PRIVACY POLICY

You play games to have fun. To have fun you have to relax. And to relax, among other things, you have to know that you"re not giving out more of you than you intend to give! The viability of an on line gaming community is intimately related to the confidence its participants have that its participants have about their private information. We at Silver Creek Entertainment accordingly take this question VERY seriously. Here is a description of our policy as of this date. Changes are possible in the future, but we will try to keep you apprised of any large changes. Please check back frequently.

This policy covers websites owned and controlled by Silver Creek Entertainment. Please note that it does not necessarily control what "other people" may say or do. By "other people" we include such as our "guides" (independent individuals not employed or controlled by us who perform certain functions in the context of social gaming and social interactions through our sites) and we include in "other people" such third parties as those who provide a medium for our games (such as Microsoft through its "X-Box"). By "other people" we also mean certain enterprises that gather and process information that Silver Creek uses internally for such things as processing orders and gathering statistics on our users. We suggest that you review the Privacy Policy of such "other people" which may have terms different from ours.

1. What Information we or other people might gather, and Why.
a. Order and Customer Service Information. This includes the stuff that one volunteers because you expect it as necessary or usual for transacting business with us, such as your name, your age, your email address, your snail-mail address, your telephone number, your credit card information and so forth. It may also from time to time include information that might not be literally required to buy a game but which may be helpful, such as your opinions about something, or demographic information, or the details of your computer configuration that helps us understand our market better, address your questions or concerns, customize your experience, improve our service, address problems as they arise, generally facilitate communication between us, and so forth. Sometimes we will seek information about users or potential users other than yourself, such as when you seek to provide one of our products to such other person as a gift.
b. Automatic gathering. Some information we get automatically. For instance, there is a "conversation" between our system and your computer in which data goes back and forth for such quality assurance/improvement purposes as updates or bug-fixes. We might also send announcements about new products which may be in part based on what we think we understand about you based upon this information. We make use of "cookies" which as you may know are alphanumeric markers used for short term memory purposes like tracking mid-order or site navigation; third parties may also use them to help make the possible relevance of other offers more likely. Such information is generally not personally identifiable. As you may know, you have options on the tool bar of your browser for disabling cookies, but we cannot guarantee that you will have full functionality with Silver Creek sites if cookies are disabled

2. Security.
We do not sell your information! Nobody is hacker-proof. However, we use the highest encryption methods as are technically and commercially reasonable for us to use. A common source of broken security is the failure by a customer to maintain adequate control of passwords. Obviously, we cannot be responsible for that, and we will do our best to not honor orders, points, etc. that involve loss or misuse of passwords. The U.S. Federal Trade Commission has useful information at www.ftc.gov.

3. Using your information.
We use the information generally to know who you are and what your wants and needs might be; specifically we use the information for billing, communicating with you, customer service, card authorizations, quality-control, gathering statistics, offering upgrades, improvements or fixes, tracking to meet royalty obligations, and sometimes to provide you with targeted news or information.

4. Who sees it?
We don"t sell it! We do, however, share some information with those who need it as our employees, agents, or certain third parties with whom we may contract to perform ordinary business functions such as processing credit cards, doing market research, delivering packages to you, etc. It is not currently a practice of ours to either market other products from third parties through our site nor send your information to third parties, except as outlined above; in the event that we do so in the future we will give you an opportunity to "opt out." We may from time to time offer a product or service jointly with a third party, in which event our use of your information will be governed by this Privacy Policy, and the third party"s use of your information otherwise in their possession will be governed by their privacy policy. In the event of a business combination or sale of assets, where your information is an "asset" concerned, we will not disclose without your consent unless otherwise required by law. We do of course reserve the right to disclose generally where such appear required by process of law.

In both your interest and ours, we seek to meet or exceed the requirements of law (e.g. US law, EU law, and the treaties that comprise the "Safe Harbor" coordination of those legal schemes.) We aspire to perfection in that regard. Any questions about privacy may be directed to us by ordinary means and we will do our best to respond.

5. What if I want Silver Creek to just delete everything?
That’s easy. Just send a message to [email protected] and ask for that to be done. We will respond with a link to accomplish that. (Note that you will be required to provide authenticating information on the link we provide i.e., that you are really you; note also that such would result in permanent deletion that cannot be undone.)

SUPPLEMENT TO THE PRIVACY POLICY OF SILVER CREEK ENTERTAINMENT (“SCE”)

(Residents of the European Union)

General Considerations

For Customers who are natural persons residing in the European Union (hereinafter “EU”), there may be additional rights provided in Regulation (EU)2016/679, commonly known as the “General Data Protection Regulation” (hereinafter “GPDR”), effective 25 May 2018, as it pertains to protection of “personal data” of natural persons domiciled in the EU. “Personal data” in the GPDR essentially means information by which one might directly or indirectly ascertain the actual identity, location, etc., of a customer of SCE. For our purposes here, “EU” may include non-EU nations that are members of the European Economic Area (EEA).

Although the GPDR may not in full measure apply to SCE’s minor presence in the EU, the GPDR is not in conflict with SCE’s basic privacy policy, which already affords all protection to our customers and which has not heretofore been breached or violated. Notwithstanding, it is the intent of SCE to comply with the specifics of the GPDR and subsequent amendments and official interpretations to the maximum practicable extent.

SCE gathers information from customers and potential customers with their consent that specifically relates to their purchase of single- or multi-player Internet games, and such ancillary activities as chat-rooms for multi-player games. SCE does not sell or distribute such information, excepting for such consented-to activities such as the use of third-party financial institutions and billing services (e.g., PayPal, Bluesnap, etc.) A customer’s consent may be withdrawn at any time, excepting for certain situations as narrowly described in the GPDR. SCE does not willfully accept such “consent” from customers or would-be customer under the age of 16 without the explicit consent of a parent or guardian, and is particularly amenable to correction where the customer had been under that age at the time they became a customer

Customers have the right to seek from SCE, upon adequate proof of their own identity, identification of such personal data of themselves, the correction of any errors therein, or deletion, subject to certain GPDR exclusions. Note that in some instances the data sought to be identified, corrected, or deleted may be more appropriately found with a third-party, such as a billing agent or channel partner; in such instance SCE will assist insofar as possible but may also direct the customer appropriately. Said third parties consent to comply with, and assist SCE in its compliance with, the GPDR.

Overall, it is SCE’s policy that personal data be handled lawfully, fairly, with transparency, in a portable fashion, and for legitimate business purposes only. EU customers may have additional rights or remedies granted, such as from national authorities in their member state. SCE will continue to develop procedures in compliance with the GPDR, with the advice and consent of such authorities the GPDR may designate for that purpose.

More Specifically…

1. Under applicable law, Silver Creek Entertainment (“SCE” or “we”, “us” etc.) is the “controller” (as that term is used in the GPDR) of personal data collected through our services.

2. When you interact with us, we may collect information from you, as follows:

a. What You Tell us Directly: We collect information from you when you voluntarily provide such information, such as when you register for access to our services or use certain Services. Information we collect may include but not be limited to username, email address, and any messages, images, transient VOIP data (to enable communication delivery only) or such information you provide in the course of game play or chat.

b. What We Collect Automatically: When you interact with us through our services, we receive and store certain information such as an IP address, device ID, and your activities within our services. We may store such information or such information may be included in databases owned and maintained by affiliates, agents or service providers. Our services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of messages users have sent, as well as the sites which refer visitors to SCE.

c. Aggregated Information: In an ongoing effort to better understand and serve the users of our services, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

d. Info through other Services: You may give us permission to collect your information in other services. For example, you may connect a social networking service ("SNS") such as Facebook or Twitter to your SCE account. When you do this, it allows us to obtain information from those accounts (for example, your friends or contacts).

e. Cookies: We may employ cookies and similar technologies to keep track of your local computer’s settings such as which account you have logged into and notification settings. Cookies are pieces of data that sites and services can set on your browser or device that can be read on future visits. We may expand our use of cookies to save additional data as new features are added to the Service. In addition, we may use technologies such as web beacons and single-pixel gifs to record log data such as open rates for emails sent by the system. Also, we may use third party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider's website via your help screen.

f. Advertisements: You may see our Service advertised in other applications or websites. After clicking on one of these advertisements and installing our Service, you will become a user of the Service. Sometimes advertising involves the collection of personal data when a user or potential user ‘clicks’ such advertising. SCE does not offer a “Do Not Track” option directly. However, you may “opt out” of personalized advertising delivered by third parties through programs that are administered by certain third parties, including the Digital Advertising Alliance or Network Advertising Initiative.

3. Processors. SCE is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries. The laws of the U.S. and other countries governing data collection and use may or may not be as comprehensive or protective as the laws of the EU or EU member-state where you live. However, it is the intention of SCE to comply as far as possible with the laws of whichever jurisdiction provides the maximum privacy protection, and to ensure to our best ability that processors and other third parties also respect your privacy.

4.Our Use of Your Personal Data. When you provide us information for a certain reason, we may use the information in connection with the reason for which it was provided. SCE or affiliates may also use your information collected through our services to help us improve the content and functionality of our services, to better understand our users and to improve our services. We may also use such information for marketing purposes, subject however, to your right to “opt out” as described above, or your right to instruct us to remove you from our mailing list. We may also use personal data for customer service, to maximize user experience, to optimize the service with improvements and advise you of such improvements, for the protection of users, or pursuant to legal requirements or process. And, of course, we may use where the user consents, expressly or impliedly. We consider unsolicited information to be information that the discloser consents to use or release.

5.SCE does not sell personal data. However, there are some circumstances where sharing or transfer may occur, such as business reorganization, outside developers or necessary transactions with affiliated companies, channel partners, outside agents or consultants, or the like. There may also be legal obligations arising where such is reasonably necessary for our compliance.

6. Links on our site to unrelated sites do not constitute any representation or guarantee that such other sites are compliant with SCE or the EU’s privacy policies

7. We do not knowingly do business with minors. A “minor” for purposes here is anyone under the age of 16, except in such EU member states where a lower age of consent has been established, but in no event under the age of 13. In the event that you are a parent or guardian of a minor and you have reason to believe that personal information has been disclosed by that minor to SCE, please contact us at the address indicated below, so that we may take corrective action.

8. Retention and Security. We retain for as long as is reasonably necessary for our purposes, subject to backup or other legitimate business procedures. We may take steps to delete or “anonymize” (render not easily identifiable to an actual person by casual inspection.)

Security is to a large degree the responsibility of the individual user. In addition, however, SCE takes reasonable steps to protect any data in our control from access or misuse by unauthorized parties.

9. We may periodically modify this. Please check back from time to time.

10. May reach us concerning your privacy rights, or you just want us to delete everything, please contact us at the following address: [email protected]. For deleting everything, you may request that at that address; we will respond by sending you a link. Please note that the link sent to you will require authenticating information (so we know it is really you) and note also that when we delete everything, it is permanent, i.e., we cannot “undelete” it.

Thank you for your business!