ArenaNet Privacy Policy

We at ArenaNet work hard to provide high quality gaming experiences. With so many individuals logging into and connecting through our games, we understand the importance of your privacy. Maintaining your privacy and the trust of our users is important to us. We may store, process, and, under certain circumstances share your information, to provide you Services.

Throughout this Privacy Policy we refer to “Services,” which means our websites, games, surveys, promotions, contests, purchases, community support, and related activities.

I. What does this Privacy Policy contain?

This Privacy Policy explains how we collect, use, protect, and store your Personal Information and how we respect applicable data protection laws. Other service providers and websites, including those we may link, may have their own privacy policies. If you have questions about how other websites, services, or games handle your Personal Information, you should review their privacy policies.

By using or accessing our Services, you are consenting to this Privacy Policy. You are also confirming that you understand English (or, in some cases French, German, or Spanish) well enough to understand it.

II. What types of information does ArenaNet collect?

Personal and Account

We may collect two types of information from you. “Personal information” is information that would allow someone to identify or contact an individual. “Account Information” is all other information and may include combined information that does not identify an individual, but may be associated with an individual’s user account. We use this information for internal purposes like improving the site or customizing content.

Examples of Personal Information

Examples of Account Information

• Full name

• Date of birth

• Email address

• IP address, device ID, MAC address

• Phone number, street address

• Social media account (Twitter handle, Facebook account, etc.), Steam ID

• Credit card information, bank information through our third party payment processors

• In-game ID, character name, gameplay history

• Account identification number

• Purchase and account history

• Computer operating system, system specifications, game file version

• Mobile OS Version

• Internet browser type

• Your “click path” through our websites

• The advertisement or link that brought you to our website

III. Where does ArenaNet collect Personal Information?

You

You provide Personal Information directly to us through the Services, for example when you:

Register for an account, or a contest or giveaway
Submit additional information on the account page
Complete questionnaires
Order products
Send email messages, submit forms, or contact us

Third Parties

We also may receive Personal Information from or through a third-party service. For example, we may provide the option for you to log in and access our Services using your credentials from a third party service (e.g. Facebook, Google). If you choose to log in using this feature, we may obtain Personal Information such as your email address or profile information from the third party service. We abide by this Privacy Policy when we use Personal Information provided to us by third parties. We do not control the information that third parties collect or how they use that information. You should review the third parties’ privacy policies for more information about how they collect, use, and share this information, including what information they may disclose to us if you use their service credentials to log in to our websites.

IV. What third parties collect Personal Information on behalf of ArenaNet?

Payment Processors

We do not directly collect your payment information and we do not store your payment information. We use third party payment processors who do collect payment information on our behalf to complete transactions. Specifically, payment and billing processors and credit card verification services may collect Personal information to process some transactions depending on the payment method you use. If you do not provide this Personal Information, they will not be able to complete the transaction you have requested.

V. Why does ArenaNet collect Personal Information?

Limited Purpose

We use Personal Information for the purpose for which you provided it, for example:

We may use contact and identification information like phone number, address, or social media profile information to contact you about our Services, for customer support, to provide you with marketing, or to contact you regarding an event or contest.
We use billing data, including some credit card information or bank information for purchases and customer support requests about refunds and chargebacks.

Lawful Basis

We only collect, use, or store your Personal Information if:

You voluntarily provide it to us with your specific and informed consent (for example, when signing up for our newsletters),
It is necessary to provide you a Service that you have requested (for example, providing you access to our games), or
We have a legitimate business interest that is not outweighed by your privacy rights (for example, maintaining records of sales through our online store).

We may need, and may require from you, certain Personal Information to provide our Services to you or to complete a transaction. You understand and accept that we will collect, use, and store your Personal Information based on the business purpose of fulfilling your requests and maintaining records of our Services to you. If you do not provide the Personal Information we need, we will not be able to process the transaction or provide the requested Service. We may also use Account Information related to your profile to detect cheating, fraud, illegal activity, or other activities that may violate our User Agreement.

With your consent, we also may use your Personal Information to create a profile for marketing campaigns, including on social media or through email. We use the information we collect to learn what you like, tailor your experience accordingly, and to improve our websites and our other products. We may also use your Personal Information in an aggregate, anonymized way to help us target advertising on social media.

VI. With whom does ArenaNet share Personal Information?

Types of Third Parties

To provide you with access to our Services, we may share your Personal Information with the following types of third parties:

• Fraud detection and management services, authentication services, and risk services
• Customer support and localization vendors
• Marketing platforms
• Social media websites, server providers, and email providers
• Moderation and user experience providers
• Fulfillment houses

We do not sell or share Personal Information with third parties for those third parties’ direct marketing purposes.
We may work with third parties to provide you some contests, sweepstakes, promotions, or surveys, and when accessing, purchasing, or subscribing to one of the Services. During the registration process, we or a third party may ask you for certain Personal Information, such as your mailing address. If you do not provide this Personal Information, we may not be able to provide the Service you have requested.
We may disclose your Personal Information to law enforcement or other appropriate third parties in connection with criminal, fraud, infringement, other investigations related to suspected illegal activities, as may be required by applicable law, or to protect the legitimate legal and business interests of ArenaNet.
We sometimes share information about our user base with third parties about our user base. Except as described in this Privacy Policy, we will not give any of your Personal Information to any third party without your express approval.

Third Party Precautions

We take reasonable precautions before sharing your Personal Information with third parties and require that they provide adequate protections.

If third parties are collecting, using, or storing your Personal Information on our behalf, we require that they have a legitimate basis for doing so, reasonably limit their retention and use, and use appropriate security measures regarding your Personal Information.
While we review the privacy and security policies of the third parties we work with, some third parties may provide additional terms in their privacy policies, which may control their use and storage of your Personal Information.

VII. How does ArenaNet treat Personal Information transferred out of the EU?

Place of Business

We may store or process your Personal Information outside of the country where we collect it. ArenaNet has its place of business in the United States of America and the United Kingdom, and by agreeing to this Privacy Policy, you understand that we will transfer some of your Personal Information to the United States of America.

Transfer Mechanisms

When transferring Personal Information out of the EU, we implement technical, legal, and physical safeguards to protect your Personal Information. We use European Commission approved standard contractual clauses, Privacy Shield certification, Binding Corporate Rules, or implement other similar measures required by applicable law. We will provide you with reasonable information regarding the relevant mechanism for your review on request.

Privacy Shield

ArenaNet complies with the EU-U.S. Privacy Shield Framework 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 Information transferred from the European Union and Switzerland to the United States. ArenaNet has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. ArenaNet is responsible for the processing of the Personal Information we receive and subsequently transfer to a third party acting as an agent on our behalf, and we remain liable if a third party acting on our behalf uses your Personal Information in a way that is inconsistent with our obligations under Privacy Shield. In compliance with the Privacy Shield Principles, ArenaNet commits to resolve complaints about our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ArenaNet using the information found at the end of this Privacy Policy. ArenaNet commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and Commissioner about Personal Information transferred from the EU or Switzerland. The Federal Trade Commission has jurisdiction over ArenaNet’s compliance with the Privacy Shield. You may have the right, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. See https://www.privacyshield.gov/article?id=ANNEX-I-introduction for more information.

Data Protection Officer

In compliance with applicable privacy laws, ArenaNet has appointed a Data Protection Officer to monitor whether we are following this Privacy Policy and are able to address any concerns about how we handle your Personal Information.

VIII. How does ArenaNet protect Personal Information?

Our Collection, Security, and Retention Policies

We protect your Personal Information through a combination of collection, security, and retention policies.

We only keep your Personal Information for as long as we need it, unless you agreed to allow us to use it for some other purpose or to comply with any statutory, regulatory, or business obligations. We respect requests to stop processing your Personal Information for marketing purposes. This includes keeping a record of your stop processing request indefinitely so that we can respect your request in future.
We use all reasonable methods to keep the Personal Information we collect and use in a secure environment, and we have implemented technical, administrative, and physical security measures that are designed to protect Personal Information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes we review these security procedures regularly to consider new technology and methods.

Your Practices and Activities

You can take certain steps to help protect your Personal Information, such as being careful what you post in public places.

Do not use your real name when selecting a username. Your username will be available to the internet’s general public while you participate in some Services, like forums, chat rooms, or message boards, so you should exercise discretion when using these Services.
Do not post your real name through the Services, and never tell anyone online anything private about yourself, including your phone number or address. Use usernames and not real names at all times.
We store the information you post in the Services, but we do not actively collect Personal Information from the content of these communications. When you communicate through a Service, even privately, we process and store those communications on our servers. We have the ability to monitor, and you consent to the monitoring of, the communications that you send and receive. Many types of communications are also publically available. We have no control over what third parties do with the content of communications. You agree that we have no responsibility, liability, or obligation to you regarding third parties’ use. Communications are exempt from the application of this Privacy Policy.
To the extent that you are able to and do create a public profile that may be available to others on our Services, you are solely responsible for its content and accuracy at all times.

IX. What rights do you have to your Personal Information?

Right to Access, Correct, Delete, or Restrict Processing

You have the right to request access to and correct or erase Personal Information, the right to restrict processing of your Personal Information, and the right to object to processing of your Personal Information. We may be unable to comply with requests under certain limited exceptions, including (1) when we are unable to confirm your identity, (2) where we are unable to verify the data you’ve provided, (3) where the request is considered excessive, and (4) where doing so would adversely affect the rights and freedoms of others. You also have the right to object to your Personal Information being processed based on our legitimate business interests and the right to object to us sending you direct marketing and profiling you for the purposes of direct marketing, so long as such contact does not include critical information regarding your active game accounts. You can contact us about any of the rights described in this paragraph, or if you have any questions regarding this Privacy Policy. In some cases, you can review or update your Personal Information stored with ArenaNet by accessing your account online. You may also request that we delete or anonymize your Personal Information. If you choose to have your Personal Information removed from our active databases, we will do so within a reasonable time after your request and we will take reasonable steps to ensure that your Personal Information is not used (except as may be required by law) by ArenaNet after you request such removal or deletion. You have the right to withdraw your consent regarding our use or storage of certain Personal Information, for example, if you do not want to receive email from us, you can “opt out” of receiving it by following the steps described in each such email or by accessing your response.

Right to Lodge a Complaint

You have the right to lodge a complaint regarding our collection, processing, or storage of your Personal Information with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred.

X. How does ArenaNet use cookies?

Cookies and Tracking Pixels

When you visit a website, it may ask your browser to store a “cookie” on your device to remember information about you, such as your language preference or login information. We and our third party providers use cookies to assign a unique number that automatically identifies your computer when you visit our websites. Some cookies remain on your computer until you delete them; others, like session ID cookies, expire when you close your browser. We and our third party providers also use tracking identifiers (such as Clear GIFs, pixels, web beacons) to track the online movements of web users. Unlike cookies, tracking identifiers are tiny graphics that are embedded invisibly on web pages or in HTML-based emails.

Purpose

We use cookies and other tracking technologies for the following purposes:

Assisting you in navigating or displaying certain types of content;
Assisting you in registration to our events, logging in, and your ability to provide feedback;
Analyzing your use of our Services, counting visits, collecting aggregated user data, and traffic sources; and
Tracking our promotional and marketing efforts.

Third Party Cookies

Some of our cookies come from third party advertisers or analytics providers. These cookies improve your experience by helping us better tailor our websites to our audience. We work with third party advertising and analytics providers for collecting information about users and their usage of our Services. We may share non-personal or anonymized information about your use of our websites with those third party providers. The third party providers use cookies and tracking identifiers to collect demographic and interest-level information and usage information from users that visit our websites, including information about the pages where users enter and exit the websites and what pages they view and visit on the websites. We do not link information we receive from our third party providers with Personal Information.

Google Analytics

We use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, US. On an anonymous basis, Google will analyze your use of our Website on our behalf. The information collected by Google in connection with your use of our Services will be transmitted to a server of Google in the US, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address, or any other Personal Information, during this process. Google’s collection and use of information is subject to Google’s Privacy Policy. If you would like to opt out of Google Analytics tracking, please visit one of the following links:

Google Ads Settings (http://www.google.com/settings/ads),
the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/), or
NAI’s consumer opt-out (http://www.networkadvertising.org/choices/).

Browser Settings

You may set your browser setting to attempt to reject the cookies and tracking identifiers, and you may still use our websites. However, you may be limited in some areas of our websites, or you may have to enter passwords or identifying information more than once.

XI. Are there any special categories related to Personal Information?

Minors
1. If you are under 13, you may not use our Services. ArenaNet will not knowingly collect, maintain, or disclose any Personal Information from children under the age of 13. If you are ordinarily resident in the European Union any reference to an age of 13 shall be deemed a reference to the age in your home country, below which, children receive additional legal data protections.
2. We do not allow children under the age of 18 to use our Services unless they do so with parental consent. If you are between the ages of 13 and 18, please let your parent or guardian know about this Privacy Policy and get his or her permission before you give us any of your Personal Information or use any Services. Some areas of the website, services, or games may have special rules for users under the age of 18. When you are in those areas, you must follow those rules.
3. If you are a parent or guardian of a child who has submitted Personal Information, you can contact us about removing that information, and ArenaNet will take reasonable steps to remove that information. To request removal of your child’s information, please send us an email and be sure to include in your message the same username and email address that your child submitted. If your child has used your credit card on our websites, games, or services without your permission, contact us immediately.
California
1. We provide registered users the ability to post information on our Services. If you are a California resident who is under 18 and a registered user and you are unable to remove content or information you posted in a public area following the instructions provided, you may request removal by contacting us. When requesting removal you must be specific about the information or content you want to remove and provide the URL for each place it is located. We are not required to remove any content or information that: (a) we, or a third party, are legally required to maintain; (b) was not posted by you; (c) is anonymized so that you cannot be identified; (d) is not based on a request that follows our instructions for removing or requesting removal; or (e) you received compensation or other consideration for providing the content or information.
2. California Civil Code Section 1798.83 permits California residents to request information from us concerning any disclosures of Personal Information we may have made in the prior calendar year to third parties for direct marketing purposes. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, you may contact us.

XII. How will ArenaNet notify users of changes to this Privacy Policy?

ArenaNet reserves the right to change this Privacy Policy at any time by notifying registered users via email of the existence of a new Privacy Policy, providing a pop-up notice on the Services, posting the new policy on the websites, or any other notification method that is appropriate based on the nature of the change. All changes to the Privacy Policy will be effective when posted, and your continued use of any of the Services after the posting will constitute your acceptance of, and agreement to be bound by, those changes.

XIII. How can someone contact ArenaNet?

Our mailing address is:

ArenaNet, LLC,
3180 139th Avenue SE, Suite 500
Bellevue, WA 98005, USA

Our customer service email address is support@arena.net.

Our privacy email is privacy@arena.net.

Last updated October 2018

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