California Consumer Data Rights

thatgamecompany complies with the California Consumer Privacy Act of 2018 (CCPA), effective January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.

Categories of Data we Collect and their Uses

In addition to the details provided in Section 4 of our Privacy Policy, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

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Personal information does not include:
  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
  • Directly from our end users. For example, from customers who engage us for customer support or to provide customer feedback.
  • Indirectly from our end users. For example, through information we collect from our end users in the course of providing customer support to them.
  • Directly and indirectly from activity on our website or in our games. For example, from APIs and cookies (described above) embedded in our website or games to measure game metrics and progress, play time per level, and other information related to improving our products.
  • From third-parties that interact with us in connection with the services we perform. For example, from third party analytics or anti-cheat providers, or to ad mediators for the purpose of providing personalized advertising and marketing customized to you.
All such Personal Information is used as otherwise described in Section 5 of our Privacy Policy. 
 

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
 
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
 
Identifiers and Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:
  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
  • Our vendors.

Your Rights and Choices 

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
 
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
 
We generally do not sell our player data. However, if we do sell your personal information for a business purpose, we will also disclose to you:
 
  • The personal information that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
 
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
 
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
 
  • Complete any transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products, including our website and games, to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
 
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
 
By phone: 1-310-453-4906
By mail: 1520 Cloverfield Blvd. Suite D, Santa Monica CA, 90404
 
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
 
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
 
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
 
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
 
Response Timing and Format
 
We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
 
Non-Discrimination
 
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.