Privacy Policy

Eddie's Social Club, LLC ("ESC") is a social gaming platform. Your privacy is important to us; this is why we created this Privacy Policy so that you are aware of what information is collected, how we use it, and who we share it with.

1. About this Privacy Policy

This Privacy Policy covers our websites on the esc.games domain, and our other websites, products, software, applications, content, data feeds and other services ("Service") on which an authorized link to this privacy policy is posted. The Service is operated by or on behalf of Eddie's Social Club, LLC.

If you have any questions, comments, or concerns regarding this Privacy Policy and/or data practices, please contact us at the following e-mail address, telephone number, or mailing address:

[email protected]
(212) 253-7131
ESC Games
Contact person ESC Privacy Manager
Address: 9 East 19th St Floor 8
New York, NY, 10003

2. Definitions

"Personal data" means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.

"Processing" means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.

Any other capitalized term that is not defined in this Policy is defined (and has the meaning) set out in our Terms of Use.

3. Setting Up an Account and Profile on ESC

Account and Profile Creation

ESC users may play as "guests" by creating an ESC account; in guest mode, users remain anonymous in their interactions within the Service and games, and do not have access to chat features, cannot use the personal messaging platform, cannot post to the forums or groups, and are subject to other restrictions (a) determined by ESC from time to time and (b) designed to prevent users from sharing personal data, whether intentionally or otherwise. As guests, users are unable to save play statistics, accumulate points, share models, create games, or participate in the ESC virtual economy.

Profile Creation

Users who want to save play statistics, and participate in the ESC virtual economy must create a profile on ESC. To create an ESC profile, we will ask you for your email address and to create a unique username and password (so you can log in to your account), and to provide other demographic information such as your age or date of birth, gender, country or language preference (so we can customize your experience on ESC).

Users should not create a username that reflects their own name or other personal data. Your username and if you choose to disclose it, your real name, will be published publicly. Once published your username and / or real name may not be able to be removed, but you can change your username at any time. Users should also not pick a password that is easy to guess, and should not share their password. For security reasons, we store passwords in encrypted form.

Usernames are used for participating in Service features. Usernames are not passed along to third-party companies except for our third-party service providers who use or process the usernames for purposes of helping operate our Service, such as effectuating payments, debug or crash reporting and website hosting.

Users must provide an email address for account creation. Users may change the email address associated with their account at any time; however, a notification will be sent to the previously provided email address upon making that change. ESC may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

4. Additional Features and Data Collection on ESC

In addition to account setup on ESC, we may collect and process information from you in connection with the following features and activities (as applicable):

  • When you post or otherwise transmit comments or messages on ESC via community features such as public chat or private chat, forums, group walls, personal posts, etc.we may collect these comments and messages, and they may be monitored, filtered and moderated for purposes such as removal of profanity, personal data, and other inappropriate conversations. We may use pre-filtered chat, comments and messages for purposes such as training and improving our filter technology, except that we will not engage in these activities with private chat, comments, and messages of EU users.
  • When you contact or send communications to ESC, for example when you contact customer support, report a problem, or submit questions, concerns, or comments regarding our Service or its content, in which case we may collect contact information such as your email address and other important information about your inquiry or concern. This information is used to respond to your communications, fulfill your requests, or provide other customer support.
  • When you use or interact with third-party plug-ins that may be available on the Service for users 13 and older, such as third-party social media widgets, share buttons, and/or login mechanisms. These features may include social plugins from Google, Facebook, Twitter or other platforms, and may be subject to the privacy policies of these other companies as posted on their respective websites. When you use these features, certain information from your social media accounts may be accessed by or shared with ESC, and likewise, certain information about your use of ESC may be posted to your profile on those platforms.
  • When you participate in contests, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. These promotions may involve the collection and use of certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion.
  • When you respond to or participate in voluntary surveys, which we may offer on our Service from time to time to conduct research or demographic studies. These surveys may collect anonymous information about your likes and dislikes, game play interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys will not collect personal data about you, unless otherwise clearly stated in such survey.
  • When you request or agree to location-based services from ESC, which may be available to our users. We may collect or track real-time or precise geolocation information to provide services such as tagging, check-in and content delivery, targeted or geo-based advertising, or other services that are dependent on knowing where you are. This information may be collected in combination with an identifier associated with your device to enable us to recognize your mobile browser or device when you return to the Service. You can always stop the collection of location information by updating your device settings, stopping to use the Service, and/or un-installing our mobile applications.
  • When you subscribe to other features or activities that we may offer from time to time on the Service and submit or upload information in connection with such features.
  • When you browse, navigate, or otherwise interact with the Service, as outlined in the "Cookies and Similar Technologies" section below.

You are under no obligation to provide personal data to ESC when requested. However, if you choose to withhold any requested information, we may not be able to provide you with certain services and features.

In addition to the specific uses above, any information that you provide or that we collect on the Service may be generally used for the following purposes:

  • To operate, maintain, and improve the Service;
  • To give you access to the Service and related features, or restrict your access;
  • To personalize the Service or content on the Service, as well as make it more user-friendly;
  • To allow you to manage your ESC account or account information, update your account settings, and (where applicable) make purchases or subscribe to services;
  • To communicate with you about the Service (product changes, feature updates, etc.);
  • To provide technical support or customer service;
  • To deliver advertising that may be relevant to your interests;
  • To protect the integrity, safety, or security of the Service or our users, comply with legal obligations, or enforce compliance with our Terms of Service or other restrictions placed on your use of the Service.

5. Cookies and Similar Technologies

Like most websites, we use cookies and other standard Internet technologies to help us improve our Service.

Cookies

A cookie is a small text file that is placed on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, for example so you don't have to re-enter them whenever you come back to the website or browse from one page to another.

A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

  • Session cookie which is erased when the user closes the browser; or
  • Persistent cookie which remains on the user's computer/device for a pre-defined period of time.

As for the domain to which it belongs, there are either:

  • >First-party cookies which are set by the web server of the visited page and share the same domain (in this case ESC.GAMES domain); or
  • Third-party cookies stored by a different domain to the visited page's domain. This can happen when the webpage references a file, such as JavaScript, located outside its domain.

How we use cookies

When you visit or access the Service, we may – by means of cookies, beacons, tags, scripts, and/or other similar technologies – automatically collect technical information about the devices and software you use to access the Service, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Service, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information. These same technologies (or a combination of them) may also be used to help us:

  • Capture and store users' preferences, account settings, and certain login information (mainly for convenience, user verification, and account security);
  • Compile statistics and analytics about your use of and interaction with the Service, including details about how and where our Service is downloaded from or accessed, how often a user visits or uses the Service, the date and time of user visits to, and actions on, the Service, which areas of the Service are visited and for how long, information regarding in-game activities, and other similar traffic, usage, and trend data;
  • Mobile analytic tools to allow us to better understand the functionality of our mobile software on your device and gain insights about how mobile software is used;
  • Gather important functionality, testing, and performance data about our Service, such as networking activity, CPU load, and resource usage, among other relevant data;
  • Moderate user behavior on the Service, such as protecting against payment fraud and other inappropriate activities;
  • Gather demographic information about our user base; and;
  • Perform other similar functions

We will not use cookies or similar technology other than for the purposes stated in this Cookie Policy.

Your choices

Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set.

Some browser manufacturers provide comprehensive help relating to cookie management in their products. Please see below for more information:

  • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB,
  • Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies,
  • Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer,
  • Safari (Desktop): https://support.apple.com/kb/PH5042?locale=en_US,
  • Safari (Mobile): https://support.apple.com/en-us/HT201265,
  • Android Browser: https://support.google.com/nexus/answer/54068?visit_id=0-636612941590933601-131731679&hl=en&rd=1, and
  • Opera: https://www.opera.com/help.

You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block or delete cookies that are already on your computer.

Please note, however, that by blocking or deleting cookies used on the Service, you may not be able to take full advantage of the Service and you may not be able to log on to the Service or play the ESC games.

6. Information Sharing

ESC may share your information as set forth below.

Agents and contractors

ESC may share users' information, including personal data like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on ESC's behalf. These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third-party service providers and the names of the providers we may use to perform these functions:

  • Analytics services (e.g., Google Inc, comScore, Flurry Analytics);
  • Advertising services (e.g., AppsFlyer);
  • Community filtering and moderation services (e.g., CommunitySift);
  • Customer support services (e.g., Zendesk);
  • Surveys and promotions (e.g., Magid);
  • Billing services and payment gateway providers (e.g., Kount, Stripe, SiftScience, PayPal, Vantiv, Incomm, Rixty, Google, Apple, Amazon, Windows Store); and
  • Hosting and content delivery network services (e.g., AWS, Equinix, CenturyLink).

These agents and contractors are only allowed to use the information shared with them only for the specific tasks they've been hired to do and consistent with this Privacy Policy, and for no other purposes. ESC takes steps to ensure that all service providers with access to personal data are capable of protecting the information we share with them.

Legal disclosures

We may disclose personal data about you as required or permitted by law and/or comply with a judicial proceeding, court order, or legal process served on our Service. To the extent permitted by applicable law, we also may disclose personal data about you in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services) or if such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our Service, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.

Business transfers

Information about our users, including personal data, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Where necessary, we will inform you of such disclosure and obtain your consent.

Anonymized information

We share aggregated, automatically-collected, or otherwise non-personal data with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users' interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the Services. We do not share personal data about you in this case.

7. Security and Data Retention

Security

The security of your personal data is important to us. When you enter sensitive information (such as credit card numbers) on our order forms, ESC (or the service provider operating the function on our behalf) will encrypt that information using transport layer security (TLS) or similar technologies. We have security measures in place to attempt to protect the personal or other sensitive information submitted to us against the loss, misuse and alteration of personal data under our control. While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use reasonable efforts to prevent it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Service, such as social networks. ESC is not responsible for the functionality or security measures of any third party.

Retention

ESC may retain users' account data internally for the following purposes:

  • Billing information and transaction histories are retained to resolve subsequent billing disputes and inquiries;
  • Publicly shared content and game items are retained for use by the community;
  • User account history is retained to support subsequent customer service inquiries and to provide, improve and develop the Services;
  • To promote safety and security on and for the Services; and
  • To comply with legal obligations.

We may retain your information for as long as is necessary and relevant to your use of the Service and our operations, which may include retaining your information beyond the end of your use of the Service.

Compromise of information:

In the event that any information under our control is compromised as a result of a breach of security, ESC will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. External links

Our Service may, from time to time, contain links to external sites or applications. We are not responsible for the privacy policies or the content of such sites or applications. To make clear when you are linking to a third-party site or application, we may display a warning message informing you when you are leaving our Service.

9. Children's Privacy and Parental Controls

In order to use the Service and access the ESC content, you need to (1) be 18 or older, or be 13 or older and have your parent or guardian's consent to the Agreements, (2) have the power to enter a binding contract with us and not be barred from doing so under any applicable laws, and (3) be resident in the United States. You also promise that any registration information that you submit to ESC is true, accurate, and complete, and you agree to keep it that way at all times.

ESC does not direct its websites, games, game engines, or applications to children under the age of 13. We also do not intentionally collect personal information from children through our websites, games, game engines, or applications. If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us and we will delete the information from our records.

10. Accessing and Updating Your Personal Data

If personal data about you changes, or if you no longer desire to use our Service, you may correct, update, amend, or deactivate your account under your account settings or by contacting ESC using the information set out above in Sec. 1. We will respond to your request within a reasonable timeframe.

11. Storage and International Transfer of Your Personal Data

ESC is based in the U.S. Your personal data which we collect are sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information.

ESC operates globally and we may transfer the personal data that we collect from you to our other offices and/or to the third parties mentioned in the circumstances described above (see "Information Sharing"), which may be situated outside of your country or regional area, and may be processed by staff operating outside your country or regional area. In particular, information provided to us or collected by us likely will be transferred to and processed in the United States by us or our agents and contractors. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence. Wherever we transfer your personal data, we will take reasonable steps to ensure that your privacy rights continue to be protected.

12. Privacy Policy Changes and Updates

We may update this Privacy Policy to reflect changes to our information practices at any time, so please review it frequently. If we update this Policy, changes will be reflected on this page and we will update the "Last Updated" date posted below. If we make any material changes to this Privacy Policy, we will attempt to notify you by email (by sending an email to the email address specified in your account, if an email account is associated with your account), or by means of a prominent notice on this website prior to the change becoming effective.

13. Consent

By using our website, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.

Last Updated: August 9, 2018