REFRACT STUDIOS, LLC
PRIVACY POLICY
Updated: March 3rd, 2017.
Refract Studios, LLC (“Refract”) is committed to protecting your privacy. This Privacy Policy describes how Refract may collect, use and disclose information when you access or use Refract Services. Terms used herein but not defined shall have the meanings set forth in the End User License Agreement (the “Agreement”).
IN ADDITION TO ACCEPTING THE TERMS OF THE AGREEMENT (WHICH IS HEREBY INCORPATED BY REFERENCE) YOU ALSO AGREE TO BE BOUND TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY DO NOT ACCESS OR USE SERVICES OR VOLUNTARILY SUBMIT ANY INFORMATION (INCLUDING PERSONAL IDENTIFIABLE INFORMATION SUCH AS YOUR NAME, EMAIL ADDRESS AND OTHER NON-PUBLIC INFORMATION) TO REFRACT.
1. WHAT TYPE OF INFORMATION DOES REFRACT COLLECT?
a. Personal Identifiable Information. Refract collects Personal Identifiable Information (“PII”) you voluntarily provide in connection with your use Services. PII includes your:
· Name.
· Phone number.
· Email address.
· Other PII you voluntarily share.
b. Non-personal Identifiable Information. Refract uses industry standard technologies to collect certain information about your device and this may include sending cookies to your computer or gaming counsel (“Non-personal Identifiable Information”). Cookies are small data files stored on your hard drive or in your device memory that helps improve your experience with Services. Refract may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used with Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Opting Out” below.
2. HOW DOES REFRACT USE YOUR INFORMATION.
a. Use. Refract may use PII, Non-personal Identifiable Information; and/or Analytical Information:
· To provide Services to you and other users.
· To enhance existing Services or develop new Services.
· To perform analytics on your use of Services.
· With third-party service providers (such as Valve, PS4, Amazon Web Services, and other suppliers that aid in the delivery of Services).
· To alert you of new products, Services and promotions that may be offered by Refract or designated select partners.
· To protect the interests of Refract, other Service users and/or to enforce one or more provisions of the Agreement and/or Privacy Policy.
· To communicate with you, including through newsletters and email notifications, confirmations, technical notices, updates, security alerts, and support and administrative messages that you may request.
b. Disclosure. Refract may disclose PII: (i) upon lawful request, in response to legal process, and when required to comply with laws; (ii) to enforce the terms of the Agreement or this Privacy Policy or; (iii) to protect the rights, property or safety of Refract, our employees, agents, customers, and other Service users.
3. INFORMATION SECURITY. Refract takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorized access, disclosure or modification of your PII. While Refract takes reasonable efforts to safeguard your personal information, no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
4. OPTING OUT. If you no longer wish to receive communication regarding new products and/or Services offered by Refract you may opt out by following the unsubscribe link located at the bottom of each communication. If you opt out, Refract may still send you non-promotional communications about Services. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. If you choose to reject all cookies, you may be unable to use certain Services. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the use does not wish to be tracked. California law requires that an operator of a website or other online service disclose how the operator responds to a Do Not Track signal and whether third parties may collect information about an individual’s online activities from the operator’s website.
5. THIRD-PARTY WEBSITES.
The Services may contain links to third-party websites. Refract does not review the privacy practices of these other websites and recommends that you review their privacy policies before sharing your personal information. Refract does not have any control over such third-party websites and is not responsible for their privacy policies or practices.
6. CHILDREN.
Refract does not knowingly collect PII directly from users under the age of 13. Consistent with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), Refract will not knowingly request or collect PII from any child under age 13 without first obtaining the required parental consent. Children can browse Services without PII being collected. If you are a parent or legal guardian and permit you child to use Services, you agree that Refract may collect, store, use and process your child’s PII for the purposes described in this Privacy Policy. If Refract learns that a user under 13 years of age has submitted PII through Services without his or her parent or legal guardian’s consent, Refract will take reasonable measures to obtain consent by contacting the child’s parent or legal guardian if possible and shall, if consent cannot be or is not obtained, take reasonable measures to delete such information from its databases and not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). If Refract obtains the required consent from the parent or guardian of a child under 13, we will only ask for PII that is reasonably necessary the use Services. Refract will only maintain PII for only as long as reasonably necessary to fulfill these purposes. The parent or legal guardian who has consented to a child providing PII may later view the child’s PII and correct or remove the information, in whole or in part; instruct Refract to discontinue all use of the child’s PII and/or not to communicate further with the child; or revoke or modify the consent, by contacting Refract at team@refract.com and including the child’s name and email address and the parent or guardian’s name and email address. Please visit http://www.ftc.gov/privacy/privacyinitiatives/childrens.html for information from the Federal Trade Commission about protecting children’s privacy online.
7. CALIFORNIA LAW. Under California Civil Code Section 1798.83, if an individual who is a California resident has provided PII to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual's PII to a third-party and knows or should have known that such third-party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what PII was shared and with whom it was shared. Any request for a disclosure required under this California law should be sent to Refract at: team@refract.com, 1191 2nd Ave #1800 Seattle, WA 98101.
8. INTERNATIONAL VISITORS.
The Services are hosted in and provided from the United States. If you access and/or use Services from the European Union (“E.U.”) or other regions with laws governing data collection and use that may differ from the laws of the United States of America (“U.S.A.”), please note that you are transferring your personal data to the U.S.A. The U.S.A. does not have the same data protection laws as the E.U. and some other regions. By providing your PII you consent to the transfer of your personal data to the U.S.A. and the use of your PII in accordance with this Privacy Policy.
9. PRIVACY POLICY UPDATES. Refract may update this Privacy Policy from time to time. When Refract does so, Refract will post the new Privacy Policy on homepage. Your continued use of Services is deemed to be acceptance of such updates. Refract encourages you to check the date of our Privacy Policy when you access and use Services for any updates or changes.
10. CONTACT INFORMATION. Refract welcomes your questions, comments and concerns about privacy. Refract can be reached at: 1191 2nd Ave #1800 Seattle, WA 98101, team@refract.com, (971) 251-0353.