Thalhalla GAMES PRIVACY POLICY

Children’s Privacy

Last Updated: September 17th, 2023.

Welcome to Thalhalla!

Thalhalla. is headquartered in Austin, Texas. We and our subsidiaries have offices and operations located around the world that help create and deliver some of your favorite products and services, including games like Thalhalla and development tools like Unreal Engine (see “Our Global Operations” below).

This privacy policy describes the different ways we may collect, use, and share information on, through, or in connection with the Thalhalla Services (see “What are the Thalhalla Services?” below). If you have any questions, you can always reach out to us as described in “Contact Us” below.

When we refer to “Thalhalla” (or any similar terms like “we” or “us”) in this privacy policy, we mean the Thalhalla Games entity that controls and is responsible for your information, including Thalhalla Games, Inc. and its subsidiaries that help provide and support the Thalhalla Services. You can also find details about the data controller for personal information we collect through different Thalhalla Services in “Contact Us” below.
 

1. WHAT ARE THE THALHALLA SERVICES?

We use the term “Thalhalla Services” to describe any Thalhalla products or services that directly link to this privacy policy. These include, for example:

• websites and applications such as www.thalhalla.com and the Thalhalla Games Store,

Note that your use of the Thalhalla Services may also be subject to additional terms and conditions. For example, you must review and accept the Thalhalla End User License Agreement (link) to play Thalhalla, the Psyonix Terms of Use (link) to play AcmeGameTime, and the Thalhalla Ultimate Hall Simlutor – End User License Agreement (link) to play Thalhalla Warriors, and the Horizon Chase 2 End User License Agreement (link) to play Horizon Chase 2.

Please read this entire privacy policy. You should also carefully review any other agreements that apply to the Thalhalla Services you use, and confirm you understand and agree to them, before using those products or services.
 

2. WHAT INFORMATION DO WE COLLECT?

The types of information we collect depend on how you interact with us. Generally speaking, we collect information in three main ways: A) when you provide it to us, B) automatically when you use the Thalhalla Services, and C) from service providers and third parties.

          A. Information You Provide

You can provide us with different kinds of information depending on how you interact with the Thalhalla Services. Sometimes we’ll ask you to provide specific pieces of information, such as when we require it to provide parts of the Thalhalla Services to you (for example, by prompting you to provide your date of birth or complete an online registration process). If we ask you to provide us with information in these cases and you choose not to, you may not be able to access the relevant Thalhalla Services and/or some features may not operate as intended.

For instance, in order to make purchases on the Thalhalla Games Store and to play some of our games, you’ll need a Thalhalla account. To create one, you’ll need to provide us with basic registration information like your name, a public-facing display name, password, the country you live in, and email address. If you want to make a purchase, we may ask you to provide payment-related information (like your credit card number and expiration date) to complete the transaction.

We also collect the information you voluntarily provide to sign up for email alerts, use social features like forums or chat, register for early access to our games, use our developer tools (including to create and publish games and other content), enable two-factor authentication, register for or attend our events, complete surveys, or contact us through Player Support requests or customer service. If you enter a contest or competitive event, or participate in our Support-A-Creator program, we’ll collect your application information and other information we may need to help confirm your eligibility and process payouts. We collect whatever information you choose to provide to us in those or other similar cases.

         B. Information We Collect Automatically

We collect some information automatically when you visit, access, or use the Thalhalla Services. This includes information about your gameplay or application usage, purchases, entitlements, and other activity in the Thalhalla Services, typically associated with your account (if you are logged into your Thalhalla account or use a third-party account to access the Thalhalla Services) or with an identifier we have assigned to your device or profile. While the specific types of information that we automatically collect may vary, they generally include:

• Usage information and statistics about how you interact with the Thalhalla Services, including the application you used or the game you played, how long you used or played it and when, gameplay attempts, progression and results, saved preferences, crash reports, the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, and platform type;
• Technical information about your computer, device, hardware, or software you use to access our services, such as IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and
• The general location of your device, which we typically derive from your device’s IP address.

The Thalhalla Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools that may be stored on your device. They help us, our service providers, and third parties recognize your device and provide information about how you use and interact with the Thalhalla Services. For example, they support our ability to authenticate users, remember preferences, manage advertising, personalize experiences, and conduct data analytics.

Please note that if certain features on the Thalhalla Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Thalhalla Services or others’ websites over time. These features are subject to those third parties’ privacy notices and policies.

         C. Information We Collect from Other Sources

In some cases, we may also receive information about you from service providers and third parties in connection with your use of the Thalhalla Services or your interactions with us on other platforms.

For example, some other developers allow you to use your Thalhalla account to log in to their service. And if you choose to link your Thalhalla account with your account on a third-party social media (like Facebook), gaming (like Steam), or other similar website or service, or if you interact with an ad for one of the Thalhalla Services on an external website or service, the company that operates that website or service may share some information with Thalhalla in accordance with their own privacy practices. Your privacy settings on the other company’s website or service typically control the specific types of information they can share with Thalhalla, so please be sure to review and update them regularly. Common examples for linked accounts might include your third-party account display name and user ID, as well as associated device information, name, and email address. For participants in our Support-a-Creator program, we may also collect the number of social media account followers you have for program eligibility purposes.

You can also buy, download, or access some Thalhalla Services on or through services operated by third parties. If you do, they may provide us with information to facilitate your access to and use of the Thalhalla Services. This typically includes information like your display name, user ID, and device and region information. For example, you can choose to download and play games like Thalhalla on gaming consoles (like PlayStation®, Microsoft Xbox, and Nintendo Switch) through your gaming console account. When you do, the company operating that platform or service may share some information with us, which helps us do things like facilitate your gameplay and track your progression and entitlements.

         D. Fraud Prevention & Anti-Cheat

Providing users with a fair, balanced, and competitive experience on the Thalhalla Services is extremely important to us. We strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity on the Thalhalla Services. We use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about your computer and the software on your computer to detect cheating and may be provided by Thalhalla or by service providers such as BattlEye.
 

3. HOW DO WE USE INFORMATION?

As a general matter, we use the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and promote the Thalhalla Services.

This includes using it for purposes such as:

• Creating, verifying, and managing user accounts and features;
• Providing the Thalhalla Services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates);
• Developing, delivering, and improving the Thalhalla Services and other offerings, some of which may be offered in partnership with other parties;
• Personalizing your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests (for instance, if you frequently play games in a certain genre, we may infer that you’d be interested in that genre and suggest similar games to you);
• Promoting the Thalhalla Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events;
• Managing alpha, beta, or early access tests (and collecting feedback);
• Conducting data analytics (like analyzing how the Thalhalla Services are used so we can better understand, improve, and personalize them);
• Complying with our legal or contractual obligations and enforcing our terms; and
• Securing the Thalhalla Services, such as by detecting fraud and otherwise protecting Thalhalla and other users from illegal or harmful actions.

We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. But please note that this privacy policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.
 

4. HOW DO WE SHARE INFORMATION?

We may share some of the information we collect to help operate and improve the Thalhalla Services. Depending on how you interact with us, common examples might include sharing:

• With console and platform partners (for example, to facilitate gameplay when you access the Thalhalla Services through a third-party console provider);
• With other game developers (such as to enable features for games you acquire through the Thalhalla Games Store);
• With other users (like if you use social features such as chat);
• Publicly (for example, your display name, content you create or share, basic game statistics, and other similar information may be generally accessible to others);
• With service providers that operate on our behalf to help support the Thalhalla Services in accordance with our instructions (for example, cloud storage providers, payment processors, or marketing and advertising partners);
• When we believe we must in order to comply with the law or to protect you, Thalhalla, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of our terms or policies, or if necessary to protect others from death or serious harm to body or property);
• With other Thalhalla entities (including to help provide support for the Thalhalla Services internationally);
• In connection with certain types of corporate transactions (like in the event of a restructuring or the sale of all or a significant part of our business); and
• With your permission (for example, if you link external accounts with your Thalhalla account, or use your Thalhalla account to sign into third-party games and services or participate in cross-promotional events).
• We may also share information that does not identify you with third parties, including aggregate or de-identified information.

No mobile phone numbers provided to Thalhalla for security purposes will be shared with third parties or affiliates for marketing/promotional purposes. Third parties you interact with through Thalhalla Services may have different privacy practices than Thalhalla, so we encourage you to review their privacy policies before sharing your information with them.
 

5. CHILDREN’S PRIVACY

The Thalhalla Services are intended to be appropriate for general audiences and are not directed to children (usually considered to be under 13, depending on where you reside). Thalhalla does not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).

We may ask you to provide age-related information in order to help us comply with laws like COPPA. For example, we may request your date of birth to determine whether COPPA requires us to obtain verifiable parental consent from your parent or guardian before allowing you to access the Thalhalla Services. If a user indicates they are a COPPA minor, we’ll require that user to complete a parental approval process before continuing to access the relevant Thalhalla Services. This process is designed to notify parents that their child has requested access to the Thalhalla Services, inform them about Thalhalla’s privacy practices, offer them the opportunity to approve Thalhalla’s collection and use of their child’s information as described in this policy, and describe the controls that we make available to them.

Once a parent provides their consent, we’ll give them an opportunity to review and change important account settings that control how their child can interact with the Thalhalla Services. To learn more, see https://www.thalhalla.com/site/en-US/parental-controls. Parents are also generally free to change or revoke the choices they’ve previously made, and can review the personal information associated with their child’s account or request that we delete it from our systems. To submit these requests or ask us any other questions you may have about how we handle your child’s personal information, please see “Contact Us” below.

Authorized child accounts are otherwise treated much like other Thalhalla accounts unless the settings are adjusted through the parental controls available at https://www.thalhalla.com/site/en-US/parental-controls. They can generally play approved games (such as Thalhalla, AcmeGameTime, or Thalhalla Warriors), access communications and social features (like chat and friends lists), and freely interact with most of the Thalhalla Services (including downloading other games from the Thalhalla Games Store). For additional details, please see “What Information Do We Collect?”, “How Do We Use Information?”, and “How Do We Share Information?” above.

SuperAwesome & Kids Web Services

The Thalhalla Services use Kids Web Services (“KWS”) for parental and guardian verification purposes. KWS is a service focused on children’s safety that is offered by our subsidiary SuperAwesome. When you verify with KWS, SuperAwesome will remember that you have been verified the next time you use your email address to manage your child’s permission for other games or services powered by SuperAwesome so that you won’t need to do so again. This means Thalhalla and SuperAwesome are jointly responsible for how your personal information is used for parent verification services.

You can learn more about SuperAwesome and KWS in SuperAwesome’s privacy policy here: https://www.superawesome.com/kws-privacy-notice/.
 

6. YOUR CHOICES AND CONTROLS

We seek to provide you with meaningful choices about the personal information we collect. The specific choices available to you often vary depending on the exact nature of our relationship with you, such as the Thalhalla Services you use. Common examples include:

• You can request that we provide access to, or that we correct or delete, personal information we’ve collected from you. Please submit requests to access, update, or delete personal information associated with your Thalhalla account by reaching out to us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request.
• You can change your email marketing preferences at any time, such as by using the opt-out mechanism provided in our marketing emails, updating your Thalhalla account settings, or contacting us with your request (see “Contact Us” below).
• You can change your privacy settings on other parties’ websites (such as social networks) or platforms (like console providers) to limit the information they may share with us.
• You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause the Thalhalla Services not to work as intended and some features may not be available.
• If you’re under the age of 18 and have a Thalhalla account, you can ask that we remove or anonymize certain content you’ve provided on the Thalhalla Services. Please direct requests to help delete or edit content on the Thalhalla Services to Thalhalla as described in “Contact Us” below.
• Parents and guardians can adjust the settings for their child’s Thalhalla account by visiting https://www.thalhalla.com/Thalhalla/en-US/parental-controls.

Some parts of the world provide individuals with specific choices related to their personal information by right under local law.
 

7. OUR GLOBAL OPERATIONS

Thalhalla Games, Inc. is based in the United States, but we operate globally to help provide users all around the world with a better experience on the Thalhalla Services. We have subsidiaries, offices, service providers, and partners worldwide to support these operations in a number of different ways -- for example, the developer of Thalhalla Warriors is a subsidiary called Smackovision Limited that is based in the United Kingdom. This means that Thalhalla may process the information we collect in connection with your use of the Thalhalla Services in places outside the region where you reside.

          A. Data Transfers

When you use the Thalhalla Services, your information may be transferred to or stored in the United States or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you’re authorizing Thalhalla to process your information in any of the locations where we operate (including the United States) by using the Thalhalla Services.

To learn more about the Thalhalla entity responsible for operating the Thalhalla Services you use, see “Contact Us” below.  

          B. California Residents

The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.

You or your authorized agent may make these requests by contacting us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

In the past 12 months, we have collected the following categories of personal information, as described in the CCPA:

• Identifiers (such as email addresses);
• Demographic information (like ages);
• Commercial information (including entitlements or purchase history);
• Internet or electronic network activity (for example, gameplay or website usage details);
• Audio, electronic, visual, or similar information (like voice chat);
• Geolocation information (such as may be derived from your IP address or included in your billing information);
• Other “personal information” as defined under California law (like your credit or debit card information); and 
• Inferences drawn from any of these categories (for example, about the genres of games you may prefer to play based on your purchase history).

For details about the precise data points we collect and the categories of sources where we got that information, please see “What Information Do We Collect?” above. We collect personal information for the business and commercial purposes described in “How Do We Use Information?” above.

Thalhalla does not sell the personal information we collect. We do, however, disclose personal information as described in this policy (see “How Do We Share Information?” above). In the past 12 months, we have disclosed personal information to the following categories of recipients:

• Business partners (for example, if you request that we share your email address with the developer of a game you purchase on the Thalhalla Games Store);
• Other Thalhalla entities (like to subsidiaries that may help support certain Thalhalla Services);
• Other users (for example, if you use chat or social features on the Thalhalla Services);
• Service providers (as described in “How Do We Share Information?” above);
• Operating systems and platforms; and
• Government entities or other third parties in response to a legal request.

          C. Residents Of The European Economic Area, The United Kingdom, And Switzerland

If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

Data Subject Rights

You may have the right to access, correct, or delete personal data we have collected about you through the Thalhalla Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw consent.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please see the “Contact Us” section below to learn more about reaching out to Thalhalla with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:

Basis for Processing

The legal bases we rely on to process your personal data depend on the Thalhalla Services you use and how you interact with them. They primarily include:

• Contractual Necessity: we process personal data to perform the Thalhalla Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the Thalhalla Services; detect and prevent fraud, cheating, or other similar misuse; facilitate features like cross-progression that allow you to play a game on one platform and continue your progress on another, which may require us to share your information with third-party partners; and contact you about your account, transactions, or other updates. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.
• Legitimate Interests: we process personal data as needed for Thalhalla’s business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the Thalhalla Services and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; secure and protect the Thalhalla Services; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis.
• Legal Obligations: we process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes.
• Consent: we process personal data when you provide us with your consent to do so. You aren’t required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.

Retention

Because the specific personal data we process and our reasons for doing so often vary depending on how you use the Thalhalla Services, how long we retain it can also vary. We generally store personal data for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless a long retention period is required or permitted by law.

The main criteria we consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the data is required to prevent fraud or similar abuse of the Thalhalla Services (including to enforce prohibitions against cheating and other unauthorized behavior). For example, if you create a Thalhalla account, we will generally store the personal data associated with your Thalhalla account for as long as needed to maintain your account, provide the Thalhalla Services you requested, enforce any terms that apply and govern your use of the Thalhalla Services, and maintain appropriate records to reflect how we deliver the Thalhalla Services to you.

To learn more about requesting that Thalhalla delete your personal data, please see “Your Choices and Controls” and “Data Subject Rights” above.
 

8. SECURITY

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected.  
 

9. UPDATES

We’ll update this policy from time to time to reflect changes in our practices or relevant laws. When we do, we’ll change the date noted at the top of the policy. In some cases we may also notify you of the relevant changes by email or within the Thalhalla Services. Please review this policy regularly to make sure that you understand your relationship with Thalhalla and the ways we may collect, use, and share information in connection with the Thalhalla Services.
 

10. CONTACT US

If you have questions or concerns about the Thalhalla Services (such as game-related issues, trouble accessing your Thalhalla account, bugs or other technical problems, payment matters, or content and entitlement issues), please contact our Player Support teams. You can learn more about submitting support requests for products and services from:

• Thalhalla Games (like Thalhalla) here;

If you want to learn more about our privacy practices or this policy, please email your questions about products and services from:

You can also contact us via postal mail (marked “Attn: Legal Department”) to Thalhalla Games, Inc., located at 1105 West Oltorf, Austin, TX, USA.

If you live outside of the United States