information obtained from consumers who contact or submit an online complaint so that we may assist these customers with current or future service issues. Consumer Services uses this information only for payment and payment verification purposes. BRG’s consumer services department may direct consumers to the consumer services departments of other companies with whom BRG has arranged to provide consumer service, so that the consumer receives appropriate assistance.
We may use personally identifying information and records for defense of a lawsuit, investigation or other action if such personally identifying information, records or profiles are relevant to the lawsuit, investigation or action.
WHO WE SHARE WITH:
We may share the personally identifying information of our website users with our affiliates in the BRG group family of companies and other third parties who assist us with fulfilling your requests, clear and verify transactions, deliver and administer products, content or services, manage and enhance customer data, store and maintain our database records, provide customer service, detect fraud or illegal activities, conduct customer research and surveys, develop new products and services and sell products and services to you.
BRG may also share personally identifying information with law enforcement or similar organizations, in connection with a criminal investigation, investigation or prevention of fraud or criminal activities, infringement of intellectual property rights or other activity that is suspected to be illegal or may expose our users or BRG to legal liability.
We may share non-personally identifying information and behavioral data from our studies with our affiliates and other third parties.
Data logged via dynamic in-game advertising or some portion of it will be shared with third party companies that operate the advertisement serving technology, and these companies may share aggregated data (meaning data that includes data about a account holder’s gaming session but is not specific to him or her) with advertisers and game publishers.
We do not control our affiliates’ or third parties’ use of your information after we share it, but we use reasonable efforts to obtain our affiliates’ and third parties’ agreement to protect the confidentiality, security, and integrity of any personal information we share with them or that we permit them to collect directly. If consumers do not want their personal information made available to others in these ways, they should not provide their personal information to us.
California Privacy Rights
Beginning on January 1, 2005, California Civil Code section 1798.83 permits BRG customers who are California residents to request certain information regarding BRG’s disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties for their direct marketing purposes. To make such a request, contact our consumer services department through the following link: email@example.com If you would like to change your current account preferences, go to the account management section of your BRG Online Services account.
Policies for Children
BRG does not knowingly collect personally identifying information from children under 13 years of age via our websites.
Website Message Boards
Our website message boards are a place where users can go to freely share their thoughts and ideas about the BRG brand. A BRG Entertainment Network account is required to contribute to these message boards. We prohibit message board participants from disclosing their own personally identifying information other than their own Online IDs. We ask our users to respect the privacy of others. Disclosure of phone numbers, addresses, age or other personally identifying information that may violate someone else’s privacy is prohibited. Encouraging or asking users to disclose publicly their personally identifying information is also prohibited.
BRG allows job seekers to inquire about jobs and submit personally identifying information in connection with applying for employment. If a job seeker creates a job profile, he or she will be asked to provide an email address and create a password. He or she can use that email address and password to access his or her account, review the information in his or her profile, edit or delete his or her profile at any time.
We treat personally identifying information submitted to us for business purposes differently from information we receive in a non-business capacity. We may share resumes or potential developer contact information submitted to us, for example, with other BRG companies or third parties, depending on the nature of the inquiry.
Accuracy & Security
We take reasonable measures to protect the confidentiality, security, and integrity of the personal information collected from our website visitors. Personal information is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. Unfortunately, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with our websites, that we store on our systems or that is stored on our service providers’ systems.
BRG operates in North America but this site is intended for consumers in the United States. When we process personal data and information and personally identifying information in the United States, we follow United States data protection and privacy regulations, which may not offer the same level of protection as in other parts of the world, such as the European Union. If we are made aware that a consumer’s country of residence is outside the United States, that consumer will be directed to the appropriate BRG company or affiliate.
Transfer of Your Information in the Event of Sale or Acquisition
We will retain personally identifying information about you for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required by law or regulations.
BRG is a licensee of the ESRB’s Privacy Online Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at http://www.esrb.org/privacy/contact.jsp
Attn.: Privacy Online Program
317 Madison Avenue, 22nd Floor
New York, NY 10017