Trustom, Inc.
Privacy and Cookie Policy
Last Updated: December 23, 2018
Effective Date: December 23, 2018
Your privacy is important to us, and we take our responsibility of caring for it seriously. This policy describes what information Trustom collects when you use the mobile, online and downloadable products and services offered by Trustom and its subsidiaries and/or watch live events hosted by or in connection with Trustom (“products“). The main subsidiary of focus here is EProAm.com.

TABLE OF CONTENTS

  1. Information We Collect
  2. How We Collect Information
  3. How We Use Your Information
  4. Information We Share with Third Parties
  5. Where We Hold Your Information
  6. How We Protect Your Personal Information
  7. Children
  8. Your Choices and Controls
  9. Third Party Services
  10. Changes to Our Policy
  11. Contact Us
  12. Right to Contact a Data Protection Authority
  13. Further Information

1. Information We Collect

The information we collect depends on what products you use and how you use them. Please see below for more details.

A. Information You Give Us Directly

We collect information you provide us, including:

  • Your EProAm.com Account information, including email address, username, country, date of birth, telephone number, discord information and password;
  • Security questions and answers;
  • Details you provide in response to surveys about our products;
  • Information you provide when seeking help from us such as your name, telephone number and records of the issues you experience; and
  • Billing information, such as your name, payment card number and payment account details;

When you participate in social features (such as chat), the information that you disclose may become publicly available. It also may be read, copied, collected or used by other users. Please make sure your privacy settings reflect your preferences.

B. Other Information We Collect When You Use Our Products

We collect other information automatically when you use our products, including:

  • IP address;
  • Mobile and other hardware or device identifiers;
  • Browser information, including your browser type and the language you prefer;
  • Referring and exit pages, including landing pages and pages viewed;
  • Platform type;

We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.

C. Information Provided to Us by Third Parties

Discord. By signing up to website using Discord, you agree your Discord account information will be provided to EProAm.com so we can establish an EProAm.com Account for you.  From Discord, we receive information including your name, email address, Discord name, and Discord deliminator. We do not receive your credit card number or other financial information.

Other Third Parties

We may receive information from third parties, like Facebook, Twitch, Google, Twitter or Omlet Arcade, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us.

We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A list of these types of third parties. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.

D. Legal Basis for Processing

If you are a resident of the European Union, we rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you create an EProAm.com Account. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via the options in Section 11 below.

2. How We Collect Information

We collect some information from you when you provide it to us directly, such as via an online form or when you talk with our customer experience team. We and third parties also use certain technologies described below to collect information to deliver excellent experiences.

A. Cookies and Similar Technologies

Cookies are small text files stored on your Internet browser. We use cookies and similar technologies to help us understand things like what web pages, features or ads you view and what games you play. This information helps us keep track of your shopping cart, measure the effectiveness of our advertising, make sure you don’t see the same ad repeatedly and otherwise help enhance your user experience. You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you’d like help in managing your cookie preferences.

We use other technologies for similar purposes as a cookie. We use pixels or clear GIFs to collect information about your use of our products and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our products, troubleshoot technical problems, detect and prevent fraud and enforce our User Agreement. Other examples include HTML 5 cookies, Silverlight Application Storage, device fingerprints and “flash cookies.” If you want to remove flash cookies or prevent them from being placed, adjust your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com/support/documentation/en/flashplayer/help/. We currently do not respond to Do Not Track (DNT) signals. We may adopt a DNT standard if one is established. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.

We also use Analytics and Advertising technologies in our website that utilize the same cookies and similar mechanisms. These technologies are described below.

B. Analytics Technologies

We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.

For instance, EProAm.com may collect and store data from your computer or device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), information about your feature usage and usage statistics, system interactions and peripheral hardware for purposes described in section 3, below. If you participate in online services, EProAm.com also may collect, use, store, transmit and publicly display your persona and/or statistical data regarding your game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.

Third party analytics services integrated into our products may combine the information they collect in connection with EProAm.com’s website with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies.

C. Ad Serving Technologies

Some of our products employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different websites, mobile apps and devices. The ads can be tailored to your interests. For instance, you may be presented with an offer for a game we think you might enjoy. Or if you express interest in a game, you might receive an advertisement later for that game or similar products on EProAm.com or third party sites. Other in-game advertising technologies enable advertising to be temporarily uploaded to your game, web browser, or mobile device and later replaced while you are online.

These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes:

  • Advertisements served and the location of the ad;
  • Length of time an advertisement was visible;
  • Domain type, IP address, size of the advertisement; and
  • Advertisement response.

Third party advertising companies may combine the information collected in the context of delivering an ad to you via our products with other information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies.

To learn more about some of these ad networks’ practices, or to opt out of third party targeted advertising, you can visit www.networkadvertising.org, www.aboutads.info/choices, youradchoices.ca, or www.youronlinechoices.eu. Note that opting out does not mean you won’t see ads; it just means that the advertising you see may be less relevant to your interests.

3. How We Use Your Information

We use your personal and non-personal information, both individually and combined together, in the following ways:

To operate our business and to enhance and personalize your game experience including to:

  • Help you find your friends or tell your friends about an EProAm.com website;
  • Facilitate sharing on social networks;
  • Serve and measure the effectiveness of advertising;
  • Set up and maintain accounts you register for;
  • Set up loyalty programs;
  • Identify, fix, and troubleshoot bugs and service errors;
  • Run competitions and contests;
  • Adhere to your preferences and to deliver dynamic content; and
  • Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.

To provide you support, including to:

  • Survey your opinions through surveys or questionnaires;
  • Communicate with you and respond to your specific requests or questions; and
  • Manage and send you confirmations and important information about your account, products, and subscriptions.

To personalize our communications with you, including to:

  • Present offers and/or information relating to games you might like;
  • Make recommendations to you; and
  • Personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

We retain the information we collect for as long as necessary to provide our products and services, and we may retain that information beyond that period if necessary for legal, operational or other legitimate reasons.

4. Information We Share with Third Parties

We do not share personal information that directly identifies you (such as your name, e-mail or postal address) with third parties for their own use without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona and game stats on leaderboards or to show trends about use of our products.

We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys, facilitating credit card processing, or sending emails. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.

We do not knowingly disclose directly identifying personal information from children under 18 years of age to independent third parties even with consent.

However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.

We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook “Like” button.

5. Where We Hold Your Information

Personal information we collect may be stored and processed for the purposes set out in this Privacy and Cookie Policy in the United States or any other country in which Trustom, its subsidiaries, or third party agents operate. By using our products, you acknowledge that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

EProAm.com’s privacy practices comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found at https://www.apec.org/Groups/Committee-on-Trade-and-Investment/~/media/Files/Groups/ECSG/CBPR/CBPR-PoliciesRulesGuidelines.ashx.

Information is collected by our parent company, Trustom, Inc.

6. How We Protect Your Personal Information

Security of our players’ information is a priority at EProAm.com, and we take a range of measures to help protect it, including encryption of sensitive financial information. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.

7. Children

Protecting children’s privacy online is extremely important to EProAm.com. When users identify themselves as being children we will: (1) not provide a path for them to input personal information, (2) collect certain information for limited purposes only, (3) block or restrict the child from accessing relevant services, such as chat functionality; and/or (4) obtain consent from parents for the use of their children’s personal information, all according to applicable law. When we say children, we mean under the age of 13 or the minimum age in the relevant territory if that age is older than 13.

Please note that if you grant consent for your child to use EProAm.com’s online or mobile products and services, this may include such general audience communication services as email, instant messaging, and online groups, and your child will be able to communicate with, and disclose personal information to, other users of all ages.

If you are a parent and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, contact the appropriate Privacy Policy Administrator at eproam.com/contact .

Information collected is secured in a manner consistent with this Privacy and Cookie Policy (see Section 6 above). If we make material changes to how we use, collect, or share your child’s personal information, we will notify parents by email or by in-game notice in order to obtain verifiable parental consent for the new uses of your child’s personal information.

We encourage you to talk with your children about communicating with strangers and disclosing personal information online.

Under no circumstances do we condition a child’s participation in an activity—like contests—on the child’s disclosure of more personal information than is reasonably necessary to participate in the activity. On certain sites, we may not permit children to participate at all regardless of consent.

8. Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of information. For example, you can update your account information and preferences, choose to opt in or out of EProAm.com marketing emails and choose whether to share your information with select EproAm.com’s partners. If you would like to opt out at any time after providing your consent, contact the appropriate Privacy Policy Administrator eproam.com/contact .

You also can review and change most of your preferences through your EProAm.com Account settings. If you need additional assistance, please contact eproam.com/contact . If you no longer wish to receive marketing emails from EProAm.com, you may also click the unsubscribe link included in the footer of every marketing email we send. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time.

You may deactivate your EProAm.com Account or delete the personal information associated with your account by contacting eproam.com/contact . If you do so, you will no longer have access to the EProAm.com events associated with your account. Note that EProAm.com may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you services, create and improve our products, comply with the law, and to run our business.

You can access the personal information we hold about you. To request access, please contact eproam.com/contact . Before we process any request, we may ask you for certain personal information in order to verify your identity.

You may have additional rights under local law, including the right to request erasure or portability of personal information and the right to object to or restrict processing of information. Where applicable, you can exercise these rights by contacting eproam.com/contact .

You also may adjust your browser settings to block certain online tracking, such as cookies, as further described in section 2.

9. Third Party Services

Our websites and products may contain advertising or third party services (such as the Facebook Like button or links to third-party websites). If you click on those links, including an advertisement, you will leave the EProAm.com website and go to the site you selected. If you visit a third party website or use a third party service, you should consult that site’s or service’s privacy policy.

10. Changes to Our Policy

We may update this policy from time to time, so please review it frequently. We’ll notify you of material changes via a notice on our home page (www.ea.com) thirty days before they go into effect. If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so. You can see when this policy was last updated by checking the “last updated” date displayed at the top of this policy.

11. Contact Us

If you have a complaint or question about this policy, please send contact us eproam.com/contact . If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

The controller of the personal information processed under this policy is Trustom, Inc.

12. Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer. Contact details for Data Protection Authorities in the EU are available at ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

13. Further Information

For more information and updates to this policy, visit EProAm.com/privacy .

 

 

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