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LAST MODIFIED: January 18th, 2023

We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

1. Who we are

Team Fray LLC (“Team Fray,” “We,” or “Us”) collects, uses and is responsible for certain personal information about you, as part of providing the “Fraymakers” game (the “Service”).
For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.

2. The Personal Information we collect and use

Information collected by us: In providing the Service, we collect the following personal information either automatically or when you voluntarily provide it to us:

  • Your name and email address are collected when you sign up for our newsletter, contact us about a Service-related issue or support ticket, enter a contest or sweepstakes, or fill out a survey (your “Contact Information”), and will be used to contact you for those purposes. The legal basis for collecting this information is your consent and to fulfill a contract with you, under GDPR Art. 6 (1) (a) and (b).
  • Aggregated and non-personally identifiable game save data, gameplay data, play history, and other Game-related data (your “Gameplay Information”). This Gameplay Information is used to improve the Service functionality and game balance. The legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (b).
  • Hardware information about your device, including amount of RAM, display resolution, CPU, etc. (your “Device Information”). This Device Information is used to analyze and improve the Service functionality, correct errors, and provide customer and technical support. The legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (b).[a]
  • When you make any posts, comments, user-generated content, or take part in any other public messaging and content on the Service (together, your “Content”), this Content may be made public to others using the Service. This Content is collected through the Service and any third-party community platforms that we use, such as Discord. The legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (b).

Information shared with us by others: If you connect a third-party service like Steam with our Service in order to create an account, that third party may share your username, profile picture, and other account and profile information (your “Account Information”). The legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (b).

Who we share your Personal Information with: We share your personal information with certain third parties as part of our operation of the Service. This data sharing enables us to provide you with the Service in the optimal way.

Some of those third-party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.

We share your Personal Information with the following third parties:
  • Game Hosting: We use certain cloud servers for multiplayer games that you play on the Service, and any information transferred through those servers is shared with those third parties.
  • Newsletters: We may use a third-party mailing list/newsletter provider to help manage our newsletter mailing list. We share your Contact Information with them for these purposes.
  • Other Sharing: We will share your Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Team Fray, its employees, clients, or users of the Service.

We will not share your personal information with any other third party.

How long your Personal Information will be kept: We will keep your personal information for the length of time required to provide you with the Service, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe.

Please note that some data may be retained if necessary to resolve disputes, enforce Team Fray user agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.

Children’s Privacy: We do not knowingly collect any personal information from children under the age of 13, nor do we allow them to create accounts, sign up for newsletters, make purchases, or browse the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16.

Team Fray takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you have any concerns about your child’s personal information, please contact us at support@fraymakers.com.

3. Transfer of your Information out of the EEA

Team Fray is based in the United States. No matter where you are located, you consent to the processing, transfer and storage of your information in and to the U.S., in accordance with the privacy policies of third parties with whom we share your Personal Information. The laws of the United States and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.
If you would like further information, please contact us (see “How to contact us” below).

4. EU Residents - Your Rights

Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.

  • By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
  • If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
  • If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
  • You have the right to ask us to stop using your information for a period of time, if you believe we are not doing so lawfully.
  • Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.
    If you would like to exercise any of those rights, please email us at support@fraymakers.com. We may ask for additional verification information, such as your username and other information required to be sure that you are the owner of that data.

5. California Residents – Your Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) gives you the following rights:

Right to Know: You can ask us what personal data we hold about you and request a copy of the information. This information includes:

  • The categories of personal information we have collected about you.
  • The categories of sources from which we collect the personal information.
  • The business or commercial purpose for collecting your personal information.
  • The categories of third parties with whom we share that information.
  • The specific pieces of personal information we have collected about you.

Right to Delete: You can request that your personal information be erased. However, there are some exceptions to this right, in situations where we:

  • Need to complete the transaction for which the personal information was collected, provide a good or service that you requested, or that is reasonably anticipated within our ongoing business relationship with the consumer, or to otherwise perform a contract between us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
  • Need to comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  • 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 businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
  • Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us.
  • Need to comply with a legal obligation.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Sale of Personal Information: Team Fray does not sell any of your personal information for any purposes.

Other Rights: In addition to the rights above, you also have the right to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the calendar year preceding your request. This request is free and may be made only once a year.

You also have the right not to be discriminated against for exercising any of the rights of California residents listed in this section.

If you would like to exercise any of the rights listed above, please email us at support@fraymakers.com.

6. Keeping your Personal Information secure

We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.
For example, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

7. Resolving Disputes

We hope that we can resolve any questions or concerns you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.
If you are an EU citizen, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

8. Changes to this Privacy Notice

This privacy notice was last updated on January 18th, 2023.
We may change this privacy notice from time to time. When we do, we will inform you via email to the email address you have provided us with through your account, or by posting a message about the change on the Service.

9. How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, you can do so by email at support@fraymakers.com, or by postal mail to 25 S Main St. Ste 6546, Yardley, PA 19067-1527.