PRIVACY POLICY

Last Updated on February 27, 2012

1. Introduction

Dialect, Inc. and its subsidiaries and affiliates (collectively “Dialect” or “we”) respect the privacy rights of our online visitors and are committed to protecting the personal information collected about you. To further this commitment, we have adopted this Online Privacy Policy (“Privacy Policy”) to guide how we collect, store, and use the information you provide us online.

2. What does this Privacy Policy apply to?

The website you are currently visiting is operated by Dialect, Inc. located at 720 York St #116, San Francisco, CA 94110. This Privacy Policy currently applies to all of the website(s) operated by Dialect (collectively referred to as “Dialect Websites” or “our Websites”). If we wish to include additional websites under this Privacy Policy, we will take reasonable steps to include them in a list and ensure that they provide a link to this Privacy Policy. Some Websites, due to the nature of the content and services they provide, may have additional information relating to the collection and use of information submitted to them. Please read each Websites Terms of Use as well as this Privacy Policy.

Please note that this Privacy Policy applies only to information submitted and collected online through the Dialect Websites (as listed above), and does not apply to information that may be collected by Dialect offline. In addition, this Privacy Policy does not extend to other companies or organizations to which we link. Because we cannot guarantee that the privacy policies of such sites meet the requirements of Dialect’s Online Privacy Policy, we encourage you to read the privacy policy of the website to which you link before you submit any personal information to that site.

Please note that by using our Websites, you signify your assent to Dialect's Online Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Websites. We reserve the right to make changes to this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you by posting the change on our Websites or in this Privacy Policy and, if necessary, give you additional choices regarding such change. Please check back from time to time to ensure that you are aware of these changes. Your continued use of our Websites will signify your acceptance of these changes.

3. What types of information does Dialect collect?

In order to give you the best experience on our Websites, Dialect may collect information about you, but only if you voluntarily provide it to us. Typically, we may ask you to submit personal and/or demographic information in connection with any one of the following features or services.

  • Website and game-specific registration
  • Newsletter subscription
  • General support
  • Product support
  • Contests, sweepstakes, and other promotions
  • Polls, surveys, or questionnaires
  • Message boards
  • Other features such as e-cards, wish lists, and tell-a-friend

The types and amount of personal information collected for these activities will vary depending on the activity. The requested personal information may include: your name, home address, telephone number, e-mail address and (for those purchasing products online) credit card information including billing and shipping addresses. For some activities, we may ask you to create a username and password and to provide other non-personal information such as your age or date of birth, gender, game and platform preferences (including information about the games and hardware you own), hobbies and interests, and other information (also known as “demographic information”). If demographic information is collected for an activity that also requires personal information, we may combine the demographic information with your personal information. Combining data allows us to customize the notices we send you and the services we provide you according to your interests and preferences. For more on how we use your information, please read the section on use below.

4. How does Dialect use the information it collects?

Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.

Dialect Tools and Updates

Information collected from those who voluntarily submit it to us is used to provide services like updates on special events, game news, and e-mail announcements of interest to our users. Occasionally, we share your personal information (e.g., e-mail address) with a third-party sponsor, co-sponsor, or other reputable third party that provides products or services that may be of interest to you. Moreover, if you register for access to our blogs or message boards, we will use your personal information to enable you to view and post messages on the boards. However, you should understand that community forums, blogs, and message boards are tools that allow you to communicate with members of the online community. As such, whenever you give out personal information in public areas, that information can be collected and used by people you don’t know.

Operational Uses

We may also use your personal information for other purposes such as “Operational Uses.” For example, we may use your information to send you administrative communications either about your account with us or about features of our Web sites, including any Dialect changes to this Privacy Policy.

We occasionally use other companies, agents or contractors to perform services necessary to our operations. For example, we have partnered with other companies to personalize our Web pages, process credit card transactions, analyze customers' interaction with our Website, and process consumer surveys. We also provide postal addresses to the U.S. Post Office for delivery purposes. In the course of providing such services, these companies may have contact with your personally identifying information. These entities have agreed to securely store and maintain the personal information received from us.

Aggregate Information

Finally, we may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, no restrictions apply under this Privacy Policy on our right to aggregate or de-personalize your personal information, and we may use and share in any way with third parties the resulting non-personally identifiable information.

Business Information

For practical reasons, we treat personal information submitted to us in a business capacity different from information we receive in a non-business capacity. Personal information submitted to us in a business capacity (e.g. resumes, event sponsorship, etc.) may be shared with third parties, depending on the nature of the inquiry.

Purchase or Sale of Businesses

From time to time, we may purchase a business or sell one or more of our businesses and your personally identifiable information may be transferred as a part of the purchase or sale. If we purchase a business, the personally identifiable information received with that business would be treated in accordance with this Privacy Policy, if it is practicable and permissible to do so. If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personally identifiable information in the same manner required by this Privacy Policy (including any amendments to this Privacy Policy). The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings.

Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Websites and Others

We will disclose personal information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our Terms of Use; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our Web sites or third parties.

5. What happens if I refuse to provide my personal information to Dialect?

If you choose not to submit personal information when requested, you may not be able to participate in certain activities on our Websites and may limit the services we can provide you. For example, if you refuse to share your e-mail address, you may not be able to receive general support or product support. To simply browse our Websites, however, you do not need to give us any personal information.

6. Does Dialect use cookies or use other passive means to collect information?

We collect information through technology to make our Websites more interesting and useful to you. For example, when you come to one of our Websites, we collect your IP address. An IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet service provider), your company, or your university. Standing alone, your IP address is not personally identifiable. At times, we also use IP addresses to collect information regarding the frequency with which our guests visit various parts of our Websites. We may combine this information with personally identifiable information.

Cookies

We may use cookies to improve the use and functionality of our Websites. A “cookie” is a small file or record-keeping device that websites often store on a user's computer. Storage of cookies on your system provides an easy and convenient method for us to personalize your experience on our Websites. For example, cookies will remember what you've placed in your shopping cart, tell us that you have visited one of our Websites before, and may contain other information that will make your next visit to our Websites more enjoyable. We may combine information contained in cookies with your personal information. You can always disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to shop online, both at Dialect and elsewhere.

Web Beacons

We may use web beacons (or clear GIFs) on our Websites or include them in the e-mail messages we send you. Web beacons (also known as “web bugs”) are small strings of code that provide a method of delivering a graphic image on a web page or in an e-mail message for the purpose of transferring data. We use web beacons for many purposes, including site traffic reporting, unique visitor counts, advertising and email auditing and reporting, and personalization. Information gathered through web beacons may be linked to your personal information.

IP Addresses

Dialect may also keep track of Internet Protocol (IP) addresses to troubleshoot technical concerns and to maintain website safety and security. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

Log Files

Dialect may collect information in the form of logs — files that record website activity and gather statistics about web users' browsing habits. These entries are generated anonymously, and help Dialect determine (among other things) how many and how often users have visited our Websites, which pages they’ve visited, and other similar data (a.k.a., navigational data). We also use the log file entries for our internal marketing and demographic studies, so we can constantly improve the online services we provide you. Log files are used internally only, and are not associated with any particular user, computer, or browser.

Network Advertisers

Many advertisements are managed and placed on our Web sites by third parties. These companies are called “network advertisers.” Network advertisers who place advertisements on our Web sites may also use cookies and Web beacons to collect non-personally identifiable information when you click on or move your cursor over one of their banner advertisements. You may not realize this information is being collected. In some cases, we may have access to information from Web beacons and cookies used by network advertisers on our sites and this information may permit us to identify other sites that you have visited that are also associated with the network advertiser.

We use third-party advertising companies to serve ads when you visit our Website. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Finally, once you’ve clicked on an advertisement and have left our Websites, our Privacy Policy no longer applies and you must read the privacy policy of the advertiser to see how your personal information will be handled on their website.

7. Who is collecting my personal information and is it shared with anyone?

The information that you disclose on the Dialect Websites is collected by Dialect or by a vendor on Dialect’s behalf; and, is used in accordance with the practices set forth above. Vendors (or agents) are entities that provide support for the internal operations of our Websites and who only use the information we share with them (or that they collect on our behalf) for purposes of internal fulfillment (e.g., online product fulfillment). Vendors are required to handle such information in accordance with this Privacy Policy.

From time to time, we may run contests, tournaments, or other events or activities (“events”) on our Websites. Information collected for these events may include personal information such as your e-mail address and may be collected by or shared with a third party sponsor, co-sponsor, or other reputable third party (e.g., promotional partner, software licensee, or game developer). If you do not want your information to be collected by or shared with a third party, you can choose not to participate in these events at the time the information is collected.

We may disclose personal information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability. In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Dialect’s customer information may be transferred to our successor or assign.

8. Can I choose how my personal information is used?

If you do not want to receive our newsletter, service related announcements, or any other communications and/or services from Dialect, please opt out from these communications or services at the time of registration or information collection. If at any time you decide to remove your personal information from our database, you may do so by emailing us at info@dialectinc.com.

9. How do I access or update my personal information?

You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by e-mailing us at info@dialectinc.com

Your California Privacy Rights

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. For inquiries regarding our disclosure policy, please contact us using the information provided below:

Dialect, Inc.
Attn: Privacy Policy Administrator
720 York St. #116
San Francisco, CA 94110
info@Dialectinc.com

10. What is Dialect’s policy regarding children under 13?

It is Dialect’s policy not to collect information from children 12 or younger at the Sites, and Dialect employs industry standard technical measures to prevent children from providing us with any personally identifiable information. Children from the ages of 13 to 17 are able to participate at the Websites; however, some features of the Websites may be unavailable to them. Children 12 and under may still surf the Websites, and may see many links to other websites while doing so. Dialect cannot guarantee that these other websites contain material appropriate for them. We strongly urge parents to monitor their children's Internet usage, and to actively participate in the selection of websites their children visit.

11. What safeguards does Dialect use to protect my personal information?

Dialect takes reasonable measures to protect the confidentiality, security, and integrity of the personal information collected from our Website visitors. Personal information collected by Dialect is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. For example, before we allow web users to access their personal information, we verify their identity by requesting information such as their username and password.

While Dialect takes reasonable precautions against possible breaches of its Websites and customer databases, no website or Internet transmission is completely secure. Consequently, Dialect cannot and does not guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Dialect urges you to take steps to keep your personal information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your user account, and closing your web browser.

12. How do I ask a question or file a complaint? (Contact Information)

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact our Privacy Policy Administrator at:

Dialect, Inc.
Attn: Privacy Policy Administrator
720 York Street #116
San Francisco, CA 94110
info@Dialectinc.com 

13. How are disputes regarding this Privacy Policy resolved?

By using our Websites, you agree that any claim arising out of or relating to our adherence to this Privacy Policy, or the breach thereof, that cannot be resolved through our internal processes, will be settled by arbitration administered by the American Arbitration Association (“AAA”) in accordance with its applicable commercial rules. You further agree that: (a) any arbitrator will be either an attorney or retired judge having significant and recognized experience with and knowledge of privacy issues and information technology; (b) the arbitration panel will apply California law, without regard to it conflict of laws principles; (c) the exclusive location for such arbitration will be San Francisco, California; and (d) all decisions of the arbitration panel will be final and binding on the parties, which waive any right to further appeal the arbitration award, to the extent an appeal may be lawfully waived.

This Privacy Policy was last updated on February 27, 2012.