Privacy Policy for LCG Entertainment, Inc & Telltale

CALIFORNIA RESIDENTS
The Supplemental Privacy Notice for California Residents attached at the end of this document describes your privacy rights as a California resident regarding the collection, use, and processing of your personal information.

INTRODUCTION
LCG Entertainment, Inc. is the owner and operator of the Telltale brand of video games (“We” “Us” “Our”), and we take our obligations regarding your data and privacy seriously.

LCG Entertainment, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LCG Entertainment, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. LCG Entertainment, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

1. OUR SERVICES

We own and manage all offerings under our “Sites”—including websites like www.telltale.com, blogs, and forums—as well as the games, products, promotions, and services we provide through our “Software”, which includes our Telltale titles. Together, our Sites and Software are collectively termed as “services.”

This Privacy Policy applies only to our services that link to this Privacy Policy, including our company Sites, www.Telltale.com and www.Telltalegames.com. If we change this Privacy Policy, your continued use or access to our services constitutes acceptance. 

2. UNDERSTANDING PERSONAL INFORMATION

We are committed to protecting the privacy of your personal information. In the context of personal information, we refer to data that can identify you as an individual, including but not limited to your name, contact details, gaming preferences, device information, and online identifiers such as IP addresses and device IDs. We may also collect data pertaining to your game progress, in-game purchases, and interactions with our services.

We collect personal information across several categories, including contact information, demographic information, financial information, behavioral information, technical information, and social media information. We use this information to provide and improve our services.

We value your privacy and respect your rights. If you wish to access, modify, or delete your personal information, please contact us at privacy@Telltalegames.com. We will promptly respond to your request and take necessary steps to ensure the security and integrity of your personal information.

3. THE SAFETY OF CHILDREN ONLINE

We believe that protecting children’s privacy online is of paramount importance. We are committed to complying fully with the Children’s Online Privacy Protection Act (“COPPA”), California Consumer Privacy Act (“CCPA”), and similar statutes worldwide. We encourage parents and guardians to discuss with their children what information should be released on the Internet, especially personal information.

Our services are not intended for children under the age of 13, and we do not knowingly collect information from children under 13. In some geographical areas, our services may not be accessible to anyone under the age of 18, regardless of whether a parent or guardian has provided consent.

If you are under 13, we request that you do not submit personal information. If we later learn that we have inadvertently gathered personal information from a child under the age of 13, regardless of where that child resides, we will remove this information from our records as quickly as possible.

If you believe we have any information from or about a child under 13, please contact us immediately at privacy@telltalegames.com or the physical address provided at the end of this section, and we will promptly take the necessary steps to remove all such information.

Attention: Data Protection Officer

LCG Entertainment, Inc.

8605 Santa Monica Blvd #56565

West Hollywood, California 90069-4109

4. WHAT INFORMATION DO WE COLLECT, WHY, AND HOW DO WE USE IT

Depending on how you use our services, we may collect personal information across several categories, including:

• Contact information such as your name, email address, phone number, and mailing address.
• Demographic information such as your age, gender, and occupation.
• Financial information such as your payment card details and billing address.
• Behavioral information such as your website usage, browsing history, and search queries.
• Technical information such as your device and browser information, IP address, and operating system.
• Social media information such as your social media handles and activity.

We collect this information to provide you with our services and to improve them. We may use it to:

• Communicate with you about our products and services.
• Verify and authenticate users, as well as to identify and prevent abuse.
• Process transactions, provide customer support, and respond to inquiries.
• Personalize and improve our services.
• Conduct research and analytics to better understand our audience and improve our offerings.

5. POINTS OF COLLECTION

A. Connecting to Our Sites Directly.

When you connect to our Sites directly from your Internet browser, we may collect your Internet IP address, type of browser, and the operating system you used. (“Cookies”) Our use of cookies is explained in greater detail in Section 8. COOKIES AND SIMILAR TECHNOLOGIES.  We may also collect the date and time you accessed our Sites, the pages you visited, and the search terms you used to find us. We collect this information in aggregate to understand how our users find us and what search criteria they use. By using our services, you authorize us to collect, store, and use this information per this Privacy Policy.

When using our services from a mobile phone or other wireless technology, we may collect information from that device, including the device type, unique identifiers, and other data you choose to provide or share in accordance with your wireless provider’s terms of use. For example, a push notification from us may appear as a pop-up message on your phone. We may also send push notifications and other information about our services to your mobile device. you can manage your mobile device push notifications through your device settings or other options your wireless device provider may provide. If you do not want us to send you push notifications or additional information in this manner, you may disable them through the settings on your phone. If we send you push notifications and you do not want to receive them, please let us know immediately, and we will take steps to ensure your information is removed from our servers and push notifications. By using our services, you authorize us to collect, store, and use your mobile device information for this purpose per this Privacy Policy.

If eligibility requirements are met, you may choose to post or upload additional information about yourself, including profile, biography, birth date, profile picture, location, interests, and occupation. Our Terms of Service, available at https://www.telltale.com/tos/, and this Privacy Policy govern postings on our forums. To learn more about how to protect the information you share in our forums, please review Section 7. KEEPING YOUR INFORMATION SECURE.

B. Creating an Account with Us.

If you create an account with us, you are required to provide an email address and password. We use the provided information to validate your account over email.

C. Purchases Directly from Us.

If you purchase our services directly from us, we may collect your billing information, including your name, address, telephone number, payment card number, and payment account details. We use this information to verify your purchase, fulfill orders, notify you of recent updates and products you might enjoy, and assist our customer support services, including identifying and resolving general issues and problems experienced by you and other users.

D. Information You Provide Through Feedback.

Our services may allow you to submit feedback to us, including comments, suggestions, and bugs you discover. When you submit this information to us, we may collect your name, username, and e-mail address to follow up with you or thank you for your suggestion. By using our services, you are authorizing us to collect, store, and use your feedback information in accordance with this Privacy Policy and the laws of the United States and the European Union. If we send you a follow-up e-mail or notify you in any other way, and you do not want to receive this notification, please let us know immediately by contacting us at privacy@telltalegames.com and we will take steps to ensure it is removed from our servers and notification services.

E. Surveys and Contests. 

When we conduct surveys or initiate contests, sweepstakes, or other programs, we may ask for your country, date of birth, telephone number, and additional information to verify who you are and how to contact you. By entering our contests, surveys, and similar programs, you authorize us to collect, store, and use your mobile device information per this Privacy Policy.

F. Information We Obtain For Specific Purposes. 

Occasionally, we may request information from you on a product order form through promotions, contests, and other online transaction forms. These requests may ask you to provide contact information (such as your name and mailing or shipping address) and, in some cases, payment information (such as credit card number and credit card expiration date). We use this information to verify orders and ensure that the individuals participating in our contests and promotions are eligible. By using our services, you authorize us to collect, store, and use this information per this Privacy Policy.

G. Geographic and Telemetry Data.

Our services may employ tracking technologies like pixel tags, web beacons, and programming codes. These technologies may enable our partners and us to derive your physical location based on your IP address, which we use to verify and authenticate users, prevent abuse, and improve our services. By using our services, you authorize us to collect, store, and use this information per this Privacy Policy.

H. Targeted Advertising and Ad Serving Technologies.

We do not use your personal information to send targeted advertising or employ ad-serving services or technology. However, we reserve the right to do so, provided that such uses conform with the laws of the United States and Europe regarding such matters.

I. Direct Advertising. 

When we directly advertise to you through activities such as email marketing, online advertising, or direct mail, we may collect information from you to help us tailor our advertising to your interests. This information may include your name, age, gender, contact information such as email, phone number, or address, as well as data about your online activity, like browsing history, search queries, and cookies. We may also collect data on your purchase history, location, interests and hobbies, social media activity, job title, and employment information.

We will always ask for your consent before sending you direct advertising, for example, if we want to send you an incentive offer by e-mail. If, for any reason, you receive a direct advertisement from us and believe you did not consent to it, please get in touch with us at privacy@telltalegames.com, and we will remove your name and e-mail address from any future direct advertising. Please also review Section 12. YOUR RIGHTS & CONTROLS, to better understand your rights and our duties regarding direct advertising.

J. Using Automated Collection Tools. 

Our services utilize automated data collection tools, including cookies, tags, and scripts. We use opt-out by default, meaning non-essential cookies are not collected until you allow it, and may be toggled on or off through our cookie banner. These tools collect certain information sent by your browser, including your IP address, browser type, entrance and exit pages, URLs, platform type, duration on a page, clickstream data, pages viewed, date and time, and other information. We use this information to identify trends, troubleshoot our products and services, understand our consumers better, help identify errors, investigate potential breaches of terms of service, this Privacy Policy, and possibly illegal activities, and design new products and services. You may choose to enable certain non-essential cookies to enhance your experience. By using our services, you authorize us to collect, store, and use this information per this Privacy Policy.

K. Information We Obtain from Social Media.

Our services may include social media functions and features, for example, a Facebook “Like” button or Twitter “Share” feature. Through this functionality, we may collect your IP address and the page you are visiting on our Sites or in our services. Third parties often host these social media functions, and in these cases, or the event we provide a link to such services and operations, your interactions. The privacy of the information you provide is subject to and governed by the company’s respective privacy policy.

L. Using Your Information for Investigative Purposes. 

We may use the information you provide or that we collect as provided above to investigate potential breaches of the Terms of Service, this Privacy Policy, and possibly illegal activities. We do this for your protection and the security of our services. Using our services, you authorize us to collect, store, and use this information per this Privacy Policy.

6. THIRD-PARTY SERVICES

A. Information You Provide Online. 

When you connect to our services through a third party, we may collect information about you from these third parties, depending on the third party’s terms of service and the privacy settings you have specified, including accessing our Software through Valve’s Steam, Sony PlayStation’s platforms and services, Microsoft’s Xbox and Windows platforms and services, Google’s Stadia platform and service, Epic Games’ platform and services, or other third-party platforms or services. We may obtain certain personal information, for example, your full name, profile picture, user ID, login, e-mail address, physical location, gender, birthday, groups and affiliations, and forum posts.

We collect this information to identify where our users come from and how they found us. We also use this information to identify trends and interests, which helps us to build better products. If you do not want us collecting or using this information, you can often disable this feature through the settings on the websites and services you use. If we have collected this information and you do not want us to use it or store it, please let us know, and we will take steps to ensure it is removed from our servers.

B. Purchases through Third-Party Services and Distributors. 

When you use third-party services to purchase our services, for example, Valve’s Steam, Sony (PlayStation platforms and services), Microsoft (Xbox and Windows platforms and services), Google (Stadia platform and service), Epic (Epic Games platform and services) and similar distribution services, we may obtain your name, e-mail address, online ID, country, state or province, language, date of birth, and other social information you provide to them.

We use this information to help verify your purchase, to notify you of recent updates and products, and to assist our customer support services, including identifying and resolving general issues and problems experienced by you and other services users. When we receive this information, we will obtain, store, and remove it in accordance with this Privacy Policy and the laws of the United States and the European Union. We do not receive your credit card number or other financial information from these services.

7. KEEPING YOUR INFORMATION SECURE

It is crucial for you to keep your passwords secure, and you should not disclose or share your password with any third parties. We also strongly urge you to periodically change your password to reduce the risk of unauthorized access to your account information. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password is compromised, you should change it immediately. You may also contact us at privacy@telltalegames.com for assistance.

A. Using Our Blogs, Forums, and other Online Functions. 

Be aware of whom you are communicating with and what information you provide to others. Our services may allow you to contribute to blogs, forums, and boards, to receive and participate in newsfeeds, to provide others with status updates and postings, and to otherwise post, share, and contribute information publicly, whether through messages, invitations, chats, photos, wall posts, and other functions (“Public Postings”). Nothing requires you to disclose your identity to others through these Public Postings, and you should always keep in mind that these will be visible to anyone who has access to our services. In certain instances, this same information may be visible through general Internet searches and other means of obtaining Internet information. For example, certain software tools and technology may allow non-affiliated third parties to copy, cut, or post your Public Postings to different locations (including services that are not owned or operated by us). The preceding may result in the unauthorized use of your Public Posting information and your unwanted disclosure of this same information to third parties, for which we are not responsible, and in some cases, may subject you to liability for the disclosure, including, without limitation, for copyright infringement.

Always exercise caution in all your Public Postings. We recommend that you do not provide or disclose any personal information when using our services. If you choose to disclose your identity to third parties using our services, you do so at your own risk. Neither we nor our third-party business partners, affiliates, or developers are responsible for the privacy or security of any information, personal or otherwise when you choose to communicate or exchange such information using the services functionality to post publicly.

B. Linking to other services. 

Be cautious of linking to other services. Our services may contain links to other websites and services, but we are not responsible for their privacy practices. We encourage our users to be aware that when they leave our services through these links, they should always read and understand the privacy policies of these websites, especially those that collect personally identifiable information.

8. COOKIES AND SIMILAR TECHNOLOGIES

A. Cookies, Generally.

“Cookies” are small pieces of data (often text files) that are placed on your computer or device by our  services that you visit or our partners. As a standard feature of major browser applications, cookies are widely used to make online services work or operate more efficiently, as well as to provide info to the providers of those online services about your browsing experiences. When you return to those same online services again, your browser sends the previously stored cookies back to the online service which allows it to recognize you and remember important info to make your use of the online services more personalized or convenient, such as by remembering your saved preferences, keeping items in your cart, or keeping you logged-in to our forum.

We and our partners also use other technologies, including data stored on your web browser or device, identifiers associated with your device and other software for similar purposes. This includes the following:

• Pixel tags: Pixel tags (also called beacons or pixels) are small blocks of code installed on (or called by) a webpage, email, app, or ads which can retrieve certain info about your device and browser and how you interact with it. This includes, for example, information about your device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, whether you’ve opened an email or clicked on an ad, and other similar info, including the small text file (the cookie) that uniquely identifies the device. Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect info about visitors to that domain, typically with the permission of the domain owner.
• Local storage: This refers generally to other places on a browser or device where info can be stored by websites, ads, or third parties (such as HTML5 local storage and browser cache).
• Software development kits (“SDKs”): Software development kits (also called SDKs) function like pixels and cookies but operate in the mobile app context where pixels and cookies cannot always function. Pieces of code (the SDK) are installed in the app that allow us and our partners to collect certain info about your interaction with the app and info about your device and network.
• IP address: IP address is the short form for Internet Protocol address which is assigned by internet access providers to every computer that is connected to the internet. Website owners have access to IP addresses of their users. Using IP addresses, we and our partners can identify the country, state and city from which a computer is connecting to the Internet. IP addresses are, for example, used for IP geolocation purposes.
• Device identifiers: We may also collect unique device identifiers or create a unique device fingerprint (this is a unique combination of different information from your device so that we can single it out) so we can identify your device. We may then use this in a similar way to cookies.

In this policy, we refer to all of these and similar technologies as “cookies.” These technologies can be used to recognize when your device does things. For instance, they may recognize when you visit pages on our or others’ sites, use parts of an app or when you open emails we send you, or links in technologies.

B. Cookie Register.

To provide full transparency, we detailed the specific cookies utilized across our services as of February 20, 2024:

Essential Cookies are used for verification, maintaining login states, and security measures against fraudulent access and data protection.

We use the following essential cookies to safeguard against fraud and ensure compliance with our policies.

__cfruid: Deployed by CloudFlare on telltalegames.zendesk.com and support.telltale.com, these cookies are essential for identifying trusted web traffic, ensuring our service’s security. They are session-based and expire upon closing the browser. Further details are available in CloudFlare’s cookie policy, available at https://www.cloudflare.com/cookie-policy/.

cf_clearance and _cfuvid: Found on support.telltale.com, associated with CloudFlare, these cookies are essential for security and to distinguish between different visitors, hence classed as strictly necessary. The cf_clearance cookie has a 1-year lifespan, while _cfuvid is session-based.

Functional Cookies are used to remember preferences and settings.

We use the following functional cookies:

CookieControl: This telltale.com cookie, with a 3-month life, manages privacy settings, aligning with functional cookie classification due to its role in remembering user preferences. CivicUK’s privacy statement has more information and is available at https://www.civicuk.com/privacy.

Analytical Cookies are used for understanding service usage patterns, aiding in service improvement through traffic analysis and user interaction insights.

We use the following analytical cookies:

_help_center_session: This is a session cookie on support.telltale.com that aids in maintaining user sessions for consistent performance throughout their visit.

Advertising Cookies for delivering relevant ads based on your interests and measuring ad campaign effectiveness.

We use the following advertising cookies:

VISITOR_INFO1_LIVE and YSC: Placed by Youtube.com, these cookies track user preferences and views of YouTube videos embedded in our sites. VISITOR_INFO1_LIVE lasts for 6 months, whereas YSC is session-based. Their functionalities are outlined in Google’s cookie policy, available at https://policies.google.com/technologies/cookies?hl=en-US.

1.  Third-Party Cookies.

Cookies on your device may be placed by us, known as ‘first-party’ cookies, or by our partners, termed ‘third-party’ cookies, when you engage with our services. These third-party cookies provide various services and may be set when you encounter embedded content from entities like Google’s DoubleClick, Nanigans.com, or Ad4game.com. Such cookies, beyond our direct control, track visits and share information with businesses, including advertisers, for enhanced service experiences.

We lack access to third-party cookies due to their operational nature—only the originator can modify them. We advise reviewing our partners’ privacy policies for your peace of mind regarding their cookie usage.  Embedded content from platforms like YouTube or Facebook, along with social media features (e.g., Facebook’s ‘like’ button), may also set their own cookies. Control over these cookies rests with the respective service providers, not us.

D. Managing Cookies.

You have control over your cookies. You can set your browser to limit or block cookies, though this may affect your experience with our services. By using our services, you acknowledge and agree to our use of cookies as described. For more about our practices and how to manage your cookie preferences, review Section 12. YOUR RIGHTS & CONTROLS.

Please Note: Third-party cookies used by our partners are subject to their policies. We encourage you to review those policies for more information.

9. INFORMATION SHARING POLICY

A. We do not sell Your Information. 

Neither we nor our third-party business partners, affiliates, or developers intend to sell, share, or rent information obtained from our services other than as discussed in this Privacy Policy. Should our policy change, we will provide notice within this policy and offer you a clear opportunity to opt out before your personal information is sold or shared.

B. We may disclose Your Information in Certain Circumstances.

Mergers or Acquisitions.

While we do not sell, rent, or otherwise disclose personal information collected from and about its users to third parties, except as expressly stated in this Privacy Policy, in the event of a merger, acquisition, reorganization, bankruptcy, or another similar event, our customer information (including your personally identifiable information) may be transferred to our successors or assigns, if permitted by and done in accordance with applicable law.

Law Enforcement. 

We may use and release information concerning your use of our services (including, but not limited to, posted Public Postings, registration information, network records, and geographic and tracking data) when we believe in good faith that such release is appropriate; to comply with the law (for example, according to a statutory demand, subpoena, warrant, or court order); to protect against fraudulent, abusive, or unlawful use of our services, and to protect our rights and property (including the rights and property of our third-party business partners and affiliates); to enforce any contract between you and us, including with our third-party business partners and affiliates; and if we reasonably believe that a situation involving danger of death or injury to any person requires such investigatory use or disclosure.

Advertising Partners.

When we pay for advertising on third party platforms, we may allow third-party partners to set technologies and other tracking tools to collect information regarding your use of our services, including your IP address, mobile identifiers, the pages you have visited, your location, browser information, the activities you engaged in on our Sites or through our services, and when you visited. Our advertising partners or we may also combine and share such information in an aggregate form. These advertising partners may use this information (and similar information collected from other websites) to deliver targeted advertisements when you visit third-party websites within their networks. Since the information is collected in aggregate, the statistics are generated anonymously. These statistics help us with marketing and demographic studies to enhance our services. 

We do not link IP addresses to anything personally identifiable. This means that a user’s session will be logged, but the user remains anonymous to us. We can and will use IP addresses to identify a user when we feel it is necessary to enforce compliance with our Terms of Service (available at https://www.telltale.com/tos/) and this Privacy Policy or to protect our services or a person or entity. If you prefer that we not share your personal information with third-party advertising partners, you may contact us at privacy@telltalegames.com.

Other Third Parties for E-mail Purposes.

We may share or use third-party services for e-mail processing, including, for example, MailChimp and SparkPost. When we do, we will ensure that these services comply with this Privacy Policy’s terms and all applicable laws.

10. DATA RETENTION AND SECURITY

We have implemented security measures to protect and prevent the loss, misuse, and alteration of the information under our control. We use industry-standard efforts to safeguard the confidentiality of your personally identifiable information, such as firewalls and encryption. While “perfect security” does not exist on the Internet, our technical experts work hard to ensure your secure use of our services.

A. Storage.

We store the information we collect from you within the United States of America. We take prudent security measures to protect you and the information we collect from unauthorized access, alteration, disclosure, and destruction. These measures include encrypting your information on our servers, keeping your sensitive information on a secured server behind a firewall, transmitting sensitive information (such as a credit card number) entered on our site or mobile application using secure socket layer technology (SSL), periodic reviews of our data collection practices and platforms, and physical security measures that guard against unauthorized access to systems where we store your information.

B. Retention.

We will keep your information only for as long as reasonably necessary, including while your account is active or the information and for as long as it may be required to fulfill our legal obligations. If you would like us to delete your account or request that we no longer use your information, please contact us at privacy@telltalegames.com.

11. WHAT WE DO IN THE EVENT OF A DATA BREACH

We will contact you within 72 hours if we suspect your data has been compromised. If you want to verify that your information is secure, we will reply to such requests as soon as possible. Please contact us at privacy@telltalegames.com.

12. YOUR RIGHTS & CONTROLS

A. Opting Out.

Our services may allow you to opt out of receiving information and solicitations from us, even if you did not do so initially. In addition, you can remove your name and e-mail address from any list we maintain and discontinue future communications at any time. To ensure removal, please follow the instructions within the specific services you are using. If the relevant services do not provide you with such an option, or you are unsuccessful or otherwise have questions, concerns, or problems, please feel free to contact us at privacy@telltalegames.com.

B. Making Changes to Your Information.

You can request that any inaccuracies about your personal information be corrected. You can also ask about why we have your personal information; how we obtained it; what we have done with it; to whom we communicated your personal information; where it has been stored, processed, or transferred; how long we will retain it; and the safeguards in place to protect it when transferred to third parties. You can also ask us not to collect or use your personal information for specific purposes. We will respond to your request without undue delay and within 30 days. We reserve the right to take reasonable steps to verify customer identity before granting access or processing changes or corrections.

If you would like to change your personal information or remove it from our records, you have any of the following means to do so: (1) Log in with your password and modify/delete your profile; (2) Send a letter to us at 8605 Santa Monica Blvd #56565, West Hollywood, California 90069-4109; or (3) E-mail us at privacy@telltalegames.com (if you reside in the European Economic Area you may contact our Data Protection Officer via e-mail at dpo@telltalegames.com).

C. Removing Your Information (Right to be Forgotten).

You have the right to request that we remove your personal information from our services and servers. If this is your desire, please contact us at privacy@telltalegames.com, and we will endeavor to comply with your request as soon as practicable and within 30 days. Please note that if you are still using our services, however, we may require your consent to retain and use such information to continue providing our services.

D. Managing Cookies.

If our service incorporates a cookie banner, you have the flexibility to accept or reject cookies at any time. Cookie preferences are opt-out by default, and you have the ability to change this at any time.

You can find out more about how to see what cookies have been set and how to manage and disable them by visiting the  “All About Cookies” website available at http://www.allaboutcookies.org/manage-cookies/index.html. You can also find information about how to enable or disable cookies on your Internet browser through your settings located in your user interface.

To learn more about how advertisers generally use cookies and the choices they offer, you can review the following resources:

• Digital Advertising Alliance (http://optout.aboutads.info/?c=2#!/)
• Digital Advertising Alliance of Canada (https://youradchoices.ca/)
• European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/)
• Network Advertising Alliance (http://optout.networkadvertising.org/#!/)

If you want to clear all cookies left behind by online services including our  services you have visited, here are links where you can download programs that clean out tracking cookies: Lavasoft (http://www.lavasoftusa.com/products/ad-aware_se_personal.php) and Spybot. (http://www.spybot.info/en/download/index.html)

When you install our mobile apps, SDKs are installed. You cannot deactivate an SDK. Consequently, do not install our mobile apps if you are not comfortable with the use of SDKs.

Please be aware that if cookies are disabled, not all features of our services may operate as intended.

13. CHANGES TO OUR PRIVACY POLICY

We may make changes to this Privacy Policy at any time or as required by US or international law. In such cases, we will post changes on throughout our services. All modifications to this Privacy Policy become effective on the day we post them unless stated otherwise and supersede all previous privacy policies. Therefore, please review this Privacy Policy regularly and print a copy for your records.

14. LEGAL COMPLIANCE

We endeavor to comply with the laws and regulations in the jurisdictions in which we collect or use your information, including the following:

A. US Laws.

• The Federal Trade Commission Act (15 USC § 45) which regulates unfair or deceptive business practices and guides consumer privacy disclosures.
• The Children’s Online Privacy Protection Act (“COPPA”) which regulates the online privacy of children under 13.
• The California Consumer Protection Act (“CCPA”) which is a comprehensive data protection statute governing the personal information of California residents.
• The California Online Privacy Protection Act (“CalOPPA”) which regulates commercial website operators that collect California residents’ personal information.
• Civil Code Section 1798.83 (“Shine the Light”) which is a California law requiring businesses to provide customers with information regarding how third parties can use their personal information for marketing purposes.

B. International Laws.

Among other requirements, the European Union’s General Data Protection Regulations (“GDPR”), requires that users affirmatively consent to specific data collection techniques (such as cookies) and collecting, storing, using, and removing certain sensitive information, prior to any such use.

15. DATA TRANSFERS

A. Data Privacy Framework (“DPF”) Program.

We conform and adhere to the DPF Program set forth by the US Department of Commerce. We store your personal information in the United States of America. Our processing of this information complies with the Privacy Policy Framework regarding the collection, use, and retention of personal information transferred from the European Union to the United States. If there is any conflict between the terms in this privacy policy and the DPF Program, the DPF Program will govern. To learn more about the DPF Program and to view our certification, please visit https://www.dataprivacyframework.gov/.

In the event we transfer your personal information to a third party, we will remain liable under the DPF Program where such personal information is transmitted in a manner inconsistent with the DPF Program unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the DPF Program, the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), we provide a dispute resolution mechanism through JAMS Alternative Dispute Resolution (ADR) for European Union, United Kingdom, and individual Swiss complaints. 

If you are a European Union, United Kingdom, or Swiss individual and believe you have a claim concerning the collection, use, and retention of your personal information, please contact us at privacy@telltalegames.com so that we can attempt to resolve your complaint in compliance with the mediation terms set forth in the Mediation section below. If we fail to satisfy your complaint after meaningful mediation, you may contact JAMS to begin the process of opening a Data Privacy case. Your case must address an alleged breach of one or more of the DPF Program principles.

B. Standard Contractual Clauses.

We will rely on EU Standard Contractual clauses and other safeguards to enable transfers outside these areas if we transfer information from European (re. European Economic Area), the United Kingdom, and Switzerland. 

16. RESOLVING DISPUTES

Alternative dispute resolution (ADR) refers to the different ways people can resolve disputes without a trial. We will comply with JAMS ADR procedures specified in the JAMS International Mediation Rules, available at https://www.jamsadr.com/dpf-dispute-resolution. JAMS Mediation will be conducted in English in Santa Monica County, California, before one mediator who is selected under such rules and procedures. All documents submitted to such mediation will be in English. The dispute may also be referred to US Federal Trade Commission, which has DPF Program investigatory and enforcement powers over us.

We strive to provide our users with the best possible experience and to resolve any issues that may arise in a fair and transparent manner. If you have concerns with how we are handling your personal data, please email us through our dedicated channel, at privacy@telltalegames.com, so that we can attempt to resolve your complaint. If we can’t come to a resolution, you can use the independent recourse mechanism provided under the DPF Framework, which is free of charge for you. If that doesn’t work, you can raise the issue with your Data Protection Authority, who will then work with the Department of Commerce to resolve the issue. However, there are certain conditions that must be met before you can do this, and some restrictions apply. In the unlikely event that you have a dispute or claim arising out of this Privacy Policy or your relationship with us, we offer a process for resolving the issue through mediation and binding arbitration.

Mediation is the first step in the process, and it provides an opportunity for both parties to discuss and try to resolve the issue with the help of a neutral third-party mediator. If the dispute or claim cannot be resolved through mediation, the matter will proceed to binding arbitration.

To initiate the mediation process, either you or we may communicate with JAMS (and the other respective party) a written request for mediation, setting forth the subject of the dispute and the relief requested. The parties will then cooperate with JAMS and one another in selecting a mediator from the JAMS panel of neutrals and scheduling the mediation proceedings.

If you need to contact JAMS to initiate mediation or arbitration, you can visit their Website at www.jamsadr.com to find contact information for their various offices and to submit a request for mediation or arbitration online. You can also contact JAMS by phone at 800-352-5267 to speak with a representative who can assist you in initiating the process. When submitting a request for mediation or arbitration, be sure to include a detailed description of the dispute or claim and the relief you are seeking. JAMS will then work with both parties to select a mediator or arbitrator and schedule the mediation or arbitration proceedings.

Under certain conditions, more fully described on the DPF Program website available at https://www.dataprivacyframework.gov/program-articles/FAQs%E2%80%93General, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. If mediation is unsuccessful, you or we may initiate arbitration by filing a written demand for arbitration. Arbitration is a legal process where a neutral third-party arbitrator will make a final and binding decision on the dispute or claim. The process is quicker and less formal than going to court, and it allows both parties to avoid the expenses and stress of a lawsuit. Any arbitration will take place in the state of California and will be governed by the laws of the State of California.

We hope that you will not need to use this process, but we want you to know that we are committed to resolving any issues that may arise in a fair and transparent manner.

17. CONTACT US

For all questions or concerns or requests, please contact our Data Protection Team at privacy@telltalegames.com. For individuals residing in the European Economic Area, contact our Data Protection Officer at dpo@telltalegames.com. You can also contact us via postal mail at the following address:

Attention: Data Protection Team

LCG Entertainment, Inc.

8605 Santa Monica Blvd #56565

West Hollywood, California 90069-4109

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Privacy Notice for California Residents (this “Supplemental Notice”) supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “You”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this Policy. 

This Supplemental Notice does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

1. INFORMATION WE COLLECT 

Concerning California Residents, our services may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. This personal information does not include any publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA’s scope, such as 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”), clinical trial data, or other qualifying research data, or personal information covered by specific sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.

Our services may have collected the following categories of personal information from consumers within the last twelve (12) months: 

CATEGORY	COLLECTED
Identifiers (Real name, email address, IP address)	YES
California Customer Records statute	NO
Protected classification characteristics	NO
Commercial information (Purchase records, consumption habits)	YES
Biometric information	NO
Internet activity (Browsing and search history)	YES
Geolocation data (Physical address)	YES
Sensory data	NO
Professional or information	NO
Audio / Electronic Information	NO
In Game Messaging	NO

If we obtain information as provided in the categories of personal information listed above, this information would be collected through the following sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our services.

2. USE OF YOUR PERSONAL INFORMATION

We use the personal information of California residents as set forth above for the purposes stated in the Section 4. WHAT INFORMATION DO WE COLLECT, WHY, AND HOW DO WE USE IT, as provided in our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. SHARING YOUR PERSONAL INFORMATION

We share your personal information with others only per our Privacy Policy as provided in the Section 9. INFORMATION SHARING POLICY. Consistent with the California Privacy Rights Act (“CPRA”), we respect your right to opt-out of the sale or sharing of your personal information. Should we decide to sell or share personal information, we will update our policy to include provisions for opting out.

4.  RESELLING YOUR PERSONAL INFORMATION

The CCPA prohibits us from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. Therefore, if we intend to sell your personal information, we will provide you with proper notice and the opportunity to opt-out, as defined by law.

5. YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) specific rights regarding personal information. These rights are explained in the Section 12. YOUR RIGHTS & CONTROLS of the attached Privacy Policy. These rights include the following:

• The right to know what data we have collected and why.
• The right to delete or modify your personal information.

Please note that we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted under federal law, 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 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 et. 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.

6. EXERCISING YOUR RIGHTS AS PROVIDED IN THIS SUPPLEMENTAL NOTICE

To exercise your rights to know or delete described above, please contact us as provided in the Section 17. CONTACT US of the general Privacy Policy. We will confirm receipt of your request within ten (10) business days. 

7. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. We believe in providing equal opportunities for all and protecting your privacy rights is a top priority for us.

8. OTHER CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

9. CONTACT US

If you have any questions or comments about this notice or have a disability and require an alternative format for either this Supplemental Notice or our Privacy Policy, please do not hesitate to contact us at the contact information provided in the Section 17. CONTACT US of the general Privacy Policy.

10. CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend our Privacy Policy and this Supplemental Notice at our discretion and at any time. When we make changes, we will post the updated notice on the Website and update the notice’s effective date.