Privacy Policy and Notice at Collection

Effective Date: July 1, 2023

Below is our Privacy Policy. It is long, but worth the read as it explains how we use your personal information. At a high-level, we wanted to explain what personal information we process for Among Us and our website.

Among Us:

• To protect our child users, we use your date of birth, country, and IP address to verify whether you are a child.
• To create an account, we will collect your username, IP address, and email address. If you are a child user, we will send your parent’s email to Kids Web Services, so your parent can set your permissions regarding personal information for our game.
• To link your account with another game platform account, we will use your username and online IDs, and in some cases, your IP address and email address.
• If you buy something in-game, we may receive additional personal information to fulfill those purchases such as your name, address, and payment information.
• If you are in a lobby when another user reports you for violations of our Terms of Use or other inappropriate conduct, your username, IP address, and gameplay information may be stored for moderation purposes.
• If you reach out to us directly, we may use that information to help fix the problem you reported.
• We do not collect any sensitive information from you, such as your precise geolocation, or sell or share your personal information for ads or profiling purposes.
• Please do not put private information in your username or chat. Someone may use or save it even if we do not.

Website:

• If you buy something on our website, we will use your name, postal address, telephone number, email address, payment information, and purchase history to fulfill those orders.
• If you sign up for our marketing newsletter, we will use the email address you provide.
• If you reach out to us directly, we may use the information provided to help fix the problem you reported.

Innersloth LLC, a Washington limited liability company (“we,” “us,” “our,” and their derivatives) provides websites, including www.innersloth.com and its subdomains (collectively, the “Website”), the videogame known as “Among Us” (the “Game”), and other online services (collectively, with the Website and the Game, the “Services”).

1. What does this Policy cover? 

This Privacy Policy and Notice at Collection (this “Policy”) sets forth how we collect, use, protect, store, disclose, and otherwise process your Personal Information (defined below). Because we do not process any Personal Information for our videogames known as “Dig2China,” “Henry Stickmin Collection,” and “Among Us VR,” those games are not covered by this Policy. You should review Schell Games’ Privacy Policy for more information about how it collects, uses, and shares the Personal Information it obtains and uses for “Among Us VR.”

This Policy also does NOT apply to information you provide to any third party or is collected by any third party (except as otherwise provided below).

By using our Services, you are confirming that you understand English well enough to understand this Policy. Should you have questions about this Policy, please contact us by emailing us at [email protected] or mailing your questions to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.

2. How do we process Children’s Personal Information? 

A “Child” is a person under the age needed to consent to the processing of Personal Information in their country of residence (for example, 13 years old in the United States and between 13 and 16 years old in the European Union). Please see below for a summary of our practices with respect to the collection of Personal Information from Children and the use and disclosure of such information.

Quick-Chat Mode

If a user of our Game self-identifies or is identified by us as being a Child (each, a “Child User”), their gameplay experience will automatically be set to “Quick-Chat Mode,” unless the parent or legal guardian of the Child permits otherwise. Child Users in Quick-Chat Mode are restricted from communicating with or otherwise making their Personal Information publicly available to other users of our Game. Child Users will only be able to use a set of fixed phrases to communicate with other users in Quick-Chat Mode and will not have links to social media in our Game. Each of these features is designed to limit our access and the access of other users of our Game to the Personal Information of Child Users in compliance with the Children’s Online Privacy Protection Act of 1998 and its rules (“COPPA”).

Accounts

Child Users may register an account with us using a registration process similar to the one adults go through; however, in compliance with COPPA, Child Users will first be subject to a parental notice and verified parental consent process. To initiate the registration and consent process for a Child User, we collect a parent or legal guardian’s email address. We will automatically generate randomized usernames for registered Child Users, unless the parent or legal guardian grants the Child User permission to create a custom username.

Child Users using an Apple or Google family sharing account are not permitted to register another account with us and are subject to the most restrictive privacy settings in the Game.

Use and Disclosure

The Personal Information we collect from or about Child Users is used to give them access to certain features of our Game and communicate with a parent or legal guardian about the Child User’s registration, including for the purpose of verifying their information in connection with the registration. We do not share or otherwise disclose Child Users’ Personal Information, except (1) as may be necessary to protect the safety of a Child, including by disclosing their Personal Information, where appropriate, to law enforcement agencies or for an investigation related to public safety; (2) to enable us to take precautions against liability; (3) to protect the integrity, safety, and security of our Game; or (4) where required to do so by law or legal process.

We and the third-party service providers listed below may collect or maintain Child Users’ Personal Information through our Game. You should review their privacy policies linked below.

• Kids Web Services (a parental and legal guardian consent management provider);
• Zendesk, Inc. and Keywords Studios Plc (each a player support service provider);
• ModSquad, Inc. (a moderation service provider); and
• Epic Games, Inc. (in its capacity as a backend service provider (for example, for account management and linking)).

When a parent or legal guardian consents to permitting their Child User’s account to be linked with any of the below third party digital content stores and game platforms, we may receive such Child User’s Personal Information through our Game. You should review their privacy policies linked below.

• Itch Corp.;
• Epic Games, Inc.;
• Google LLC;
• Microsoft Corp.;
• Apple Inc.;
• Valve Corp.;
• Sony Interactive Entertainment LLC; and
• Nintendo of America Inc.

Please contact us with questions about our service providers’ privacy policies and our collection and use practices by emailing us at [email protected] with the subject line “Children’s Privacy” or mailing your request to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.

At any time, a parent or legal guardian may review their Child’s Personal Information retained by us, require us to correct or delete such Personal Information, request that we delete their Child’s account, and/or refuse to permit us from further collecting or using their Child’s Personal Information by contacting us using the email or mailing address provided above. To protect parents and legal guardians’ privacy and security and the privacy and security of Child Users, we may require a parent or legal guardian to take certain steps or provide additional information, which we will keep strictly confidential, to verify their identity before we provide any information about the Child or take the requested actions.

Kids Web Services

Our Game is provided and operated by us. However, some functionalities of our Game, including the parent portal and contact with parents for purposes of obtaining verified parental consent and informing parents of their Child User’s online activities, are operated by Kids Web Services (“KWS”). You may contact Kids Web Services directly here or [email protected] for any questions related to their use of Personal Information. KWS’s privacy policy can be found here.

Kids Web Services is designed specifically to power kid-friendly registrations and digital experiences, as well as parental management tools, across the web and mobile ecosystem in compliance with the COPPA and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation). KWS is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. The kidSAFE Seal Program is an independent safety certification service and seal-of-approval program designed exclusively for children-friendly websites and technologies, including child-targeted game sites, educational services, virtual worlds, social networks, mobile apps, connected products, and other similar interactive services and technologies. Click on the seal or go to www.kidsafeseal.com for more information. To learn more about COPPA, you may also consult this simple one-page informational guide from the kidSAFE Seal Program: www.kidsafeseal.com/knowaboutcoppa.html.

Kids Web Services is also a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, Kids Web Services has voluntarily undertaken this privacy initiative, and its services have been reviewed by ESRB Privacy Certified to meet established online information collection, use, and disclosure practices. As a licensee of this privacy program, Kids Web Services’ services are subject to audits and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

3. What categories of Personal Information do we collect?

We may collect different types of information from you depending on how you use our Services, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person. The categories of Personal Information we may collect are listed below. Certain types of Personal Information may fall under more than one category.

We do not knowingly or intentionally process any sensitive Personal Information.

We may also collect information that does not generally identify you but may become associated with your account. We may use information that does not identify you for any permissible business or operational purpose under applicable law.

4. From what sources do we collect Personal Information?

Directly From You

We may collect your Personal Information when you provide it to us directly, including the examples below.

• When you open our Game, we may collect your date of birth.
• When you create an account for our Game, we may collect your username and email address.
• When you use the public functions in our Game or on our social media accounts (such as Discord, TikTok, Twitch, Twitter, Facebook, and Instagram), we may collect the information you choose to disclose. 
• When you sign up for our newsletter, we may collect your email address.
• When you contact us or report a problem with our Services, we may collect your email address, first and last name, and records and copies of your correspondence.
• When you respond to a survey or questionnaire, we may collect the information you provide.

Automatically From You

We may collect your Personal Information automatically as you use our Services. For example, we may collect your Personal Information as you interact with our Website or as you play our Game. For more information about our and third parties’ use of cookies and other automatic data collection technologies, and certain choices we offer to you with respect to them, please see Section 5 below.

From Third Parties

We may receive your Personal Information from or through third parties that help us provide or facilitate your access to our Services, including those listed below. 

• E-commerce and merchandising service providers such as Shopify Inc.: For example, when you purchase merchandise from our merchandise Website, we may receive your first and last name, postal address, email address, phone number, purchase history, and payment information.

• Player support service providers such as Zendesk, Inc.: For example, when you contact us or report a problem with our Services, we may collect your email address, support ticket ID, and records and copies of your correspondence.

• Digital content stores and game platforms such as those operated by Itch Corp., Epic Games, Inc., Google LLC, Microsoft Corp., Apple Inc., Valve Corp., Sony Interactive Entertainment LLC, and Nintendo of America Inc.: Examples below.
  • When you link your account, we may receive your username from Epic Games, Google, Microsoft, Apple, Valve, Sony, or Nintendo, and your platform ID from Itch, Epic Games, Google, Microsoft, Apple, Valve, Sony, or Nintendo. In addition, we may receive your Internet Protocol address from Apple and your email address from Itch.
  • If you purchase in-Game content or features after linking your account, we may receive your purchase history from Itch, Epic Games, Google, Microsoft, Apple, Valve, Sony, or Nintendo. In addition, we may receive your zip code, city, and state or country from Google.
  • When you send invites to your friends to play our Game, we may receive your platform ID from Itch, Epic Games, Google, Microsoft, Apple, Valve, Sony, or Nintendo.
  • If you leave a review about our Game in the Microsoft Store, we may receive your device type, username, and country.
  • When you contact Google regarding a problem with our Game, we may receive your purchase history, zip code, state or country, and city.
  • To display your friends list or accept an invite from a friend to play our Game, we may receive the usernames of your friends from Epic Games, Google, Microsoft, Apple, Valve, Sony, or Nintendo.

• Payment service partners such as Xsolla (USA), Inc.: For example, when you purchase a key through https://buy.among.us/, we may receive your email address, non-precise geolocation, and payment information. 

• Backend service providers such as Epic Games, Inc.: For example, when you create an account, we may receive your online and device IDs from Epic Games.

• Analytic service providers such as Unity Technologies: For example, when you install our Game, we may receive an online ID from Unity, excepting Child Users.

• Diagnostic service providers such as Functional Software, Inc. d/b/a Sentry: For example, when you install our Game, we may receive an online ID from Sentry, excepting Child Users.

• Parental and legal guardian consent management providers such as Kids Web Services: For example, if you are a Child User, we may receive your platform ID and date of birth from Kids Web Services.

• Other users of our Game: If a user reports to us that you are violating our Terms of Use by using offensive language in the public functions of our Game or are attempting to hack our Game, for example, we may collect the information provided by that user about you and create a report of your actions. If you are a parent or legal guardian of a Child User, we may receive your email address from your Child User.

We abide by this Policy when we use Personal Information provided to us by third parties. However, we may not control the Personal Information that third parties collect or how they use that Personal Information. You should review the third parties’ privacy policies for more information about how they collect, use, and share the Personal Information they obtain and use.

5. How do we and third parties use cookies and other automatic data collection technologies?

Cookies are small data file identifiers that are transferred to your computer or mobile web browser that allow us and third parties to recognize your browser or mobile device and transfer information about you and your use of our Services.

Our Cookies and Other Automatic Data Collection Technologies

We may use cookies and other automatic data collection technologies on our Services to collect Personal Information, including the examples below.

• When you visit our Website, we may collect information regarding your interaction with our Website, including pages viewed.
• When you create an account for our Game or play our Game, we may automatically collect your Internet Protocol address.
• When you contact us or report a problem with our Services, we may collect your Internet Protocol address and device information.
• When you are reported by another user in-Game, we may automatically collect your chat logs and past sanctions.

Third Party Cookies and Other Automatic Data Collection Technologies

Cookies and other automatic data collection technologies on our Services may come from third parties as listed below. These cookies and other automatic data collection technologies improve your experience by helping us better tailor our Services to you.

• Shopify Inc.: We may use Shopify, an e-commerce service offered by Shopify Inc., a Canadian corporation, with offices located at 151 O’Connor Street, Ground floor, Ottawa, Ontario, K2P 2L8. Shopify may use automatic data collection technologies to collect your Personal Information on our behalf to help us improve our merchandise Website (such as your interaction with our merchandise Website and Internet Protocol address). For more information about Shopify’s privacy practices, you can review its Cookies Policy.

• Unity Technologies: Excepting Child Users, we may use Unity Analytics, an analytics service offered by Unity Technologies SF, 30 3rd Street, San Francisco, CA 94103, and Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland. Unity may use automatic data collection technologies to collect Personal Information directly from your device and use this Personal Information to help us analyze your use of our Game. You should review Unity’s Cookies Policy, which includes instructions on how to restrict the collection of your Personal Information (such as your purchase history, Internet Protocol address, non-precise geolocation data, and certain gameplay information).

• Functional Software, Inc. d/b/a Sentry: Excepting Child Users, we may use Sentry, a diagnostics service offered by Functional Software, Inc. d/b/a Sentry. Sentry may use automatic data collection technologies to collect your Personal Information on our behalf to help us improve our Game (such as your Internet Protocol address, device information, purchase history, and game play information). For more information about Sentry’s privacy practices, you can review its Privacy Policy.

• Xsolla (USA), Inc.: We may use Xsolla, a payment service offered by Xsolla (USA), Inc. Xsolla may use cookies to collect your Personal Information on our behalf to help us with key purchases for our Game (such as your Internet Protocol address). For more information about Xsolla’s privacy practices, you can review its Cookies Policy.

Choices about Cookies

You may set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Please note that, if you disable or refuse cookies or other automatic data collection technologies, some aspects of our Services may be inaccessible or not function properly.

6. For what purposes do we collect your Personal Information?

In addition to the purposes described above, we may collect your Personal Information for the below purposes.

• To provide or improve our Services: We may use your Personal Information to process your requests to access our Services and certain of their features and to generally present and improve our Services. For example, we may use your Personal Information to improve our Game.

• To administer our Services: We may use your Personal Information for any lawful business or operational purpose in connection with administering our Services. For example, if you reach out to us, we may use your Personal Information to respond to you or to troubleshoot a problem you reported having with our Services. 

• To market our Services: We may use your Personal Information to market our Services to you. For example, with your prior consent, we may send you news and updates about our products and our Services.

• In furtherance of legal and safety objectives: We may access, use, and share with others your Personal Information for purposes of safety and other matters in the public interest. We may also provide access to your Personal Information to cooperate with official investigations or legal proceedings (e.g., in response to subpoenas, search warrants, court orders, or other legal processes). We may also provide access to your Personal Information to protect our rights and property and those of our agents, users, and others, including to enforce our agreements, policies, and our Terms of Use. For example, we may use your Personal Information to respond to inappropriate or reported conduct in-Game and to enforce user bans for our Game.

• In connection with a sale or other transfer of our business: In the event all or some of our assets are sold, assigned, or transferred to or acquired by another company due to a sale, merger, divestiture, restructuring, reorganization, dissolution, financing, bankruptcy, or otherwise, your Personal Information may be among the transferred assets.

• As we may describe to you when collecting your Personal Information: There may be other situations when we collect your Personal Information and simultaneously describe the purpose for that collection.

Lawful Basis

We only collect, use, or store your Personal Information for a lawful basis such as:

• you voluntarily provide it to us with your specific, informed, and unambiguous consent (for example, when you sign up for our newsletter);
• it is necessary to provide you with a Service that you have requested (for example, providing you access to our Game);
• we have a legitimate business interest that is not outweighed by your privacy rights (for example, to respond to your inquiries); or 
• it is necessary to protect your vital interests or the vital interests of others (for example, where necessary to protect the safety of one of our users or someone else).

7. In what situations do we disclose your Personal Information?

We may disclose your Personal Information to a third party, such as a service provider or contractor for a business or operational purpose, or with your consent. When we disclose Personal Information for a business or operational purpose, we enter into a contract with the service provider or contractor that describes the purpose and requires the service provider or contractor to both keep that Personal Information confidential and not use it for any purpose except performing the contract. These service providers and contractors include our:

• backend service providers such as Epic Games, Inc.;
• e-commerce and merchandising service providers such as Shopify Inc., Dual Wield Studio LLC, and Penny Arcade, Inc.;
• parental and legal guardian consent management providers such as Kids Web Services; and
• player support and moderation service providers such as Keywords Studios Plc and ModSquad, Inc.

We may also disclose your Personal Information:

• to our subsidiaries and affiliates;
• to our lawyers, consultants, accountants, business advisors, and similar third parties who owe us duties of confidentiality;
• to a buyer or other successor in the event of a sale, merger, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information retained by us pertaining to the users of our Services is among the assets transferred;
• to comply with any court order, law, or legal process, such as responding to a government or regulatory request;
• to enforce any contract we may have in effect with you;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others; and
• if you have consented to such a disclosure.

We do not sell, rent, or share your Personal Information for cross contextual behavioral or targeted advertising, automated decision-making, or profiling purposes.

8. How is my Personal Information protected?

Our Retention, Purpose Limitation, and Security Policies

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

• Limited retention: We retain each category of Personal Information only for as long as necessary to fulfill the purposes for which the Personal Information was provided to us or, if longer, to comply with any legal obligations, to resolve disputes, and to enforce contracts. For example, we may retain Personal Information collected about you to prevent repeated violations or suspected violations of our Terms of Use if your account has been banned or your access to our Services has been disabled for any reason. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, subject to the foregoing considerations, it is our policy to delete your Personal Information if we stop operating our Game or the feature through which the Personal Information was acquired.

• Purpose limitation: We will use your Personal Information only for our Services you choose to access and for the purposes notified to you, unless we otherwise obtain your consent. We limit the collection of Personal Information to what is adequate, relevant, and reasonably necessary for those purposes.  

• Security measures: We use reasonable security measures to ensure a level of security appropriate to the volume and nature of Personal Information processed and risk involved, considering the size, scope, and type of our business, and have implemented contractual, technical, administrative, and physical security measures designed to protect your Personal Information from unauthorized access, disclosure, use, and modification, including industry-standard encryption for the transmitting of Personal Information (e.g., DTLS, TLS 1.2+, HTTPS) and industry-standard hashing techniques for the retention of Personal Information (e.g., SHA256+Salt). As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this Policy does not guarantee the security of your Personal Information. In the event of a security breach, we will notify the proper regulatory authorities and any affected users of the breach within 72 hours after we become aware of the breach to the extent required by applicable law.

Your Practices and Activities

Your practices and activities are likewise very important for the protection of your Personal Information. You should take certain steps to help protect your Personal Information, such as being mindful of what you share publicly in our Game, including the below.

• Do not use your real name when selecting a username.

• Do not share your real name or anything private about yourself or anyone else with other users of our Game.

• Do not pick a password that is easy to guess, and do not share your password. 

Please remember that we have no control over what other users do with the content of your communications and no responsibility or obligation regarding other users.

9. How do we treat Personal Information transferred to the United States?

Place of Business

We may store or process your Personal Information outside of the country where we collect the information or the country in which you reside. Our primary place of business is in the United States. You should understand that we may transfer some or all of your Personal Information to the United States to carry out certain operational and processing needs as described in this Policy.

Transfer Mechanisms

When transferring Personal Information out of foreign countries, we implement technical, organizational, and physical safeguards to protect your Personal Information. We use European Commission approved standard contractual clauses and implement related measures where required by applicable law. Please contact us if you have questions related to the relevant transfer mechanism for your Personal Information.

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

Right to Access, Correct, Delete, or Restrict Processing

Subject to any limitations and exceptions under applicable law, you have the right to request access to your Personal Information and exercise the below rights. 

• You have the right to correct or update certain types of Personal Information. In many cases, you can review or update your account information by accessing your account online.

• You have the right to request deletion of your Personal Information. If you choose to have your Personal Information removed from our Services, we will carry out your request within 30 days of account verification, subject to extension, and we will only retain minimal Personal Information to document your request and the actions we took to carry out your request.

• You have the right to restrict certain processing of your Personal Information and the right to object to some types of processing of your Personal Information. 

• You have the right to withdraw your consent at any time.

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

We will comply with your requests in accordance with, and subject to, applicable law. For example, we are not required to delete your Personal Information if we have an overriding legitimate ground for retaining that information, such as to prevent fraud. Please note that we are legally prohibited from carrying out requested actions in some instances, including (1) when we are unable to confirm your identity or (2) where doing so would adversely affect the rights or freedoms of others. Further, we are not required to carry out a requested action in some instances, including where the request is considered excessive.

We are Here to Help

Please email us at [email protected] with the subject line “Privacy Request” or mail your request to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA if you would like to exercise any of the rights described above or if you have questions regarding your rights.

11. Additional Notice for California, Colorado, Connecticut, Utah, and Virginia Residents

California Online Privacy Protection Act

The following applies to California residents:

• We do not track users of our Services over time and across third party websites or online services and therefore do not respond to Do Not Track signals. We are not aware of any third party that tracks users of our Services over time and across third party websites or online services. Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control, a legally recognized browser-based control that indicates whether you would like to opt out of the processing of your Personal Information for certain purposes.

California Shine the Light Law

The following applies to California residents:

• California residents may 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, please email us at [email protected] with the subject line “California Shine the Light Law” or mail your request to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.

State Privacy Laws

The following applies to California, Colorado, Connecticut, Utah, and Virginia residents (in the event of a conflict between this Section 11 and any other section in this Policy, this Section 11 controls):

• Right to Know and Access: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive and confirm your verifiable consumer request, we will disclose to you the following, to the extent retained by us:
  • the categories of Personal Information we collected about you;
  • the categories of sources for the Personal Information we collected about you;
  • our business or commercial purpose for collecting, selling, or sharing that Personal Information;
  • the categories of third parties with whom we disclose that Personal Information;
  • the specific pieces of Personal Information we collected about you (also known as a data portability request); and
  • if we sold or shared your Personal Information, two separate lists disclosing (1) sales, identifying the Personal Information categories that each category of recipient purchased, and (2) disclosures for a business or operational purpose, identifying the Personal Information categories that each category of recipient obtained.

• Right to Deletion: You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and contractors to delete) your Personal Information from our records, unless an exception under applicable law applies. We may deny your deletion request if retaining the information is necessary for us or our service providers or contractors to:
  • complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide our Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • help to ensure the security and integrity of our Services to the extent the use of your Personal Information is reasonably necessary and proportionate to those purposes;
  • debug our Services to identify and repair errors that impair existing intended functionality;
  • exercise free speech, ensure the right of another user to exercise their free speech rights, or exercise another right provided for by law;
  • comply with the California Electronic Communications Privacy Act;
  • 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 Personal Information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided consent;
  • enable solely internal uses that are reasonably aligned with user expectations based on your relationship with us and compatible with the context in which you provided the Personal Information; or
  • comply with a legal obligation.

• Right to Correction: You have the right to request that we correct inaccurate Personal Information. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate Personal Information, taking into account to the nature of the Personal Information and the purposes of the processing of the Personal Information.

No Discrimination

We will not discriminate against you for exercising any of your privacy rights under applicable law. Unless permitted by applicable law, we will not:

• deny you our Services;
• charge you different prices or rates for our Services, including through granting discounts or other benefits, or imposing penalties;
• provide you a different level or quality of our Services; or
• suggest that you may receive a different price or rate for our Services or a different level or quality of our Services.

Verifiable Consumer Requests

To exercise your rights described above, please email us at [email protected] with the subject line “State Privacy Rights” or mail your request to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. The verifiable consumer request must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of verifiable consumer request, unless you request a longer period of time for Personal Information we collected about you after January 1, 2022. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

To appeal a decision regarding your verifiable consumer request, please submit your appeal using one of the two methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

For data portability requests, we will select a format to provide your Personal Information that is readily useable, easy-to-understand, and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

12. How will we notify you of changes to this Policy?

We reserve the right to change this Policy from time to time consistent with applicable law. If we make changes to this Policy, we will notify you by revising the date at the top of this Policy and provide you with additional notice such as an in-Game notice or email notification.

In the event that any changes we make to this Policy affect Child Users in a way that requires prior parental consent under COPPA, we will obtain such prior parental consent.

13. How can you contact us?

If you have questions, you may email us at [email protected] or mail your questions to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.

If you are a law enforcement agency, please email us at [email protected] with your request for Personal Information with the subject line “Law Enforcement Request” or mail your request to Innersloth LLC, PO Box 2532, Redmond, WA 98073, USA.