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Privacy Policy

City of Heroes: Homecoming - Privacy Policy

City of Heroes: Homecoming - Privacy Policy

Last updated on January 9th 2020
A quick summary: this document explains:
  • a) what information we and our partners collect when you use Homecoming's games and services;
  • b) where that information is stored and how it is protected;
  • c) how we use that information;
  • d) how long we retain that information; and
  • e) your rights in relation to that information.

This Privacy Policy explains to you how your personal information is collected and stored and what happens to it regarding the City of Heroes Services. Because we know legal wording is not much fun, we have included a short and informal summary of each section (but the full version is the legally binding one). If you have any queries you can contact us via a private support ticket at https://cohhc.gg/support.

1. WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS

This Privacy Policy explains the different kinds of information Homecoming Servers can collect from you when you're using the City of Heroes Services. Legally, we cannot and will not collect personal information about children below 13 without parental/guardian involvement. We will comply with applicable privacy laws, including the EU's GDPR and the US' COPPA.

1.1. About Us. We are Homecoming Servers LLC (incorporated and registered in the state of Delaware with filing number 7407345) of 7283 NC HWY 42 W, STE 102-197, Raleigh, North Carolina 27603, USA as well as the Homecoming group of companies (“Homecoming Servers”).

1.2. Which services does this Privacy Policy apply to? Our servers which run ‘City of Heroes: Homecoming’, our websites, user accounts, customer and technical support, forums, wikis, blogs, social media services and other products and services - “City of Heroes Services” for short.

1.3. What information does this Privacy Policy apply to? Specifically, this Privacy Policy governs personal data (or, in the USA, personally identifiable information) and applicable non-personal information (or, in the USA, non-personally identifiable information), which we collect from you when you are using the City of Heroes Services ("personal data" means information which, on its own or in combination with other information, can be used to identify you).

1.4. What about children? We recognise we have a special obligation to protect personal information obtained from children. Legally you must be at least 13 years old to use the City of Heroes Services (but this might be older depending on whether or not a particular City of Heroes Service has a required minimum age rating) as per our User Agreement. We do not knowingly collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact us via a private support ticket at https://cohhc.gg/support.

1.5. What about GDPR? We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal information contained in this Privacy Policy which is used by Homecoming Servers in connection with the City of Heroes Services, Homecoming Servers is the data controller under EU data protection legislation.

2. WHAT INFORMATION IS COVERED?

We may collect certain information when you use the City of Heroes Services such as your name and email address (more information below). We do not receive or store your payment details.

2.1. What information might we collect from you? When you sign up for, download, use or play the City of Heroes Services then we will collect certain information from you. The information that we collect varies depending on the particular City of Heroes Services used, but this may include:

A. Technical Details. When you use, play or access the City of Heroes Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any console device identifier; your operating system, browser type or other software; and your hardware or other technical details.

B. Your Activities. When you use, play or access the City of Heroes Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences; chat-logs; friends lists; achievements; scores; gameplay statistics; time spent playing.

C. Your Communications. If you contact us (e.g. via email or call for customer support) or post in chat sessions, forums, on our social media pages, or other areas of the City of Heroes Services, we may collect and maintain a record of your contact details and the content of your communications.

D. User Accounts. To access certain City of Heroes Services (e.g. games or forums) you may need to create a user account. Or if you sign up to a newsletter, you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable City of Heroes Services (e.g. when you sign up for a newsletter) and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.

Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.

2.2. What about the storage of payment details? The processing and storage of payment details is a matter for the relevant platform and the applicable payment methods/processors. Homecoming Servers will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g. PayPal) via the user account you have associated with that platform account.

2.3. What about cookies? We and third parties on our behalf also collect information about you via cookies and other advertising tracking technologies.

3. WHERE IS YOUR INFORMATION STORED?

Your data will be held on servers located in Canada or Germany. We will do our best to keep this information secure. No information security system is perfect so please remember to be careful.

Where will your information be stored? The information we hold will primarily be stored and processed in Canada and Germany. All information we hold is stored on our secure servers which we own or license from appropriate third parties. We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.

4. HOW IS YOUR INFORMATION USED?

We will use your information to run, maintain and improve the City of Heroes Services as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may share information with partners in order to run our services.

4.1. How might your information be used? We may use the information above in order to (for example):

A. Perform our agreement with you: provide the City of Heroes Services to you, including: to carry out our obligations arising from any contracts between you and us; allow you to participate in interactive features of the City of Heroes Services when you choose to do so; and provide you with chat functionality and other communication systems.

B. For our legitimate interests: monitor the performance of the City of Heroes Services; ensure that the City of Heroes Services are presented in the most effective manner for you and your device(s); for analytics purposes; enforce our User Agreement and other policies; notify you about changes to the City of Heroes Services; provide, maintain, protect and improve the City of Heroes Services; and to protect Homecoming Servers and City of Heroes Services users.

C. Comply with our legal obligations: where we are required to do so by law; and comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.

D. Based on consent: when you upload a crash report to us; if you choose to enable data logging in-game; provide you with marketing information about products or services that you request from us or which we feel may interest you where you have asked us to do so.

4.2. Will we ever share any of your information with other parties?

A. We will never share your information with third parties for their own marketing purposes without first obtaining your consent.

B. We may engage third party service providers in the course of providing the City of Heroes Services to you (e.g. data storage, server hosting, customer and technical support, game analytics etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.

C. We may share your information within the Homecoming Servers company group for the purpose of providing the City of Heroes Services.

D. In the event of a reorganisation or merger of Homecoming Servers we may transfer personal information to an involved third party who will protect this to at least the same level as we do in this Privacy Policy.

5. HOW YOU USE YOUR INFORMATION AND THIRD PARTIES?

You have the option to share your own personal information with other parties, in which case it will be governed by those parties' own privacy policies – make sure to take a look at them.

Please remember that any communications you have via the City of Heroes Services may reveal details about you. Also, any information you post publicly will be publicly available to other people. We are not responsible for your use of any otherwise private personal information which you make available, or the activities of other users or other third parties to whom you give or make available your information or content. The City of Heroes Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.

6. DATA RETENTION

We retain your information for as long as needed to provide the City of Heroes Services to you or longer where permitted by law.

How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. For any data received in relation to crash reports or data logging, we hold this information for up to 30 days. For any chat-logs, we hold this information for up to 30 days (unless they are part of an ongoing support request, in which case the relevant chat log will be deleted once the request is closed).

As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all City of Heroes Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.

7. YOUR RIGHTS

You have rights about how your personal information is used, which can vary depending on where you live. If you have any questions, please contact us via a private support ticket at https://cohhc.gg/support.

7.1. Can you ask us to stop processing your personal information? You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications.

7.2. What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the GDPR), you have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain City of Heroes Services may no longer function properly or may be completely unavailable to you (even services that you have paid to use).

7.3. Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Homecoming Servers LLC at 27283 NC HWY 42 W, STE 102-197, Raleigh, North Carolina 27603, USA. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.

7.4. Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact us via a private support ticket at https://cohhc.gg/support.

8. OTHER

We can change this Privacy Policy, but if we do we will put the changed version online. Please feel free to contact us if you have any questions with regards to the changes via a private support ticket at https://cohhc.gg/support. Please read our User Agreement at https://cohhc.gg/user-agreement.

8.1. Will we ever change this Privacy Policy? Possibly, but if we do we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on you as of the date of publication (i.e. the new “Last Updated” date). You are welcome to contact us if you have specific questions about the changes, you can contact us via a private support ticket at https://cohhc.gg/support. If you do not agree to those changes, regardless of whether you email us, then unfortunately you must cease using all City of Heroes Services.

8.2. Are there any other documents you should read? We'd also like to remind you that our User Agreement has more information about how we operate the City of Heroes Services (https://cohhc.gg/user-agreement).

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