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This page will guide you through the Tripwire Privacy Notice, last updated 21st September 2018. The table of contents is listed below, so that you can navigate around it simply. If you wish to contact us with specific data subject request, the exact method is listed in the relevant section.
If you have any questions or concerns about this Privacy Notice, please contact us by sending an email to: [email protected].
Tripwire Interactive LLC ("Tripwire Interactive") is an American video game developer based in Roswell, Georgia. Our headquarters are located at 1775 Woodstock Road, Roswell, Georgia 30075.
This Tripwire Interactive Privacy Notice ("Privacy Notice") describes how Tripwire Interactive collects, uses, shares, and retains personal data that you provide to us, or that we collect, when you use the Tripwire Interactive websites located at: www.heroesofstalingrad.com; www.killingfloorthegame.com; www.risingstormgame.com; www.killingfloorcalamity.com; www.tripwireinteractive.com; rs2vietnam.com; www.killingfloor2.com; maneatergame.com (collectively, “the website”), register for any forums, blogs, mailing lists, contests, surveys, or other activities made available through the website, or use any Tripwire Interactive game we create or license.
Please read this Privacy Notice carefully. If you disagree with anything in this Privacy Notice you must not provide personal data for anything through the website or use Tripwire Interactive's games or services. By using or continuing to use the website or any of our games or services, you are accepting the terms, conditions and directions set forth in this Privacy Notice, as described below.
2.1 General Description
The specific data Tripwire Interactive collects, stores and processes depends on which products you use and how you use them. We collect personal data and non-personal user data and will disclose in this Privacy Notice the circumstances under which Tripwire Interactive collects either personal data or non-personal data.
For purposes of this Privacy Notice, Tripwire Interactive adopts the definition of personal data set forth in the General Data Protection Regulation (EU) 2016/679 ("GDPR") at Article 4(1) which broadly defines personal data as "any information relating to an identified or identifiable natural person" and includes identifiers such as a name, online identifiers such as an IP address, and email addresses. This is not an exhaustive list, but a few examples aimed at helping you understand what constitutes personal data.
Non-personal user data is data that should not identify a person or to allow Tripwire Interactive to contact a specific person. Some examples of non-personal data are information about the number of users that visit Tripwire Interactive's website and the pages of the website which are visited, as well as usage data as to certain features of Tripwire Interactive games that is not connected to any particular user. These are examples and not an exhaustive list of all types of non-personal data.
If you are from the United States, you may be accustomed to the term "personally identifiable information" or "PII" to describe personal data. For purposes of this Privacy Notice, personally identifiable information is personal data as defined in Article 4(1) of the GDPR except as specified under Children.
Where this Privacy Notice describes processing personal data, Tripwire Interactive adopts the definition of "processing" set forth under Article 4(2) of the GDPR: "processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2.2 Website Data Collection
You can browse Tripwire Interactive's website without disclosing any personal data. Except as described in this Privacy Notice, Tripwire Interactive does not share any personal information with any third party that you may choose to provide to us in connection with our forums, wiki, blogs, press lists, and other requested services described below in sections 2.2.1 - 2.2.8.
2.2.1 Google Analytics
Tripwire Interactive uses Google Analytics, a web analytics tool provided by Google Inc. ("Google"). We use Google Analytics on the website and on the store pages hosted by Steam: https://store.steampowered.com/. Google Analytics uses so-called "cookies", text files stored on your computer, and an analysis of your use of the web page enabled. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the United States and stored there. However, Google uses an IP anonymization tool on our website, with which your IP address is shortened by Google and anonymously transmitted on a global basis. This means that whether your IP address is collected from the United States, or the European Economic Area, the United Kingdom or Switzerland (collectively, the "EEA"), or anywhere else in the world, it will be transmitted using Google’s IP anonymization tool and will not disclose any personal data. Google uses the non-personal data information collected to evaluate your use of the website for Tripwire Interactive, to create reports for us about the website activity and to provide other services related to the website and internet usage to Tripwire Interactive. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=eh. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
2.2.2 Forums & Wiki
If you want to participate in Tripwire Interactive's forums or Wiki, you will have to complete a registration process. Children under the age of 13 are not permitted to participate in our forums or Wiki. As part of the registration process, Tripwire Interactive requests information about your date of birth to prevent children under the age of 13 from participating on our forums or Wiki (to learn more about our data collection activities with respect to children under the age of 13 click here). To register to participate in Tripwire Interactive's forums or Wiki, we will need to collect your username, email address and IP address. We collect, record and store this personal data so we can send a confirmation to the email address you provide and use that response in combination with the username and IP address to confirm that you are a real person and not a bot or some other type of spam actor, and to ensure that you do not pose a security risk. The email that we send to you when you sign up to participate on our forum(s) will ask you whether you would like to opt-in to receive notifications about private messages that occur on the forum or receive notifications about new entries for threads you may be following. We also collect, record and store your email address so that we can use it to communicate with you about any allegations of misuse and/or ban you from participation in accordance with our Forum Rules. If you no longer wish to participate in our forums or Wiki and would like Tripwire Interactive to delete the username, email address and IP address collected when you registered, please send us an email to: [email protected] with Delete Me in the subject line and we will delete the username, email address and IP address we collected when you registered for the forum and/or Wiki and that personal data will be deleted within thirty (30) days. If you are an EEA resident who wishes to make a request to delete data pursuant to Tripwire Interactive’s Right to Erasure (Right to be Forgotten) procedure please go to the Right to Erasure (Right to be Forgotten) portion of this privacy notice by clicking here.
2.2.3 Requested Direct Marketing Materials
If you want to receive direct marketing materials from Tripwire Interactive, the website may offer you the opportunity to sign up to request receipt of direct marketing materials for a particular game via the email address you submit. We collect, record and store your email address if you have requested that we contact you about new products, beta-launches, services and offerings so that we can use it to send you these communications via email. This includes signing up to pass us your email by checking the box when purchasing a product on the Epic Games Store. If you no longer wish to receive the marketing materials you initially requested, please follow the instructions contained in our marketing materials that allow users to unsubscribe from receiving these types of communications from us.
2.2.4 Requested Support
You have the option of creating an account on Tripwire Interactive's support system to track any support issues you may have. We collect, record and store your email address if you have elected to create an account on our support system so that we can use it to contact you regarding any support issues you may have. If you decide you no longer want to participate in Tripwire Interactive's support system, you can request that we cancel your account by emailing us at [email protected]. We will delete the email address we have collected and stored in connection with your support system account within thirty (30) days of receiving your request.
2.2.5 Career Opportunities & Independent Contractors
You may apply to a job posting on the "jobs" portion of our website and submitting the online application via email to [email protected]. We keep your job application materials for the period of time while we are recruiting for the particular position to which you are applying. Once the position has been filled, the successful applicant’s job application will go on file in our Human Resources department; all other candidatess job application materials will be retained for one year as required by local law and then deleted - with the exception that we may ask for your permission to retain your application on file for future opportunities, in which case you can always request that we delete it at a future date by emailing us at [email protected].
Tripwire Interactive also occasionally retains the services of independent contractors in the EEA. If you are retained as an independent contractor and you are a resident of the EEA, your contract with Tripwire Interactive will indicate the categories of personal data we must collect, record, and store to effectuate our contract with you by processing this personal data and comply with regulatory laws in the United States and the EEA. Generally speaking, the personal data we collect pursuant to our agreements with independent contractors includes your name, address, any relevant company name, relevant tax ID and payment details required to make payment and comply with applicable financial and tax regulations.
2.2.6 Server Hosts
You can volunteer to be a server host for Tripwire Interactive games without any charge. In order to get notifications about changes and updates to server-side versions of our games, you may sign up here.
If you sign up, we will collect, record and store your email address so that we can use it to communicate with you about your volunteer service as a Server Host. If you decide you no longer want such notifications, you can unsubscribe at the same URL and you will be removed immediately and your email address will be deleted immediately.
2.2.7 Contestants & Contest Winners
Tripwire Interactive occasionally holds contests announced from time to time via one of our websites, with entries usually being submitted via the Steam Workshop for the relevant Tripwire game. If you register to enter a Tripwire Interactive contest, we may collect, record and store your email address and name. If you do not win the contest we will immediately delete the email address and name you submitted for the purpose of entering the contest. If you win the contest, we will contact you at the email address you provided when registering for the contest. In the event we cannot contact you at the email address you submitted, we may attempt to reach you via messaging on Steam. If you win the contest, we will request information necessary to send you the contest prize such as your name, address, relevant tax ID and payment details required to make payment and comply with applicable financial and tax regulations.
2.2.8 Press Lists
If you are a member of the press and would like to receive press releases and, potentially, invitations to online events, you can sign up to be on our Press List by emailing your credentials to [email protected]. We collect, record and store the email address and name of anyone who elects to sign up for our Press List so that we can verify the publication that you represent and use the email address to contact you to provide press releases and/or invitations to online events. Our Press List is processed, on our behalf, by One PR Studio. If you no longer wish to receive Tripwire Interactive's press materials or another member at your publication would like to receive these materials instead, you may email [email protected] and you will be deleted from the Press List within 7 business days.
2.2.9 Tripwire Gear Store
You may purchase Tripwire Interactive related merchandise on our online store. Our store is run by our third-party partner Design by Humans and any data processing activity in connection with purchases made on our online store is described in the store Privacy Notice located here.
2.2.9 Cookies
Tripwire Interactive's websites, like most others, stores cookies on your computer. No personal data is saved in those cookies. For more information on our Cookie Policy, please read here. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:
2.3 Games Data Collection
Tripwire Interactive strives to create the best gaming experience possible. To provide an enhanced and personalized gaming experience that minimizes the interruption of bugs and service errors, prohibits and investigates fraudulent activity, and helps us determine how we can improve our games, we automatically process a range of personal data described below.
For all the personal data processing activities described in sections 2.3.1-2.3.5, Tripwire Interactive is the data controller as defined by Article 4(7) of the GDPR. This means Tripwire Interactive determines the purposes and means of the processing of the personal data. We do not delete the data we collect described in subsections 2.3.1-2.3.3 unless the law governing your personal data provides you with a right to deletion and you request to delete this data.
2.3.1 In-Game Analytic Data
We process your proprietary platform identification (SteamID, EGS ID, PSN online ID, Xbox Live ID and/or Nintendo Account) and your in-game data to allow us to analyze gameplay across the board and improve our games based on how the game is actually being played. In-game analytic data is information that includes, but is not limited to, maps played, characters played, weapons used, results of matches, heatmap information on where players died/were killed from in game and current level achieved.
2.3.2 Achievements, Player Stats
We also process your SteamID, EGS ID, PSN online ID, Xbox Live ID and/or Nintendo Account along with your Achievements/Trophies and statistics related to the level of play you achieved in a particular session and over time, weapons used, characters defeated, and various details relevant to the particular game you are playing. This data allows us to provide you with a seamless gaming experience where you can begin each game session on the highest level previously achieved and access your personal dashboard of game accomplishments and statistics from within the game.
2.3.3 Inventory of Gifts & In-Game Purchases
Your SteamID, EGS ID, PSN online ID, Xbox Live ID and/or Nintendo Account is also processed in conjunction with any in-game purchases, gifts or other game inventory you may have obtained so that there is a permanent record of your inventory acquired in the game that you can access. Tripwire Interactive partners with several third parties detailed below to maintain these inventory data, including:
2.3.4 Surveys
Tripwire Interactive occasionally creates surveys administered by Google. These surveys are placed onto the main menu of your game. You are invited to participate in the survey but your participation is entirely voluntary. If you elect to participate in a survey, we collect, record and store your email address because we use your email address to confirm that you are a real person and not a bot or some other type of spam actor. When the time period for the survey has ended, the link to the survey will be removed from the main menu of your game. Once the survey is closed to further participation, all email addresses are deleted, so that we can begin analysis of the survey.
2.3.5 Prevent Cheating
Tripwire Interactive is committed to keeping our games fair and prohibiting cheating. We partner with third party Kamu to identify and ban cheaters. Kamu’s data processing practices are described in more detail in 3.1 Kamu.
2.3.6 Crashes, Bugs & Service Errors
To identify, diagnose and correct bugs and service errors we partner with Bugsplat to log crashes and provide us with diagnostic information. If your game crashes it will request whether you want to send an error report to Bugsplat. If you choose to send the error report Bugsplat will collect, record, store and use your IP address and, optionally, your email address, so that we can process that data to analyze why the service error occurred.
For the bug-fixes, crashes and other service errors that Tripwire Interactive partners with Bugsplat to address, and which are detailed in section 2.3.6, Tripwire Interactive is the data controller and Bugsplat is the data processor as defined by Article 4(8) of the GDPR. This means Bugsplat processes the limited personal data disclosed in 2.3.6 on behalf of Tripwire Interactive to address service errors and crashes that occur in our games.
2.3.7 Digital Rights Management (DRM)
To provide DRM on some games, we partner with Denuvo to verify that each user trying to play the game has a legitimate licence to do so. The game sends data including your User ID and IP address, all of which is hashed to anonymize it and is recorded on an AWS server in the anonymized form, for future comparison to ensure that the user is indeed authorized to run the game.
For the DRM that Tripwire Interactive partners with Denuvo to address, and which is detailed in section 2.3.7, Tripwire Interactive is the data controller and Denuvo is the data processor as defined by Article 4(8) of the GDPR. This means Denuvo processes the anonymized personal data disclosed in 2.3.7 on behalf of Tripwire Interactive to provide DRM to users of our games. This data will be erased when Denuvo has no further legal/contractual obligation to store the data longer.
2.3.8 In-Game VOIP
To provide in-game VOIP on some games, we partner with Vivox to provide VOIP servers and services. The game sends your platform ID to Vivox, which is used to create a non-identifying, unique Vivox user ID, which is generated per user, so that no personally identifiable information is stored.
We partner with several third parties to provide our games and services to you. These third parties and their role in processing your personal data is described in detail below.
3.1 Kamu
Tripwire Interactive partners with Kamu (formerly Easy AntiCheat) to identify cheaters and ban them from our games and services. Kamu must process your Username and account identifier, in-game analytic data and achievement statistics, technical information about the hardware used to play the Game, such as motherboard manufacturer, CPU identifier, GPU identifier, and general performance indicators, technical information about the methods, technics, technologies or alike used in our games that may be suspected to indicate the use of methods that are considered unacceptable by Tripwire Interactive, and/or other equivalent information. Kamu processes this data as part of its anti-cheating technology that helps keep our games free from cheaters and fraudulent activity. Kamu cannot delete the personal data and non-personal data it collects in order to prevent any future or further cheating or fraudulent activity. For more information about Kamu’s data processing activities, go to: https://www.easy.ac/en-us/support/rs2/account/privacy/.
3.2 Platform Partners: Valve, Sony, Microsoft, Epic & Oculus
Our games are available on platforms developed by Valve (Steam), Sony (PlayStation), Microsoft Microsoft (Xbox and Gamepass), Epic (via Epic Online Services [EOS]), Nintendo (Switch) and Oculus (collectively, "Platform Partners"). Tripwire Interactive’s Platform Partners process your SteamID, EGS ID, PSN online ID, Xbox Live ID and/or Nintendo Account to keep track of your Achievements/Trophies and statistics related to the level of play you achieved in a particular session and over time (as described above), and maintain a record of your in-game inventory purchases or gifts (as described above).
Some Platform Partners (specifically Valve, Epic and Oculus) also collect summary data related to players’ usage of their systems, including games played, time spent playing each game and country you reside in. Platform Partners do not collect any personally identifiable information/personal data, instead anonymizing the data. They use this data to provide us with summary information such as Peak Concurrent Users, Daily/Weekly/Monthly Actual Users, Average and Total Minutes Played.
3.3 Playfab
In-Game inventory data for items purchased, won or gifted are maintained in the Playfab service, for non-Steam platforms. Playfab processes your EGS ID, PSN online ID, Xbox Live ID and/or Nintendo Account to maintain a record of your in-game inventory purchases or gifts (as described above).
3.4 Bugsplat
As described above, Bugsplat is a Tripwire Interactive partner that helps us analyze crashes, bugs and other interruptions of service that may occur on our games. If you experience a service interruption while playing one of our games, you will receive a notice from Bugsplat that asks whether you would like to send an error report to Bugsplat and advising you that Bugsplat must process your IP address in order to capture the error report, and Bugsplat will ask you if you would like to submit your email address. Bugsplat provides us with diagnostic information about service interruptions, and the IP address and email address collected that you have elected to disclose when you receive the error notice from Bugsplat. We use this information to help us analyze why the service interruption occurred and attempt to avoid similar crashes in the future.
3.5 Denuvo
As described above , Denuvo is a Tripwire Interactive partner that provides Digital Rights Management (DRM) software, used in some of our games. As stated above, the data is anonymized before being sent and cannot be read or decrypted by Denuvo or Tripwire Interactive in any way. The data is stored on AWS servers, fully-compliant with GDPR and protected by the EU-US privacy shield. Please see Section 5 for information and current views on Privacy Shield.
3.6 Vivox
As described above, Vivox is a Tripwire Interactive partner that provides in-game VOIP services, used in some of our games. As stated above, no personally identifiable information is stored.
3.7 Mailchimp
Tripwire Interactive partners with Mailchimp to manage and provide email services related to requests for marketing materials and requests to join our Press Lists. Mailchimp processes your email address if you sign up for these features. If you decide you no longer want to receive marketing materials or be on our Press List, follow the directs to unsubscribe at the bottom of any of our emails to you.
3.8 Design By Humans
As described above, Tripwire Interactive’s online store is run by our partner Design By Humans. Any data processing activity in connection with purchases made on our online store is described in the store Privacy Notice located here.
3.9 One PR Studio
As described above, Tripwire Interactive’s main Press List is managed by our partner One PR Studio. One PR Studio processes your email address if you sign up for our Press List. If you no longer wish to receive Tripwire Interactive's press materials or another member at your publication would like to receive these materials instead, you may email [email protected] and you will be deleted from the Press List within 7 business days.
Personal data processed by Tripwire Interactive is processed and stored by Tripwire Interactive in the United States. Tripwire Interactive uses reasonable physical, technical and administrative measures to safeguard all personal data it processes and prevent unauthorized access and disclosure of any personal data. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal information that we process. You acknowledge that Tripwire Interactive processes your personal data at your own risk.
5.1 Tripwire Privacy Shield Participation
Tripwire Interactive participates in and has certified its compliance with both the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union, European Economic Area, the United Kingdom, and Switzerland. We have certified that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, redress and enforcement (the "Privacy Shield Principles"). By adhering to the Privacy Shield Principles and registering with the U.S. Department of Commerce Privacy Shield, Tripwire Interactive agrees to subject its compliance to the regulatory enforcement of the Federal Trade Commission ("FTC") or any other statutory body empowered to enforce compliance with the Principles. To learn more about the Privacy Shield program, and to view Tripwire Interactive’s certification, please visit http://www.privacyshield.gov. Tripwire Interactive is responsible for the processing of personal data it receives, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. Tripwire Interactive complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the U.K. and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Tripwire Interactive is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Tripwire Interactive may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
5.2 Invalidation of Privacy Shield by the EU Court (Grand Chamber)
In a judgement dated 16 July 2020 in Case C311/18, the EU Court stated that Privacy Shield is not an adequate protection and should not be considered as such. Until such time as a clear alternative becomes available, Tripwire Interactive will adhere, where possible and legally permissible, to the current principles under the Privacy Shield Framework.
6.1 Disputes Generally
We take your privacy concerns seriously. If you believe that Tripwire Interactive has not adhered to this Privacy Policy, please contact us by sending an email to: [email protected] with the subject line: Privacy Concern. In your email, please describe in as much detail as possible the ways in which you believe that this Privacy Notice has not been complied with. We will respond to you within 45 days of receipt of your email and will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
6.2 Dispute Resolution
In compliance with the Privacy Shield Principles, Tripwire Interactive commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Tripwire Interactive at: [email protected] with the subject line: Privacy Complaint.
Tripwire Interactive has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of this independent recourse mechanism by which your complaints and disputes can be investigated and expeditiously resolved will be provided at no cost to you.
Tripwire Interactive commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
EU citizens may report privacy complaints directly to their local Data Protection Authorities. Swiss citizens may report privacy complaints directly to the Swiss Federal Data Protection and Information Commissioner. You may also contact us to be directed to the relevant contacts by emailing us at [email protected] with the subject line: Data Protection Authority for EEA Residents.
As a Privacy Shield participant, Tripwire Interactive commits to binding arbitration at the request of an individual to address any complaint relating to our Privacy Notice or our information practices that has not been resolved by other recourse and enforcement mechanisms.
7.1 Requests from Law Enforcement & National Security Issues
Tripwire Interactive may disclose information we have about you (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement authorities or other government officials, including to meet national security requirements, or (iii) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or illegal activity.
7.2 Service Providers
As noted throughout this Privacy Notice, Tripwire Interactive may employ others to facilitate the website and related business functions (“Service Providers”), provide services on our behalf, perform service-related business activities, or assist us in analyzing how the website is used. These Service Providers provide us support services such as credit card processing, website hosting, email and postal delivery, analytics, marketing services, security and fraud prevention. The Service Providers have access to your personal information only to perform these tasks on Tripwire Interactive’s behalf and are obligated not to disclose or use it for any other purpose. The Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
7.3 Corporate Transactions
We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our website users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information.
Tripwire Interactive adheres to the Children’s Online Privacy Protection Act (“COPPA”) and does not knowingly collect personal data from children under the age of 16.
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that Tripwire Interactive collects, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties with whom we may share the Personal Information.
We generally collect the following categories of Personal Information about you when you use the website, our games or services:
We generally do not collect the following categories of Personal Information about you:
For more information about the Personal Information we collect, how we collect it and details of which data, under different circumstances, please refer to sections 2 and 3 above.
We collect your Personal Information for the business purposes described in sections 2 and 3 above, including for analytics, to support your use of our forums, to provide you requested marketing materials or customer support, to store cookies, and to ensure the integrity of the website and related services. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in sections 2, 3 and 7 above, and include our website, marketing, analytics, and security service providers, and law enforcement authorities when required to do so.
Privacy Rights
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems. To assert your right to know or your right to delete your Personal Information, please contact us according to the “Contact Us” section below. To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud- prevention purposes.
Under California Civil Code Section 1798.83 (also known as the "Shine the Light" law), Tripwire Interactive customers who are residents of California may request certain information about Tripwire Interactive disclosure of personal data during the prior calendar year to third parties. If you are a California resident and wish to make this request, please send an email to [email protected] with California Shine the Light in the subject line. You may also request this information by mail at: Tripwire Interactive ATTN: Privacy Management, Tripwire Interactive, 1775 Woodstock Road, Suite 100, Roswell, Georgia 30075.
In addition, if you are a California resident between the age of 13 and 18 and are a registered user on the Tripwire Interactive Forum or Wiki (or participate on our blogs), you may request that we remove content or information about you that you posted by (a) submitting a request in writing to [email protected] with the subject: California SB 568, and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that you cannot be individually identified; (iv) you do not follow the instructions posted in this Privacy Notice on how to request removal of your content or information; or (v) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain the applicable content or information.
10.1 General Description
For purposes of this Privacy Notice we define the EEA to include any EU member state, the European Economic Area ("EEA"), the United Kingdom, or Switzerland. EEA Residents includes any data subject located in the EEA at the time of personal data collection. EEA Residents have certain rights concerning the processing of their personal data under the GDPR. This portion of our Privacy Notice advises EEA Residents of the applicable GDPR rights (often called "data subject rights"), and how to effectuate these rights by communicating with us. If you are not an EEA Resident, this section of the Privacy Notice does not apply to you.
10.2 Legal Basis for Processing Personal Data
Tripwire Interactive has a legitimate interest in providing its users with a state of the art gaming experience and to allow users to participate on our forums & blogs, enter contests, complete surveys and other voluntary pursuits at the specific direction and choice of the user, without risk of fraudulent activity and with a minimum of service interruptions caused by bugs or other system failures. In providing our website, games and other services to our users we aim to collect the minimum amount of personal data necessary to achieve these goals. The lawful basis for processing an EEA Resident’s personal data is the legitimate interests grounds described under Article 6(f) of the GDPR.
10.3 Right of Access
EEA residents have the right to obtain from Tripwire Interactive the confirmation as to whether or not personal data concerning him or her are being processed. EEA residents may request access to the following information:
This Privacy Notice advises you as to the details of the personal data Tripwire Interactive is processing.
If you need additional confirmation concerning the personal data Tripwire Interactive is processing you may request confirmation by sending an email to [email protected] with Right of Access in the subject line.
The right to access is described under Article 15 of the GDPR.
10.4 Right to Rectification
EEA residents have the right to request that Tripwire Interactive correct or “rectify” any inaccurate personal data concerning him or her.
If an EEA resident believes Tripwire Interactive has inaccurate or incomplete personal data, he or she may request rectification by sending an email to [email protected]ß with Right To Rectification in the subject line. Tripwire Interactive will ensure any inaccurate or incomplete data is corrected within thirty (30) days of receiving your email request.
The right to rectification is described under Article 16 of the GDPR.
10.5 Right to Erasure (Right to be Forgotten)
EEA residents have the right to request that Tripwire Interactive erase/delete personal data concerning him or her without undue delay. Tripwire Interactive shall have the obligation to erase personal data without undue delay under the following circumstances:
If one of the aforementioned circumstances applies, and an EEA resident wishes to request the erasure of personal data stored by Tripwire Interactive, he or she may request erasure/deletion by sending an email to [email protected] with Right To Be Forgotten in the subject line.Tripwire Interactive will comply with the erasure/deletion request within thirty (30) days of receiving your email request.
The right to erasure is described under Article 17 of the GDPR.
Right of Restriction of Processing
EEA residents have the right to restrict Tripwire’s processing of personal data if one of the following circumstances applies:
Where processing has been restricted because the accuracy of the personal data is contested by the EEA resident, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
Tripwire Interactive will inform any EEA resident who has obtained restriction of processing because the accuracy of the personal data is contested by the EEA resident before the restriction of processing is lifted.
The right to restriction of processing is described under Article 18 of the GDPR.
10.7 Right to Object
EEA residents have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on Tripwire Interactive’s legitimate interest grounds for lawful data processing under Article 6(1)(f) of the GDPR and described throughout section 2 of this Privacy Notice.
If you are an EEA resident and object to the processing of your personal data, please notify us by sending an email to [email protected] with Right to Object to Processing in the subject line and Tripwire Interactive will no longer process the personal data if we cannot demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. The right to object is described under Article 21 of the GDPR.
10.8 Right to Data Portability
The right to data portability is available when the data processing activity is based on consent under Article 6(1)(a) or Article 9(2)(a) or when the data processing is necessary for the performance of a contract under Article 6(1)(b). There are not any data processing activities that occur based on any of these circumstances, so EEA residents have no right to data portability when accessing or using any of our games, websites or other services.
The right to data portability is described under Article 20 of the GDPR.
10.9 Right to Lodge a Complaint with a Supervisory Authority
If you believe that Tripwire Interactive processing of personal data infringes the GDPR, please contact us by sending an email to: [email protected] with the subject line: EEA Privacy Concern so that we can address your concerns. As described in Section 6, EEA Residents are entitled to lodge a complaint via JAMS at https://www.jamsadr.com/contact class or by visiting the website at https://www.jamsadr.com/eu-us-privacy-shield. In addition, as an EEA Resident you have the right to lodge a complaint with the relevant data protection authority where you live or work, or in the place where the alleged breach of data protection law has taken place if you believe our processing of personal data infringes the GDPR. The right to lodge a complaint is described under Article 77 of the GDPR.
From time to time Tripwire Interactive may need to modify this Privacy Notice to reflect changes in our business practices, data collection practices or processing activities. We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on our websites and games. It is strongly recommended to check our websites often, referring to the date of the last modification listed at the top. If we change the Privacy Notice in material way that adversely impacts your privacy rights, we will post a notice on our website and may send you an email notifying you of the change, if you have provided your email address to us. If you do not agree to the changes made in any amended Privacy Notice, you should discontinue your use of our website, service and games, and stop providing personal data to us prior to the time the modified Privacy Notice takes effect. If you continue using our website, services or games and provide personal data to us after the modified Privacy Notice takes effect, you will be bound by the modified Privacy Notice.
We welcome your questions and comments about Tripwire Interactive’s privacy practices. You may contact us anytime via our website located at https://www.tripwireinteractive.com/#/company, by email at [email protected], or as follows:
Tripwire Interactive
ATTN: Privacy Management
1775 Woodstock Road,
Suite 100 Roswell, Georgia 30075
