Language:
This EULA, Terms of Service, Privacy Policy and GDPR disclosure (the "Terms") will remain updated at the following URL, reflected immediately upon changes and will supersede any duplicate Terms:

https://www.throneoflies.com/legal

In this document, you will find (ordered):

Terms of Service (ToS) and End-User License Agreement (EULA)
Privacy Policy (PP)
General Data Protection Regulation (GDPR)


1 - Imperium42®, LLC - Throne of Lies® The Online Game of Deceit (Game) - Terms of Service (ToS) and End-User License Agreement (EULA)


These terms and conditions outline the rules and regulations for the use of Imperium42® - Throne of Lies®: The Online Game of Deceit - throneoflies.com's website/game/forum/Discord/associated sites and applications.


Imperium42®’s remote address is located at:


Imperium42

848 N. Rainbow Blvd.

Unit #8058

Las Vegas, NV 89107 - 1103


Please note that, although our remote address is based in USA, this is a forwarding address (by physically-present humans): our Terms of Service is based on the legalities of Taipei, Taiwan (ROC).


General Considerations


For purposes of this Agreement, “Website” means the Throne of Lies: The Online Game of Deceit - throneoflies.com's website and all subpages thereto, including our online forums, and the term “Game” shall mean the interactive entertainment product Throne of Lies: The Online Game of Deceit, developed by Imperium42®, LLC, and shall include the Game client and all versions thereof across all platforms, including but not limited to expansions, updates, and game keys for digital download, as well as all content and intellectual property embodied therein. “Intellectual Property” means all copyrights, trademarks, patents and inventions, trade secrets, personality rights, and other proprietary rights commonly identified as “intellectual property rights” or pseudo-intellectual property rights by applicable foreign or domestic law, and by way of example but by no means a limitation of the foregoing includes: visual assets, Game code, artwork, music, audiovisual works, methods, processes, prototypes, technology, storyboards, characters, plot devising, slogans, logos, and any material distributed under confidentiality or non-disclosure restrictions.


By accessing the Website or purchasing the Game, we assume you accept the Community Guidelines, End User License Agreement, Website Terms of Service and Privacy Policy contained herein (collectively the “Agreements”) in full. Do not continue to use the Website or Game if you do not accept all of the terms and conditions set forth below.


The following terminology applies to these Terms of Service, End User License Agreement, Privacy Policy, and any or related agreements referenced herein: "End User", “You” and “Your” refers to you, the person accessing this website/game and accepting the Company’s terms and conditions. "The Company", “Ourselves”, “We”, “Our” and "Us", refers to our Company. “Party”, “Parties”, or “Us”, refers to both the End User and ourselves, or either the End User or ourselves. All terms refer to the offer, acceptance and consideration of payment necessary to undertake the process of our assistance to the End User in the most appropriate manner, whether by formal meetings of a fixed duration, or any other means, for the express purpose of meeting the End User’s needs in respect of provision of the Company’s stated services/products, in accordance with and subject to, prevailing law of Taiwan. Any use of the above terminology or other words in the singular, plural, capitalization and/or he/she or they, are taken as interchangeable and therefore as referring to same.


Community Guidelines (Code of Conduct)


Because Throne of LIes is an online game, your actions impact up to 15 other players per game match - and many of these players may (at the lowest) even be 13 years old. In order to maintain a safe, fun community, Imperium42, LLC and volunteers may issue disciplinary actions to regulate community behavior. Similar, in a way, to real-life that you wouldn’t walk into a classroom and say racial slurs to your teacher without expecting some form of disciplinary action.


The scope of the Community Guidelines and determination of disciplinary action is solely up to the discretion of Imperium42, LLC. Although Imperium42®, LLC can issue disciplinary action on your account, not limited to warnings, suspensions, and permanent bans for any reason. Imperium42®, LLC will generally only issue higher-level disciplinary actions, such as bans, for extreme measures and/or patterns. Imperium42, LLC will generally issue warnings or lower-level suspensions before higher-level suspensions/bans, although not always - it will depend on the extremities. Due to a hierarchy system with limited disciplinary action scopes, some disciplinary actions may act as temporary placeholders until a greater disciplinary action is issued by higher-level staff with the necessary scope: Disciplinary actions may be raised or lowered, depending on player behavior and internal communication. For example, if you “trash talk” the developers after a disciplinary action, you will probably receive a greater disciplinary action. If you disagree with these moderation practices or any part of the Community Guidelines or this document, do not play the game.

Common reasons for disciplinary action include, but are not limited to, offensive in-game names/alias’ (including poorly-misspelled offensive names, such as twisting 1 word of each letter), cheating, “meta-gaming” (revealing private information outside the game, such as announcing your class that no one else knows on voice chat), “trash talking” the developers/mods/community members, “spoiling” recent movies/TV shows/games, hate speech, “toxicity”, racism (including subtle racism - if it offends more than one person, it’s defined as racism), antisemetism, blatant over-use of swearing, “LGBT”-unfriendly remarks (we are an openly LGBT-safe community), posting “NSFW” (Not Safe For Work) content, revealing personally identifying information (for real-life; not in-game information), discussing piracy, discussion/participation of cheating/hacking, participation or plans to “raid” communities and/or reviews of any game, demanding/extorting changes, posting links in-game, harassing, stalking, spamming (including repeated “ALL-CAPS”), multiple accounts to evade disciplinary action, stalking, being “overly creepy”, imitating staff/moderators, gamethrowing, intentionally leaving while alive, speaking a foreign language on a public English server/match, drawing obscenities on the “Deathnote”, intentionally going “AFK” (Away From Keyboard), “stream sniping” (cheating via watching a Twitch streamer or live content creator’s streaming content within the same game as you), asking to be “converted” (or otherwise going against your faction’s objective), impersonating staff/mods, violating the Steam Subscriber Agreement ( https://store.steampowered.com/subscriber_agreement/ ), our Global Rules ( http://throneofli.es/rules ), or our game rules ( http://throneofli.es/gamerules ).


While most disciplinary actions start with a warning and progresses higher, this is not the guaranteed action for each case.


We want to make sure that our Game and Website remain fun, healthy, and safe environments for you and your friends to enjoy. By accepting our Terms of Service and End User License Agreement, you understand that these Community Guidelines apply to your use of both the Website and the Game, as well as any and all social media channels (including but not limited the Game’s Steam page, the official Discord server ( https://discord.gg/tol ), the official forum ( https://forum.imperium42.com ) , Facebook and similar social media platforms, as well as online video and streaming platforms such as, by way of example and by no means a limitation of the foregoing, YouTube.com and Twitch.tv) in connection with the Game operated or managed by Imperium42® (collectively herein the “Community”). Your failure to comply with any part of the Community Guidelines may result in your Game account’s termination, or we may otherwise ban you from further contributing to the Community by whatever legal means available to us.


Sometimes we may issue disciplinary action, such as, but not limited to bans, based on the information obtained outlined in the Privacy Policy below to refrain a user from “evading” or otherwise avoiding a ban by unauthorized means. This will result in an automated, 30-day ban for evasion. Imperium42® will not be held liable for issuing disciplinary action from ban evasion that may be issued to a family member associated with your computer/network that would otherwise be tied or otherwise associated to the same user in any form (including different accounts): This means that if someone else was using your computer and/or network while under disciplinary action, this person would be also receive disciplinary action, as well, as Imperium42® assumes this is the same player that was issued disciplinary action and not someone else using that computer and/or network: If you are suspended, banned, or otherwise issued disciplinary action against your account, any accounts associated with the computer and/or network will also receive such disciplinary action or greater for an evasion attempt: It is advised to warn others that use your computer and/or network, if you were suspended or banned, as a courtesy. By agreeing to this document, you also accept this risk and adhere to these terms regarding “disciplinary action by association”. Furthermore, duplicate accounts are not permitted in any form, if caught, whether the user is under disciplinary action or not.


Furthermore, you accept sole and complete liability for any content shared by you to our Community. As such, you agree to indemnify and hold harmless Imperium42® and its officers, employees, agents, affiliates, subcontractors, members and assigns, against any and all claims, disputes, demands, actions, suits, damages, liabilities, obligations, losses, settlements, judgements, costs and expenses (including without limitation attorneys’ fees and costs) made or entered into against us that arise out of, relate to or are the result of content you share with or to the Community.


User Comments and Feedback


Our Community offers various opportunities to interact and share your opinions and thoughts with us and other End Users in Game or via our forum, social media pages, Discord, through the Game’s Steam page, or via other Community initiatives. However, please note that the opinions or views expressed, or statements made to the Community (other than by Imperium42®’s employees, officers, or verified community leaders) via posts, user comments, feedback, “wiki” entries, online chat (in Game or via Discord or comparable social media outlets), or via the “Death Note” feature of the Game (collectively referred to herein as “User Comments”), do not reflect the opinions or views of Imperium42®.


We do not review, edit or modify User Comments prior to their publication to the Community. However, we reserve the right to remove or modify any User Comments shared with the Community for any reason. By sharing User Comments and accepting the terms of these Community Guidelines, you acknowledge that we may make such deletions or changes without notice to you, nor is any such change or removal subject to review, appeal or revocation.


You retain ownership in your User Comments and all Intellectual Rights contained therein, provided such User Comments do not contain Feedback as defined below. We may, from time to time, publicly share or redistribute User Comments on our Website, or through other Community channels, press releases, or promotional and marketing materials. You hereby grant us a non-exclusive, perpetual and irrevocable right and license us to use your User Comments in connection with the promotion of the Game.


We appreciate any feedback, suggestions, improvements, constructive criticism, or ideas you may have in connection with the Game or Website (“Feedback”). However, we cannot guarantee that the Feedback you provide has not already occurred to us. By submitting Feedback to Imperium42®, you hereby assign all right, title, and interest in and to the Feedback to Imperium42®, including, but not limited to, Intellectual Property rights. To the extent that any such rights cannot be assigned under international law, you hereby waive your existing or future rights and release us from any and all claims arising from our use of your Feedback.


User Generated Content


We encourage our End Users to create and share with our Community your fan art, fan fiction, video montages, Let’s Play videos, and other creative content relating to the Game (herein “User Generated Content”). We also encourage streaming and recording your gameplay and sharing it with the community or through social media video streaming services such as YouTube.com or Twitch.tv—for the purpose of these Agreements, we also consider your streams and videos containing our Game “User Generated Content”.


We want you to create and express yourself freely, and you retain all rights in and to your User Generated Content. By sharing your User Generated Content with the Community, you grant Imperium42® an unrestricted, irrevocable, non-exclusive and universal right and license to reproduce, modify, and redistribute your User Generated Content solely in connection with the promotion and marketing of the Game.


However, as User Generated Content is ultimately derived from our Game, all User Generated Content must comply with these Community Guidelines, the Term of Service and our End User License Agreement. Failure to comply with any of the terms contained therein may result in the cancellation of your Game account and whatever other remedies may be available to us, including issuing take downs to the appropriate service providers due to the breach of the licenses and rights granted to you herein.


Our Game also contains a feature called a “Death Note” (sometimes called “Deathnote”) that allows you to share doodles, notes, drawings, hints, clues, and anything else your imagination, morals, and these Community Guidelines permit; for purposes of this section, “Death Notes” are also User Generated Content and are subject to the same Community Guidelines and license grants as other User Generated Content.


“Death Notes” are shared by you in real time in-Game, which means we are not equipped to review each Death Note produced by our End Users. We rely on our Community to police and help us identify problematic User Generated Content; therefore, please do not hesitate to contact us if you find something objectionable, infringing, or in violation with the Community Rules and Restrictions listed below. The best method for such contact is via the report button at the end of each game/match.


Infringing Content


To the extent possible under International Law, Imperium42® is not liable for any copyright infringement arising from any User Generated Content shared with the Community or through our Game or Website. However, under the Digital Millennium Copyright Act of 1998 we are able to provide the lawful owners of copyrighted works recourse in the event that their copyrights are infringed. If you believe that your copyrights are being violated by User Generated Content, User Comments, or other materials located in our Game or on our Website or other Community channels under our direct control, please contact us so that we may investigate your claims and, if appropriate, modify or remove the infringing material. We require the following information before we are able to investigate your claim:


An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright;
A description of the copyrighted work that you believe has been infringed;
A description of where the material that you claim is infringing is located or identified on the Website or in the Game or Community channels under our direct control, including a verifiable link to the material;
Your name, address, telephone number, and email address;
A statement by you that you have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law, and is not a permissible “fair use” of your work; and
A statement by you, made under penalty of perjury, that the information submitted to us is accurate and that you are the owner of the copyright or authorized to act on the owner's behalf.

The above information should be provided to Imperium42®’s Registered DMCA agent for notice of claims of copyright or other intellectual property infringement, who can be reached by emailing copyright@imperium42.com.


If you believe your content has been taken down pursuant to the above procedures in error, we require the following information sent to the agent referenced above before we can investigate your claim or re-post your content:


Your physical or electronic signature;
your name, address, and phone number;
identification of the material and its location before it was removed;
a statement under penalty of perjury that the material was removed by mistake or misidentification;
your consent to the jurisdiction of a federal court in the district where you live (if you are in the U.S.), or your consent to the jurisdiction of a federal court in the district where your service provider is located (if you are not in the U.S.); and
your consent to accept service of process from the party who submitted the takedown notice.

Community Rules and Restrictions


By entering into these Agreements and accepting the Community Guidelines, you agree to comply with the following:


Nothing you share with the Community, including but not limited to User Generated Content or User Comments, may contain content that infringes on the intellectual property rights (including copyright, trademark, and patent rights), proprietary rights, trade secrets, personality rights, contract rights or restrictions, or other right of any third party;
To the extent that any third-party content is embodied in any content you share with the Community, including but not limited to User Generated Content and User Comments, you have acquired the necessary rights and licenses to reproduce the same;
You will NOT harass other users. Harassment includes but is not limited:
Publicly disclosing personally identifiable information of another End User or member of the Community;
Stalking, doxing, or otherwise infringing on the privacy of any member of the Community;
Disparaging, defaming, name-calling, or engaging in any form of discrimination against another member of the Community;
Engaging in any act of sexual misconduct, including but not limited to sexual innuendo, sharing sexually explicit content (including but not limited to sexually explicit content in User Generated Content or User Comments), or making offensive or inappropriate advances or comments to a member of the Community;
Making false claims, tickets, or reports about events or any third party, regardless of their standing with the Community or Imperium42®; or
Using exploits, hacks, or third party tools to obtain an unfair advantage against other members of the Community in-Game.
You agree that the list of conduct identified as harassment above is not exhaustive. We reserve the right to determine what constitutes “harassment” in our sole and exclusive discretion.
You will not engage in acts of revenge, disparagement or retaliation against us for any feature contained in or modification made to the Game that you dislike. Your sole remedy for that is to stop playing the Game;
You will not engage in solicitation or advertise other products or services to the Community without our prior consent (email is sufficient);
You may not commercially distribute, sell, or otherwise commercially exploit User Generated Content (including video streaming) without our prior consent (email is sufficient).
Defamation-classified slander/libel against, including but not limited to, any other player, guide, moderator, staff member, Imperium42, LLC.
We never issue disciplinary actions for negatively reviewing the company or game. However, if your review contains slander/libel or otherwise, but not limited to, accusing the company and/or volunteer community moderators of a crime and/or threaten to sue, this may count as harrassment that may result in in-game disciplinary action. We take legal words very seriously. We may, at the discretion of Imperium42, LLC, offer a lessened disciplinary action if such words were removed and an apology is offered. Don’t forget, criminal accusations hurt chains of people in real-life by your actions!
End User License Agreement

License


We retain exclusive rights for any and all of any and all State, Federal, and International intellectual property and proprietary rights in and to the Game and all copies of the Game, including without limitation all copyrights, inventions, trademark rights, trade secret rights, trade dress rights, and any and all other intellectual property and proprietary rights embodied in or derived from the Game. We prohibit the copying, reproduction, and circumvention of technology of the Game beyond the terms of this license. The Game is licensed to you, as opposed to being sold or assigned to you, and your continued legal use of the Game is contingent upon your compliance with this Agreement and the License Terms set forth below.


License Terms


We hereby grant you a non-exclusive, revocable, non-transferrable, and limited right to license one copy of the Game for your personal, non-commercial use. Continued use of the Game is contingent upon your compliance with the following:


You represent that you are an adult in your country of residence, or you at least thirteen (13) if you reside in the United States. You agree to this End User License Agreement on behalf of yourself and, at your discretion, for one (1) minor child for whom you are a parent or guardian and whom you have authorized to play the Game using the license granted to you;
You may not modify, distribute, transmit, display, perform, reproduce (except for one archival and backup copy as permitted by applicable laws), publish, license, create derivative works from, adapt, translate, sublicense, auction, rent, lease or sell all or any part of the Game. In addition, you may not hack, emulate, reverse engineer, decompile, or disassemble any part of the Game. All rights not expressly granted are reserved by us. You agree that you have no interest, monetary or otherwise, in any feature, content, or Intellectual Property contained in the Game;
You must comply with the Community Guidelines set forth above. Failure to comply with the Community Guidelines will result in the revocation of all rights set forth herein. Any breach substantial enough to cause harm to Imperium42® or a third party may be accompanied by the application of any and all legal rights and claims reserved by us herein;
Absent a valid distribution Agreement between you and Imperium42®, you may not commercially exploit or otherwise make the Game available on any third-party network, FTP, internet website, torrent site, file-sharing service, intranet, or “cloud”, whereby individuals other than you may download and install the Game. You further agree that you will not link to any such third-party network, torrent, FTP, file-sharing service, intranet, or “cloud” that is not legally owned by us or our distributors. For the sake of clarity, “commercially exploit” as used herein includes offers to perform in-Game services for other End Users in exchange for payment outside of the Game;
You may not use cheats, automation software (bots), hacks, mods or any other unauthorized third-party software designed to modify the Game experience;
You may not use any unauthorized third-party software that intercepts, “sniffs”, “mines,” or otherwise collects information from or through the Game, including without limitation any software that reads areas of RAM and/or network information (such as packet capturing) used by the Game to store information about a character or the game environment; provided, however, that we may, at our sole and absolute written discretion, allow the use of certain third-party user interfaces that does not offer an “advantage” to the player beyond existing, public information;
You may not modify or cause to be modified any files that are a part of the Game in any way not expressly authorized by us;
You may not provide or develop matchmaking services for the Game, or intercept, emulate or redirect the communication protocols used by us in any way, for any purpose, including without limitation unauthorized play over the internet, network play, or as part of content aggregation networks;
You may not facilitate, create or maintain any unauthorized connection to the Game or the Service, including without limitation (a) any connection to any unauthorized server that emulates, or attempts to emulate, the Service; and (b) any connection using programs or tools not expressly approved by us;
You may not violate any applicable law or regulation in connection with your use of the Game; and
disrupt or assist in the disruption of (i) any computer used to support the Service (each a “Server”); or (ii) any other End User’s Game experience. ANY ATTEMPT BY YOU TO DISRUPT THE SERVICE OR UNDERMINE THE LEGITIMATE OPERATION OF THE GAME CLIENT MAY BE A VIOLATION OF CRIMINAL AND CIVIL LAWS.


Ownership and Independent Origin



All characters, events, and portrayals contained in the Game are purely fictional and any resemblance to real events or real individuals whether alive or dead is purely coincidental. We do not claim any rights or interest in or to existing trademarks, trade names, personalities or likenesses that may incidentally resemble an existing product, service, or person. Furthermore, we do not claim any right, obligation, or liability in and to User Generated Content (such as “Death Notes”) or third-party content otherwise made available in the Game. The rights in and to any such third-party content remains with its respective owners.





DISCLAIMER



ALL INFORMATION, CONTENT, SERVICES, AND MATERIAL AVAILABLE IN THE GAME AND RELATED SOFTWARE ARE PROVIDED ON AN “AS IS” BASIS. TO THE FULL EXTENT PERMISSIBLE BY LAW, WE DISCLAIM ANY AND ALL WARRANTIES AND REPRESENTATIONS, EXPRESS OR IMPLIED, INCLUDING ANY WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. WE DO NOT WARRANT THE NON-INFRINGEMENT OF ANY INTELLECTUAL PROPERTY RIGHT.



NO WARRANTIES



IMPERIUM42® AND ITS LICENSORS AND DISTRIBUTORS DISCLAIM ANY AND ALL WARRANTIES WITH RESPECT TO THE PRIVACY AND INTEGRITY OF THE COMPUTER RESOURCES YOU USE TO OPERATE THE SOFTWARE. NEITHER WE NOR OUR LICENSORS OR DISTRIBUTORS SHALL BE LIABLE FOR ANY DISRUPTIONS, DELAYS OR OTHER OMISSIONS IN ANY CONNECTION, DATA EXCHANGE OR OTHER INTERACTION THAT YOU MAY EXPERIENCE WHEN YOU USE THE GAME, REGARDLESS OF CAUSE (I.E., ANY SYSTEM FAILURE, SERVER ACCESS LOSS, OR DATA BREACH RESULTING FROM ANY CAUSE, INCLUDING, WITHOUT LIMITATION, ACTS OF GOD, NATURE OR OTHER CAUSES (BY WAY OF EXAMPLE, BUT BY NO MEANS A LIMITATION OF THE FOREGOING, EVENTS SUCH AS WAR, EMBARGO, INTERFERENCE BY THE FORCE, HOSTILE DOMINATION BY UNKNOWN SENTIENT OR BORG LIFE FORMS, OR ANY BACTERIA, VIRUS, OR OTHER UNKNOWN INFECTION OR PATHOGEN THAT RESULTS IN ANY COMMUNICABLE DISEASE THAT CAUSES LIFE TERMINATION AND THE SUBSEQUENT REANIMATION OF BODILY FUNCTIONS ACCOMPANIED BY LIMITED BRAIN ACTIVITY, AS WELL AS AN INSATIABLE URGE FOR HUMAN FLESH). NEITHER WE NOR OUR LICENSORS OR DISTRIBUTORS SHALL BE RESPONSIBLE FOR THE CONDUCT OF ANY USERS OR COMPUTERS THAT CONNECT (INCLUDING THOSE INFECTED BY THE ABOVE REFERENCED DISEASE), EXCHANGE DATA, OR OTHERWISE INTERACT WITH YOU OR YOUR COMPUTER AS A RESULT OF YOUR USE OF THE GAME.



LIMITATION OF LIABILITY



YOUR PURCHASE AND USE OF THE GAME IS AT YOUR OWN RISK. WE DO NOT WARRANT THAT YOUR ABILITY TO PLAY THE GAME WILL BE TIMELY, SECURE, UNINTERRUPTED OR DEFECT-FREE. IN NO EVENT WILL WE (INCLUDING OUR OFFICERS, DIRECTORS, PERSONNEL, AGENTS, OR EMPLOYEES) NOR OUR AFFILIATES BE LIABLE FOR DIRECT, INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, OR CONSEQUENTIAL DAMAGES (INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOSS OF BUSINESS, PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, LOSS OF USE OR LOSS OF DATA, OR BUSINESS INTERRUPTION) HOWEVER CAUSED AND ON ANY THEORY OF LIABILITY, WHETHER IN CONTRACT, STRICT LIABILITY, OR TORT ARISING IN ANY WAY OUT OF PURCHASE OR USE OF THE GAME. IN NO EVENT WILL YOU BE ENTITLED TO A REFUND OR CHARGEBACK FOR THE GAME.



Website Terms of Service


Cookies


We employ the use of cookies. By accessing the Website you consent to the use of cookies in accordance with our Privacy Policy, attached to and incorporated in these Terms of Service by reference.

Most of the modern day interactive websites use cookies to enable us to retrieve user details for each visit. Cookies are used in some areas of our site to enable the functionality of this area and ease of use for those people visiting. Some of our affiliate / advertising partners may also use cookies. See our privacy policy for more details.


Hyperlinking to our Content


The following organizations may link to our website without prior written approval:


Government agencies;
Search engines;
News organizations;
Online directory distributors when they list us in the directory may link to our website in the same manner as they hyperlink to the websites of other listed businesses; and
Systemwide Accredited Businesses except soliciting non-profit organizations, charity shopping malls, and charity fundraising groups which may not hyperlink to our website.

These organizations may link to our home page, to publications or to other website information so long as the link: (a) is not in any way misleading; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products or services; and (c) fits within the context of the linking party's site.


We may consider and approve in our sole discretion other link requests from the following types of organizations:


commonly-known consumer and/or business information sources such as Chambers of Commerce, American Automobile Association, AARP and Consumers Union;
dot.com community sites;
associations or other groups representing charities, including charity giving sites,
online directory distributors;
internet portals;
accounting, law and consulting firms whose primary clients are businesses; and
educational institutions and trade associations.

We will approve link requests from these organizations if we determine that: (a) the link would not reflect unfavorably on us or our accredited businesses (for example, trade associations or other organizations representing inherently suspect types of business, such as work-at-home opportunities, shall not be allowed to link); (b)the organization does not have an unsatisfactory record with us; (c) the benefit to us from the visibility associated with the hyperlink outweighs the absence of the same; and (d) where the link is in the context of general resource information or is otherwise consistent with editorial content in a newsletter or similar product furthering the mission of the organization.

These organizations may link to our home page, to publications or to other website information so long as the link: (a) is not in any way misleading; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and it products or services; and (c) fits within the context of the linking party's site.


If you are among the organizations listed above and are interested in linking to our website, you must notify us by sending an e-mail to support@imperium42.com . Please include your name, your organization name, contact information (such as a phone number and/or e-mail address) as well as the URL of your site, a list of any URLs from which you intend to link to our website, and a list of the URL(s) on our site to which you would like to link. Allow 2-3 weeks for a response.


Approved organizations may hyperlink to our website as follows:


By use of our corporate name; or
By use of the uniform resource locator (Web address) being linked to; or
By use of any other description of our website or material being linked to that makes sense within the context and format of content on the linking party's site.

No use of our logo or other artwork will be allowed for linking absent a trademark license agreement.


Iframes


Without prior approval and express written permission, you may not create frames around our Web pages or use other techniques that alter in any way the visual presentation or appearance of our website.


Reservation of Rights


We reserve the right at any time and in its sole discretion to request that you remove all links or any particular link to our website. You agree to immediately remove all links to our website upon such request. We also reserve the right to amend these terms and conditions and its linking policy at any time. By continuing to link to our website, you agree to be bound to and abide by these linking terms and conditions.


Removal of links from our Website


If you find any link on our Website or any linked website objectionable for any reason, you may contact us about this. We will consider requests to remove links but will have no obligation to do so or to respond directly to you.


Whilst we endeavor to ensure that the information on this website is correct, we do not warrant its completeness or accuracy; nor do we commit to ensuring that the website remains available or that the material on the website is kept up to date.


Uptime Guarantee


As we are an independent game studio, there will be no uptime guarantee for our Website. However, we will make every attempt to try our best to ensure our Website is up-and-running, budget permitting.


Payment Policy: Steam


If you purchased the game through Steam, they have their own policies.


Payment Policy: Non-Steam


If you purchase the game via a non-Steam channel, such as Stripe or PayPal, chargeback fees will be passed on to the purchaser (you). Issuing a chargeback will result in your game key being invalidated and you will be banned from all services. Refusal to pay a chargeback fee will result in selling the debt to a loan collection agency.


TL;DR: Don’t issue a chargeback.


Refund Policy



No refunds from us - sorry. We are an indie company and we charge less than $10 for an online game and we do not yet have the resources to dispute whether the refund reason is legitimate or not (we would rather add great features, instead). If you bought the game through Steam, however, you are eligible for a refund through Steam. If you live in Australia and purchased the key within Australia you may be eligible for a refund. You must specifically let us know and provide receipt of evidence proving you both reside and purchased the key within Australia.


Disclaimer


To the maximum extent permitted by applicable law, we exclude all representations, warranties and conditions relating to our Website and the use of this Website (including, without limitation, any warranties implied by law in respect of satisfactory quality, fitness for purpose and/or the use of reasonable care and skill). Nothing in this disclaimer will:


limit or exclude our or your liability for death or personal injury resulting from negligence;
limit or exclude our or your liability for fraud or fraudulent misrepresentation;
limit any of our or your liabilities in any way that is not permitted under applicable law; or
exclude any of our or your liabilities that may not be excluded under applicable law.

The limitations and exclusions of liability set out in this Section and elsewhere in this disclaimer: (a) are subject to the preceding paragraph; and (b) govern all liabilities arising under the disclaimer or in relation to the subject matter of this disclaimer, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty.


To the extent that the Website and the information and services on the Website are provided free of charge, we will not be liable for any loss or damage of any nature.


Privacy Policy


Our Privacy Policy can be found here: https://www.ThroneOfLies.com/legal


Contact Information


If there are any questions regarding these documents, you may officially contact us using the information below:


http://support.imperium42.com

support@imperium42.com


Or, unofficially, for minor questions:


https://discord.gg/tol




Last Modified 02/10/2018


2 - Imperium42®, LLC - imperium42.com - Throne of Lies® The Online Game of Deceit (Game) - ThroneOfLies.com - Privacy Policy (GDPR at bottom)


Imperium42® Game Studio developed an online game with a login system for both the Website (*.imperium42.com and *.throneoflies.com) and game, so we would like to tell you how we collect what info and why:


This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website/game.


What personal information do we collect from the people that visit our website/forum/game (PC, Mac, Windows, and possibly other platforms)?

When ordering or registering on our site, as appropriate, you may be asked to enter your email address, choose an alias (Username/Display Name) or other details to help you with your experience.


Web Server Logs


When you visit our Website, we may track information to administer the site and analyze its usage. Examples of information we may track include:

Your Internet protocol (IP) address.

The kind of browser or computer you use.

Number of links you click within the site.

State or country from which you accessed the site.

Date and time of your visit.

Name of your Internet service provider

Web page you linked to our site from.

Pages you viewed on the site.

In-Game Only: Media Access Control address.


When do we collect information?

We collect information from you when you register on our site, subscribe to a newsletter, Open a Support Ticket or enter information on our site, when you launch/play the game, and/or when you provide us with feedback on our products or services,


We may also collect anonymous demographic information when accessing the website/game to help improve our product - if demographic information is blocked by an extension, that is okay! However, we cannot guarantee full functionality, if blocked.


How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website/play our game, or use certain other features in the following ways:


• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.

• To improve our website/game in order to better serve you.

• To allow us to better service you in responding to your customer service requests.

• To administer a contest, promotion, survey or other site feature.

• To send periodic emails regarding your order or other products and services.

• To issue kicks/bans/suspensions and/or to provide public proof of disciplinary actions.

• When disciplinary action is challenged or publicly dishonest/incorrect information is provided (such as in a review - or, specifically, a “revenge review”), we may provide a limited set of the collected information publicly to prove or disprove such a case.


How do we protect your information?

We do not use vulnerability scanning and/or scanning to PCI standards.

We only provide articles and information. We never ask for credit card numbers unless it is through a secured third-party (like Swipe, for example), although we may retain fragments of data (or “metadata”) such as to provide express checkout services, remember your preferences, and related “quality of life” features.


We do not use Malware Scanning.


Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is generally encrypted via Secure Socket Layer (SSL) technology.


We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.


All transactions are processed through a gateway provider and are not stored or processed on our servers.


Most, if not all of your information is securely stored with PlayFab (formerly) and GameSparks (recently), which we use for our cloud database.


Do we use 'cookies' on the website or store local preferences from the game on your computer?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.


Similarly, we may store your preferences and/or tokens (we do not store plaintext passwords) -- we may, however, store your username and/or other information locally, such as graphical settings or basic login prefill information (not your password).


We use cookies/local preferences to:

• Understand and save users’ preferences for future visits.

• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.


You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each/every browser varies in regards to how to turn off cookies, please consult your browser’s documentation to learn how to change cookie behavior/settings.


If users disable cookies in their browser:

If you turn cookies off, some features will be disabled. Some of these features make your site experience more efficient and may not function properly without cookies such as placing orders, “Remember Me” features, logging-in activities, and possibly other unforeseen features.


Privacy Policy Revisions

There will likely be an iteration of revisions throughout the game’s lifetime. By continuing to use our services, you agree to adhere to the updated revisions. If you do not agree, do not play.


Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice or falls within the scope of our Terms of Service/EULA/Privacy Policy. This does not include website/game hosting partners and other parties who assist us in operating our website/game, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.


However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.


Public Information Disclosures

If a dishonest comment of/in any form and/or review and/or a disciplinary action is challenged, we may provide a limited scope of information publicly to prove or disprove a case. This will NEVER include your last name, your email address, or your full MAC/IP address(es) (although we may include a partial for ban evasion cases). Any other data we may publicly post in order to resolve a situation that will only identify your gaming alias - no Personal Identifying Information that will reveal your real-life person.


GameAnalytics

We use GameAnalytics to record low FPS (frames-per-second), view debug/error logs online so we don’t have to keep asking for your logs, demographics and insights for how to improve the game and fix things. For example, to keep track of balance. These stats are generally aggregated, anonymous stats.


GameSparks and In-Game Privacy

We use GameSparks as our BaaS (Back-End-As-Service) to privately and securely store your player and account information to allow you to play the game from any computer without the game being hacked. This also allows a convenient login system from multiple sources, such as Facebook and/or Steam. Your friends list is is also stored here. Other friends can find you by your email address, GameSparks ID, your display name, if you are Steam friends, username, or possibly other related queries. Once a friend is added, you may not [currently] be able to remove them until we add this feature in the future. There may be other third-party social features that you would generally be prompted to accept their own terms/privacy policy and disclose what privacy features we are requesting (such as Facebook or Discord).


We also store match records, including chat logs, private whispers, “Death Note” (sometimes called “Deathnote”) pictures, and potentially other related logs and reports are uploaded to GameSparks and/or the official forum (at https://forum.imperium42.com) and/or Discord (at https://discord.gg/tol). This is stored for evidence against harassment and/or abuse as well as research to improve our game. When you are in-game, consider every action taken as being okay with it being publicized or reviewed in any form/use. See more about GameSparks data/privacy policies: https://www.gamesparks.com/privacy-policy/


Webhooks

We may periodically create webhooks from in-game or other services, such as website or forum, that may announce activity. For example, when you start a match, a Discord message may popup stating you started a match with accompanying public info.


Steam

We use Steam as convenient way to sign in, among other features. We also use Steam for friend discovery, parties with friends, and other features included within Steamworks. We also may use Steam for both game purchases and in-game purchases. See more about Valve’s data/privacy policies: http://store.steampowered.com/privacy_agreement/


Stripe

(Currently not in-game) We may use Stripe on our website or other associated sites/products to assist in purchasing game keys, products, or other related items via a card. We only store tokens and information relating to the purchase. In reference to credit card numbers, we are limited to only storing the last 4 digits of your credit card # for reference and possibly similar information that would not jeopardize the security of your card. We do not store credit card numbers. Your data is encrypted and safe with Stripe. See Stripe’s privacy policy at https://stripe.com/us/privacy/


PayPal

(Currently not in-game) We may use PayPal on our website or other associated sites/products to assist in purchasing game keys, products, or other related items via a card. We only store tokens and information relating to the purchase. In reference to credit card numbers, we are limited to only storing the last 4 digits of your credit card # for reference and possibly similar information that would not jeopardize the security of your card. We do not store credit card numbers. Your data is encrypted and safe with PayPal. See PayPal’s privacy policy at https://www.paypal.com/ie/webapps/mpp/ua/privacy-full


DigitalOcean

We may use DigitalOcean for API purposes or other developmental and/or data-based reasons to better add features. The API may communicate with third-party services, such as Steam, Stripe, MailChimp (opted-in), Discord, GameSparks, and other possible services. While we communicate with them to improve user-experiences (such as stats, Discord bots, and player disciplinary reports), your information is generally kept on third-party servers, such as GameSparks or Steam, to better protect your information. See DigitalOcean’s privacy policy at https://www.digitalocean.com/legal/privacy/


Twitch

https://twitch.tv is a website dedicated to streaming. With your permission, we may offer Twitch links to link your account and share streams and/or other Twitch information, such as friends. All privacy disclosures will be prompted for you to agree upon at the time of account linking. If you a are streaming Throne of Lies, we may also “host” and/or “autohost” you on the official Throne of Lies Twitch page at https://twitch.tv/ThroneOfLiesGame


Discord

https://discord.gg/tol is our primary community hub. We may use publicly-accessible information from this site and/or information agreed to upon a prompt that discloses what privacy information we request. See Discord’s privacy policy at https://discordapp.com/privacy


Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website/game. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.


Google

(Currently not in-game) We use Google Analytics for anonymous demographics to help improve our website(s). Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of www.example.com, to prepare reports on its activities and share them with other Google services.


Google may use the data collected to contextualize and personalize the ads of its own advertising network.


Google Analytics has the following features enabled

Site Tracking/Reporting

Demographics and Interest Reports

We may use this anonymous information

To better understand our users.

To compare different groups of users for conversion research.

To refine ad campaign strategies.

Learn more about how Google determines user demographics.

Learn more about how Google determines user interest categories.

Personal data collected: Cookie and Usage Data. Place of processing: USA. Find Google's privacy policy here https://www.google.com/intl/en/policies/privacy/ .


Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.


We have implemented the following

• Demographics and Interests Reporting


We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.


Opting out

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.


MailChimp Newsletter

To opt-out of our newsletter, there should be an unsubscribe button on every email. We have always used double opt-in for your privacy, so users pre-GDPR do not need to confirm again to stay subscribed.


California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf


According to CalOPPA, we agree to the following

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.


You may be notified of any Privacy Policy changes:

On our Privacy Policy Page ( https://www.throneoflies.com/legal/privacy.html )

And/or our official forum ( https://forum.imperium42.com )


Forum-Specific Notices

The board owner can read private messages.


You may change your personal information:

• By logging into your account. Not all personal information can be changed.


How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. However, this may break some mechanics on the website and should be considered browsing “as-is”.


Does our site allow third-party behavioral tracking?

It's also important to note that we do not allow third-party behavioral tracking


COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.


We do not specifically market to children under the age of 13 years old.


Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.


In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:


We will notify you via email - within 7 business days of company discovery.


We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.


CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.


We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions

• Process orders and to send information and updates pertaining to orders.

• Send you additional information related to your product and/or service

• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.


To be in accordance with CANSPAM, we agree to the following:

• Not use false or misleading subjects or email addresses.

• Identify the message as an advertisement in some reasonable way.

• Include the physical address of our business or site headquarters.

• Monitor third-party email marketing services for compliance, if one is used.

• Honor opt-out/unsubscribe requests quickly.

• Allow users to unsubscribe by using the link at the bottom of each email.


If at any time you would like to unsubscribe from receiving future emails, you can email us at

• Follow the instructions at the bottom of each email.

and we will promptly remove you from ALL correspondence.


Terms of Service

Our EULA can be found here: https://www.ThroneOfLies.com/legal/terms.html


Revisions

There will likely be an iteration of revisions throughout the game’s lifetime and can find the latest version at https://www.ThroneOfLies.com/legal/privacy.html - By continuing to use our services, you agree to adhere to the updated revisions. If you do not agree, please do not use our services.


Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below for our remote forwarding address:


https://www.ThroneOfLies.com

Imperium42®, LLC

848 N. Rainbow Blvd.

Unit #8058

Las Vegas, NV 89107 – 1103


support@imperium42.com

https://discord.gg/tol


GENERAL TERMS FOR ALL AGREEMENTS


Dispute Resolution


You agree to follow these Agreements’ dispute resolution policy as set forth below in connection with any potential claims or disputes arising from your purchase and use of the Game:

Informal Negotiations. Parties to a dispute concerning this Agreement or purchase and use of the Game will attempt to informally negotiate a potential settlement or resolution to the dispute.
Online Arbitration. In the event that informal negotiations are unsuccessful, the parties agree to follow the American Arbitration Association’s online arbitration procedures to resolve the dispute.
Binding Arbitration. If for any reason online arbitration is unsuccessful or unavailable to the parties, parties agree to submit to binding arbitration in Taipei, Taiwan (ROC), or a venue otherwise deemed convenient by both parties.


You agree that any arbitration shall be limited to the claim between Imperium42® and you individually.


YOU AGREE THAT (A) THERE IS NO RIGHT OR AUTHORITY FOR ANY DISPUTE TO BE ARBITRATED ON A CLASS-ACTION BASIS OR TO UTILIZE CLASS ACTION PROCEDURES; (B) THERE IS NO RIGHT OR AUTHORITY FOR ANY DISPUTE TO BE BROUGHT IN A PURPORTED REPRESENTATIVE CAPACITY OR AS A PRIVATE ATTORNEY GENERAL; AND (C) NO ARBITRATION SHALL BE JOINED WITH ANY OTHER.


No Waiver


Our failure to enforce at any time any of the provisions of these Agreements or related agreements shall in no way be construed to be a present or future waiver of such provisions, nor in any way affect the right of any party to enforce each and every such provision. The express waiver by us of any provision, condition or requirement of these Agreements or related agreements shall not constitute a waiver of any future obligation to comply with such provision, condition or requirement.


Miscellaneous Provisions


Jurisdiction and Choice of Law. The validity, interpretation, and performance of these Agreements are governed and controlled by the laws and regulations of Taipei, Taiwan (ROC). In the event of a dispute you agree to submit to the personal and exclusive jurisdiction of the courts of last resort in Taipei, Taiwan (ROC).


Severability. If any portion of these Agreements is found invalid by any competent Court of Law, the invalidity will not affect other provisions or applications of the remainder of this Agreement which can be given effect without the invalid portion.


Notification of Changes to these Agreements. We may from time to time change one or more of the Agreements herein, or certain parts thereof. You agree that notification to you of these changes will be effective upon updating the EULA in an update of the Game or via update on the Website.


Prior Versions. These Agreements constitute the full understanding of your agreement with us. Any prior versions of this document have no effect on these Agreements.


Assignment. These Agreements may be assigned by us to any third party at our sole discretion. You may permanently transfer all of your rights under the End User License Agreement to a recipient, provided that the recipient agrees to the terms of this License and you remove the Game from your computer.


Legal Fees. In the event that either party is required to obtain the assistance of an attorney in order to enforce the terms of these Agreements, the party prevailing in such an enforcement action will be entitled to recovery of all reasonable attorney’s fees in connection with such action.


Survival. All provisions intended to survive termination of these Agreements, including but not limited to rights granted to us pursuant to the Community Guidelines, disclaimers, limitations of liability and no warranties, payment rights and restrictions, and other such ongoing limitations, obligations, or disclaimers of the parties will survive the termination of these Agreements.


Conclusion. If you do not agree with this document’s Terms of Service, End-User License Agreement or Privacy Policy, please do not play the game. If you purchased through Steam, at the time the last edit of this license agreement and to the extent of our last-known knowledge regarding Valve/Steam policites, you are eligible for a refund within two (2) hours via (and issued by) Steam.


3 - General Data Protection Regulation (GDPR) - Privacy Policy Extension




INTRODUCTION

Imperium42, LLC complies with GDPR. As a general rule of thumb, the instructions for submitting requests below are the recommended ways to go about making the request, as they may be automated, easier to do, secure, and timely (sometimes even instant compliance, if automated). There are other ways to make such requests, however they may be manually done and take more time to respond (up to 30 days).


Since GDPR requirements, we have extended our privacy policy and any existing players will have to re-agree these new agreements/policies as we update for compliance.


One thing to note is that nearly all below “why” reasons for collecting data can nearly all append “and to diagnose issues/errors”. As with any program (which is why companies update), there is no such thing as bug-free software. When there are issues, most all of the data collected below may also be used to diagnose issues/errors in a timely manner and have samples for comparison to help replicate an issue to fix, find patterns, and such. For example, if a user cannot get past the login screen and we notice his email is blank or incorrect, we know it’s an issue regarding the email (or just before it). If a user has an issue with a microtransaction purchase, we can lookup his Steam order ID to query Steam to ask for status information. As a technical, online game, every single piece of data is used in some form in addition to diagnosing bugs/errors such as the examples above.


Another major “used for many things” set of data is for moderation purposes. As an online social game where 16 players make up the plot using words (text), one can imagine that toxicity is possible in numerous forms. Thus, if a player is reported, logs, in-game names, log journals, deathnotes, player match information and such are necessary to effectively moderate. Read more about our transparent moderation practices: http://throneofli.es/moderation


Because we are awesome, we will put forth our greatest effort to extend GDPR’s policies worldwide (instead of only Europe) as we believe everyone should have access to their own data and erase themselves (partially or completely) if that’s what they want to do.


You may use our automated system to automatically gather your data once per 15 days.


Each service will contain the following:


WHEN DO WE AGREE TO THE COLLECTION OF INFORMATION?
WHAT SPECIFIC DATA IS COLLECTED / PRIVACY SCOPE? WHY (WHAT USE)?
OPT-OUT
ERASURE
REQUEST YOUR DATA

“PRIVATE” VS “PUBLIC” INFORMATION (PRIVACY SCOPE):


Private = This information is not shared publicly, but may be shared with staff.
Public = Anyone can see the data in any form. For example, the results of a match, your display name (nickname), avatar, title, etc. Just because it’s public doesn’t mean the user or other users have instant access to it -- it just means it’s potentially publicly available. There also may be exceptions, such as when using 3rd-party services: For example, SteamId isn’t always available to be public -- but sometimes it is.

Throne of Lies (Online Game):


A - WHEN DO WE AGREE TO THE COLLECTION OF INFORMATION?

When you first played Throne of Lies, you agreed to our ToS, EULA and privacy policy. These are displayed when you first install the game and before you login. You would not be allowed to progress until you physically clicked the “view agreement(s)” (or similarly-named) button and physically checked the “I agree” (or similarly-named) checkboxes. As an online game, more information collection is necessary than an online game. Because some users may be found to disrupt other user game experiences since it is an online game, moderation practices may require additional information. This is generally speaking, as more specifics are below.


B - WHAT SPECIFIC DATA IS COLLECTED IS COLLECTED ABOUT ME / PRIVACY SCOPE? WHY?


Private:


IP Address = Used either as last used or as a list to detect duplicate account; assist in disciplinary actions; detect ban evasion; to overall improve our moderation practices for players reported by the Steam community; and to uphold our ToS/EULA. The IP is also shared with Photon (our game servers) to provide Photon services (the game, itself), but are not stored with them unless errors occur. Also helps security and prevents fraud. The processing of this specific data is necessary for the legitimate interest/purposes of ensuring network security and for information security/to prevent exploitation.
Mac Address = Used either as last used or as a list to detect duplicate account; assist in disciplinary actions; detect ban evasion; to overall improve our moderation practices for players reported by the Steam community; and to uphold our ToS/EULA. Also helps security and prevents fraud. The processing of this specific data is necessary for the legitimate interest/purposes of ensuring network security and for information security/to prevent exploitation.
Email = We store your email address entered at registration. Although we check if the email formatting is valid, we no longer check if the email is subscribed. This email may be bogus - we do not know: All we know is what you typed at registration. This assists in speeding up help desk support tickets, matching Kickstarter or other supporting sites to claim rewards, and practical reasons such as alert for data breaches. We do not share this with anyone except MailChimp and only if the user has double-opted in.
Email Status = This is the last-known email subscription status to the double-opted-in MailChimp email list. This may not be as updated as directly checking MailChimp, but helps speed up inquiries if a user is having issues opting out. We also have backlog to potentially reward players for subscribing to us.
Last Authentication Token = This verifies the user is who they say they are for the session. Prevents hacking, mostly. We can verify it in the back-end.
VTD Cents = Total Real-Life money spent on in-game purchases. This is retained for when we adjust pricing and can potentially reimburse players that spent a greater amount of money, if inflated.
Number of Real-Life Purchases Made = Total quantity of in-game purchases. This is retained in case a user files a claim saying they never made a purchase before - this quickly helps us verify. We may also compare the number of real life purchases made to the VTD, above, to see if we should lower our prices to ensure everyone’s happy with the price-reward ratio.
Steam Receipt - Success = Used to track the success of a Steam microtransaction and to confirm proof of receipt. This also helps with diagnostics if a transaction failed.
Steam Receipt - Item Key/ID = Used to track what item a Steam microtransaction purchase was and to confirm proof of receipt if inquired or audited. This also helps with diagnostics if a transaction failed.
Steam Receipt - Steam Response - Result / OrderId / TransactionId = Steam’s response to the microtransaction result to ensure records match if inquired or audited. This also helps with diagnostics if a transaction failed.
Steam Receipt - Stage / Memo = Confirms whether the microtransaction purchase was in a live or sandbox environment and if it’s waiting on the customer via a popup or if it went through. Only live transactions go through. This also helps with diagnostics if a transaction failed.
Steam Receipt - Item Info = Confirms the item purchase and details, such as item id, total amount of gold (gp) granted, bonus gp from the purchase (depending on the tier), cost in cents, category (“GOLD” is the only category we have, currently), description (“xx gold pieces”), gold tier (1~5, for example)
Steam Receipt - Date / Time Purchased = Confirms the time/date purchased if inquired or audited.
GDPR - Gdpr Num Times Request Fulfilled = How many times a user requested their data and we fulfilled the request (automatically). Used to ensure compliance and prevent abuse.
GDPR - Last Fulfilled Request Date = When the user last requested their data and when we sent it to them (automatically). Proof of compliance.
GDPR - Last Fulfilled Request Time = When the user last requested their data and when we sent it to them (automatically). Proof of compliance.
Twitch - oAuth2 Information (+8/29/2018) = We store Twitch oAuth2 (Twitch linking) information to bring Twitch features to the game, such as secrets and tokens. The access token and refresh token are private - others are public. See Twitch’s privacy policy here: https://www.twitch.tv/p/legal/privacy-policy/
Discord - oAuth2 Information (+8/29/2018) = We store Discord oAuth2 (Discord linking) information to bring Discord features to the game, such as secrets and tokens. We don’t normally have this unless you link it, yourself. Don’t confuse Discord oAuth2 info with the Discord “RPC” user information that is public. See Discord’s privacy policy here: https://discordapp.com/privacy
DeviceID = Either last used or in a list, used to detect duplicate account; assist in disciplinary actions; detect ban evasion; to overall improve our moderation practices for players reported by the Steam community; and to uphold our ToS/EULA. Also helps security and prevents fraud. The processing of this specific data is necessary for the legitimate interest/purposes of ensuring network security and for information security/to prevent exploitation.

Any other information/data not explicitly listed here will be considered Public data.


Public

Note: Most data classified as “public” is actually “semi-private” until called upon. Many pieces of public information only other player computers see (not the actual player) unless a log is posted for a bug report or issue that may contain some of this information, becoming public. For the sake of this privacy policy, to be safe, we’ll call it all “Public”:


Game ID / _id / PlayerId / FriendId / pid = Sort of like your fingerprint identity -- most all database entries are linked to this to help identify your game character. You can’t do anything private with this ID, so it’s fine if other people see it - it’s not a secret, but the average player has no use for it so we generally keep it semi-private. Friends also have access to this. The ID is also sent to Photon to enable Photon services (the game servers, itself), but are not stored with them unless errors occur.
GameSparks System - SparkPlayer = System information saved by default via GameSparks. Core player information to help you login and do normal game tasks. See their documentation to see what we can do with this data: https://docs.gamesparks.com/api-documentation/cloud-code-api/player/sparkplayer.html
GameSparks System - SparkPlayer - Active Games = The Imperium42 games you play so you don’t have to create multiple accounts (In theory) when we make a 2nd+ game. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - Active = Is the user active or inactive? In inactive, certain features may enable or disable. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - syncDisplayName = This synchronizes the DIsplayName and UserName. It’s the same thing. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - externalDisplayName = Your Steam name used for authentication, share with Steam friends (friends list), and debugging. Also used to find a player via Steam ID in game logic. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - externalUserName = Your Steam ID prefixed with “ST_” for Steam connection relations and to find a player via Steam ID in game logic. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - externalUserId = The exact same thing as your SteamId, just called something different. See steamID below for more information. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - externalSystemId = The primary way we link your account so we can use passwordless authentication. In this case, Steam (“ST”). Helps us recognize the authentication mechanism. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - profilePic = The URL of your profile pic. This will allow for game profiles to include your Steam profile picture instead of something boring. Profile pictures are public via Steam. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - lastRefresh = The last date and time this information was updated. Assists to determine if the data is up-to-date. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - userName = Your original username automatically generated by GameSparks before your official username is chosen. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - segments = We may put players in segments such as “ALPHA_STATUS” to handle events for groups of players that participated in special events such as alpha, beta, and the Kickstarter. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - online = Same as isOnline below. If the user is offline, events shouldn’t be allowed. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - externalAuthentication = Stores SteamId. Used in other entires below. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - achievements = Coming soon to assist ease the implementation of Steam achievements. Currently empty. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - currencies = Stores how much gold you have for varies in-game purchases. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - authTokens = Securely logs you in. Prevents hacking. Ensures identity. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - gameId = The Imperium42 game. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - created = Date registered. Can be used for veteran rewards. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - location= The region where you are most likely located (approximate country, city, latitude and longitude). Used for geographical restrictions, GDPR compliance, per-region laws. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - lastSeen = Date last logged in. Used for upcoming daily rewards and time-since-last-played logic. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - lastActiveHour = Time of last active session. Used for upcoming daily rewards and time-since-last-played logic. This data is automatically generated by GameSparks
GameSparks System - SparkPlayer - DisplayName = The same as DisplayName below - this is just the initial system save. This data is automatically generated by GameSparks.
GameSparks System - SparkPlayer - sessionTimeTotal = The total amount of sessions a user logged in. Used for upcoming achievements. This data is automatically generated by GameSparks.
GameSparks System - Messages - notification = Whether we should notify the user regarding an incoming message or wait until they’re back in the lobby.
GameSparks System - Messages - includeInCount = Arbitrary value used by GameSparks logic. This data is automatically generated by GameSparks.
GameSparks System - Messages - When = Date the message was sent. Tracks expiration of message. This data is automatically generated by GameSparks.
GameSparks System - Messages - seen = Triggered when the user has seen the message. This prevents us spamming the same message if it’s already seen. This data is automatically generated by GameSparks.
GameSparks System - Messages - serverSeen = This means it’s seen by their computer, but not yet by the player. Waiting to show it to the player. This data is automatically generated by GameSparks.
GameSparks System - Messages - dismissed = Triggered when the user has seen and acknowledged message received. Also used for confirmation of warning/disciplinary action messages. This data is automatically generated by GameSparks.
GameSparks System - Messages - expiresAt = The date the message will be deleted from the database automatically. This data is automatically generated by GameSparks.
GameSparks System - Messages - summary = Message content template. Used to swap placeholder values. This data is automatically generated by GameSparks.
GameSparks System - Messages - title = Title of the message. Without this, messages would be boring. This data is automatically generated by GameSparks.
GameSparks System - Messages - subtitle = Subtitle of the message. Without this, messages would have no “short version” or “extra info”. This data is automatically generated by GameSparks.
GameSparks System - Messages - message = The message itself. Without this, there would be no message! This data is automatically generated by GameSparks.
GameSparks System - Messages - messageClass = The type of message sent. For example, silent messages will be silent until you enter the lobby. This data is automatically generated by GameSparks.
GameSparks System - PlayerTransactionAudit - reason = The reason for storage, such as “bought item with currency”. This data is automatically generated by GameSparks.
GameSparks System - PlayerTransactionAudit - requestId = The unique ID related to the transaction. Sort of like a merchant-kept receipt used to identify a transaction in case of dispute. This data is automatically generated by GameSparks.
GameSparks System - PlayerTransactionAudit - scriptType = Records what stage the purchase is in - for example, request or response. This data is automatically generated by GameSparks.
GameSparks System - PlayerTransactionAudit - goods = The list of virtual goods purchased, the amount the virtual good is worth and the new value (quantity) of the good. This data is automatically generated by GameSparks.
GameSparks System - uploadedFiles = Storage of reporting deathnotes or uploading deathnotes and/or bug reports and/or logs. This data is automatically generated by GameSparks.
Synchronization Versions = When we make updates to our database architecture, we save what version you last updated. This information is semi-private because players don’t normally see this number, but it’s useless if they actually do see it publicly.
Randomize gear preference = Remember your preference to randomize your gear or not or normally the option would revert when you leave that section. Although this isn’t public, it’s useless information to the average person. This helps when you play with friends and you don’t want them to recognize who you are each time or the same reason you change your clothes each day instead of buying the 20 pairs of the same one (simply for fun / for a change).
Equipped weapon = We want to remember your selected weapon so we can equip it in-game.
Equipped Armor = We want to remember your selected weapon so we can equip it in-game.
Equipped Emote - We want to remember your selected emote so we can equip it in-game.
Term ver accepted = What version was the latest ToS/EULA/Privacy Policy seen and agreed to? Used for GDPR compliance and proof of terms/policies seen/accepted.
Registration source = Currently every one should say “Game”, but during our early stages, we experimented with website and pre-Kickstarter registration. We want to experiment with different ways to register for an easier experience.
Saw Matchmaking tutorial = We force the tutorial on the first run. Without this, we’d never know to let you in to matchmake and only forever see the tutorial.
Saw interactive tutorial = We used to have a “welcome screen” when you first login. Without this, we’d never know you saw the welcome screen and would infinitely show it each login. We will add another welcome screen soon, if not already, by the time you read this.
Last version = This aids us with login issues, ensures the user isn’t hacking (if the version was completely differently-formatted, for example), verifies server-side the version matches, sometimes notifies you that an update is required (perhaps you may crash if you continue without updating).
Steam ID = Used for authentication, moderation practices, linking Steam to 1-click login, and unique identification. Some users prefer to keep it public, some private. When used in moderation practices, if it is going to be displayed publicly (Discord #justice, via a public appeal or alleging innocence, and such practical cases), we generally censor out all but the last 4 digits. However, some cases may reveal the full steam ID, if it is public information at that time. Friends also have access to this. May not be public all the time, depending on the user’s Steam preferences.
Friend status = Was your friend request accepted? Rejected? Ignored?
Alpha status = If you participated in Alpha testing, you get a special flag that will soon be used for special perks, such as an avatar, title, or some form of prestige. This may be displayed to friends or publicly.
List of titles = Whatever titles you may have unlocked while playing or supporting our game in some form (Patreon, Kickstarter, or an event/promo). Some may be manually added by staff and is generally a prestige addition.
List of avatars = Whatever avatars you may have unlocked while playing or supporting our game in some form (Patreon, Kickstarter, or an event/promo). Some may be manually added by staff and is generally a prestige addition.
Display name history = This is mostly used for moderation practices. Let’s say a person named <super obscene name> gets reported by several players and immediately changes his name after, this contains proof of display name. This also helps us find a player via an inquiry if the user accidentally mentions an old name, forgetting he changed it.
Steam Name = Since our authentication system requires Steam, this assists with generally debugging if a user is unable to login. If a user has an issue with microtransaction or other Steam-related issue, this will assist in speeding up the case. Used in moderation practices. Your Steam name is also used to help auto-generate a username/display name for you. Your Steam friends may also be able to see this for your initial friends list. May be used in moderation practices.
Is Banned = Is the user banned (suspended)? If suspended, the user is unable to login per our EULA. It also informs us to popup a message upon login. If a user queries they can’t login, we can immediately see why. Likely also used in moderation practices.
Display Name = Users have their game ID to uniquely identify themselves, but display names are what other players see.
Backer status = You’d get this as a Kickstarter backer. This helps us diagnose Kickstarter rewards, if they claimed their pledge rewards, and may even offer future perks as our thanks.
Last Class = We store your last class to prioritize not getting the same class twice in a row. If a user claims he got tons of the same class in a row, this also helps us diagnose the issue. This may be displayed in other places, such as rich presence. May be displayed to the user one day for fun.
Last room = The room name (like tol-r-asdf123-123=). This helps aid reconnection to your last game and “get” your last match from the database for queries. This also helps moderation purposes to lookup your last known room. Likely also used in moderation practices.
Selected title = The text title you see in the lobby, when a user invites you to a game, possibly shown in the future in matchmaking, experimentally shown in rich presence.
Selected avatar = The avatar picture you see in the lobby, when a user invites you to a game, possibly shown in the future in matchmaking, experimentally shown in rich presence.
Is Guide = This is a volunteer prestige role that has extra perks such as a unique title/avatar. This also helps us track how many guides we currently have by aggregating this stat. Select guides (called Judges) have extended Discord BOT commands for moderation features.
Is Mod = This is a volunteer prestige role that has extra perks such as a unique title/avatar and extra gold (gp). This also helps us track how many moderators we currently have by aggregating this stat. Moderators have extended Discord BOT commands for moderation features.
Is Staff = Are they a contracted Imperium42 staff member? If so, grant extra diagnostic abilities and moderation privileges.
Registration Date = When you registered. Useful to track seniority and offer prestige perks for those that have been with us longer. Likely also used in moderation practices to help determine how new the user is to help make a judgment call. It may also show in some form for potential anniversary perks.
Last Name Change Date = You can only change your name once every 24 hours to prevent abuse. When you change your name, this detects it. This also aids in moderation practices if a user did something bad then immediately changed his name.
Last Ban Date = Helps aid moderation, generally to find out when the user was last suspended, if at all. For example, if the user was suspended recently and tons of players reported him after just getting off a suspension, it shows a negative pattern and his disciplinary action may be greater than the previous one.
Last Ban Reason = Helps aid moderation, generally to find out why the user was last suspended, if at all. For example, if the user was suspended recently and tons of players reported him after just getting off a suspension and new incoming reports are showing it’s for the same reason, it shows a negative pattern and his disciplinary action may be greater than the previous one. This may be publicly shown in the Discord #justice channel in a semi-anonymous fashion (we may include the proof of ban reason + history + basic user info, but no text so users can’t CTRL+F find certain users/reasons).
Last Status = Rich presence, such as “Matchmaking”, “In-Game”, and similar statuses that friends may see. For example, if a user can’t be invited, it may look like a bug - if you see your friend is currently in a match, it’s more intuitive why you can’t invite them to your game. Common practice in online video games with friend lists.
Room Name / Room Name History = Shows previous rooms the user was in for both debugging and moderation purposes. If a user was reported, this is proof the user was in that game and can reference the match information from there. If a room was buggy, this helps us diagnose what’s going on.
Is Online = For rich presence use - if online, then notify friends of other friend status changes, for example.
Last IGN (In-Game Name) / IGN / IGN History = Shows your last in-game name (+history). Mostly used for moderation purposes (let’s say the user was reported for an inappropriate name) or if a user inquires about a match but only remembers his in-game name. May be displayed the user one day for fun.
Journal / Journal Left / Journal Right = Mostly used for moderation purposes (say, if a user was reported for racism in their journal logs). However, it may also be used to analyze how players store their journal logs to improve the feature. It may also be used for Twitch API use for user engagement - for example, a user could click the journal area and see your last-known journal/log entry. May also be used for achievements (write x characters total journal logs).
Room Status = This is used for our matchmaking/reconnection logic where things you do are dependent on the status of the room (pre-game, mid-game, end-game, and such).
Game Status = While this is also used for game logic to decide what you can or cannot do depending on your game status (such as “Matchmaking” or “Tutorial”), it’s also used for rich presence.
Game Mode = Detect if you’re on Casual Mode, Classic Mode, etc. Currently, the only mode is “Classic”, but there have been two historical, alternate game modes. Some modes enable/disable different feature sets. May also be used for achievements (play x mode).
Is Match Private / In Private Group = Matchmaking logic - if the match is private, for example, we want to show x or y buttons that we wouldn’t normally show in public (such as queue as group / start game early). May also be used for achievements (play x private games).
Player Start Count = The number of players that started in a match. We can see how often players stay until the end and use for achievements. It’s also used to calculate gold (gp) earnings (full groups mean more gold distribution).
Player End Count = Determine how many players stay until the end of the game used to see if we need to improve the post-death spectator experience. Low counts may mean uninteresting matches to watch.
Date Match Started = The date when the match started. Mostly used for moderation purposes or the potential use of community websites that show match information. Also for debugging purposes (if date start/end are not realistic, there may be errors). May also be used for seasonal promotions.
Time Match Started = The time when the match started. Mostly used for moderation purposes or the potential use of community websites that show match information. Also for debugging purposes (if date start/end are not realistic, there may be errors). May also be used for time-based achievements.
Date Match Finished = The date when the match ended. Mostly used for moderation purposes or the potential use of community websites that show match information. Also for debugging purposes (if date start/end are not realistic, there may be errors). May also be used for seasonal promotions.
Time Match Finished = The time when the match ended. Mostly used for moderation purposes or the potential use of community websites that show match information. Also for debugging purposes (if date start/end are not realistic, there may be errors). May also be used in time-based achievements.
Is Match Live = Used to determine if a match is currently live or not. If live, for example, we do not want to disturb the users when moderating. This may also be used for flags to determine if features should be enabled/disabled, such as reconnection.
Match Day = Used to determine what day (count) in-game it is. This can be used to analyze how long games usually last (how many days) and to determine certain game logic (such as “don’t allow x ability for the first 3 days”). May be an achievement one day to play x days or end the game before/after x days.
Match is Day (or Night) = Used to determine what phase (day/night) the game is in for certain game logic (abilities and mechanics change between day and night). Also potentially used for an upcoming Twitch overlay to determine what abilities a user has for viewers to hover over to determine what abilities they have (since day/night abilities differ).
Number of Players Alive = The number of players alive. For example, some abilities may require a need to know how many players are alive before a mechanic kicks in. Also potentially used for an upcoming Twitch overlay to show a graphical visual of how many players are left alive just for fun. May also be an achievement soon for winning with x teammates alive.
Last Master Id = The master’s id that is the random client responsible to tell the server who won and related match information. We use the master ID to diagnose issues if a call failed. Since master’s are responsible for reporting the entire match’s win/losses to determine who gets gold or not, it’s very important to diagnose issues.
Last Master Display Name = Simply used for easy reference in case we recognize the name for speedier diagnosis than looking at an ID. 25%+ of our playerbase is in Discord, so they would be way easier to contact fast if we know the name of the master if experiencing issues to ask for logs or questions about the match.
Match Players List = List of players in a match. Shared, public information listed either (already) above or below.
Match Friendly Winners String = Match summary used for end screen, Discord BOT, and in-game to show a friendly version of who won, like “Blue Dragon + The Mercenary”.
Match Winning Classes List = List of winning classes to help us determine balance, a core mechanic of the game. Also used to diagnose issues if the winners string above says “King” won when he may not be in the winners class list. May also be an achievement to win “with x class”.
Match Winning Factions List = List of winning factions to help us determine balance, a core mechanic of the game. Also used to diagnose issues if the winners string above says “Unseen” faction won, yet no Unseen faction members were in the class winners list. May also be an achievement one day to “win with Neutral faction”, for example.
Match Spectators List = List of spectator IDs. We have to differentiate players vs spectators since spectators don’t actually play. Effects core gameplay mechanics. May also be an achievement soon for spectating x games all the way.
Match Player’s “Pi” Index = The in-game index value of your player. Arbitrary to anyone looking at it, but crucial to diagnose bugs.
Match Player’s Start Class = The player’s start class of a match. Not only for awareness, but also to ensure you don’t get the same class twice (or at least attempt it). Also used to show the end screen summary at the end and for an upcoming player match list. Also used for moderation purposes. Also used for player statistics. May also be an achievement soon.
Match Player’s End Class = The player’s final class at the end of a match. Used at the end screen and also determines if the player was “converted” or not. This further helps with moderation. Also used for player statistics. May also be an achievement soon.
Match Player’s Start Faction = The player’s start faction at the beginning of a match. Used at the end screen and also determines if the player was “converted” or not. This further helps with moderation. Also used for player statistics. May also be an achievement soon.
Match Player’s End Faction = The player’s final faction at the end of a match. Used at the end screen and also determines if the player was “converted” or not. This further helps with moderation. Also used for player statistics. May also be an achievement soon.
Match Player’s Is Alive = Determines if the player is currently alive or finished the game alive. If not alive, the opposite is dead. Used for moderation and also for player statistics. May also be an achievement soon for staying alive until the end.
Match Player’s Loaded In Game = Ensures a user was loaded in the game. Also used for moderation practices (let’s say a user said someone quit on purpose - if they never loaded in the game, it’s likely accidental). Because loading between lobby and in-game is such an important mechanic, it’s also used to diagnose issues.
Match Player’s Was Connected Until End = Used for achievements, gold (gp) distribution (mainly for the bonus gp, at the moment), and to detect trends for intentional leaving (“gamethrowing”) for moderation purposes. May also be an achievement soon if stayed until the end.
Match Player’s Left Game Reason = The canned reason a player left the game. If a user was disconnected, this helps diagnose what most likely happened, such as “Left Won”, “Left Dead”, “Left Alive”. This also helps with moderation since it’s more clear than “was connected until the end”.
Match Player’s Is Eligible To Reconnect = If eligible to reconnect, show the reconnection screen. Reconnection is a complex mechanic and ongoing diagnostics of eligibility to reconnect is necessary for the feature to continue functioning properly. Also used in moderation (if a user is ineligible in a normal situation, perhaps he quit on purpose).
Match Player’s Player Connection Int = The same thing as “left game reason”, but in a form easier for game logic to do something with it (0 = connected, for example). Also used in moderation.
Match Player Won = Did the player win? Also used for moderation (for example, if 1 word against another, we can determine motive if a player won or not). Also for historical purposes; we want to make a stat website soon. Will likely also be an achievement soon.
Match Creator Id = Used for diagnostic purposes. If the creator had an issue creating a room, we can find patterns and diagnostic information if we know the match creator’s id.
Warnings / Ban (Suspension) List = List of a user’s warnings/bans (suspensions) to aid in moderation. Historical warns/bans assist in finding patterns to determine both truth and disciplinary action length determination.
Warnings / Ban (Suspension) Message (Reason) = Used to aid in moderation. Historical warns/bans reasons assist in finding patterns to determine both truth and disciplinary action length determination.
Date Warned / Banned = Used to aid in moderation. We need to know if they are currently banned or were historically banned. This also helps with the ban message to provide more awareness to suspended players.
Time Warned / Banned = Used to aid in moderation. We need to know if they are currently banned or were historically banned. This also helps with the ban message to provide more awareness to suspended players.
Days Banned = Used to aid in moderation. We show users a simply number of days they are banned in addition to other mentioned awareness in this document. Also helps compute when the user should be unbanned.
Reports Received List = Used to aid in moderation. Historical warns/bans reasons assist in finding patterns to determine both truth and disciplinary action length determination.
Reports Given List = Used to aid in moderation. Some players may abuse outgoing reports. Also used to track the ratio of outgoing reports to games played to determine the potential legitimacy of a report (fewer reports are more likely to be more genuine).
VAC Report Id = We participate in Steam’s Valve-Anti-Cheat (VAC). When a player report is received, an ID is returned. Read more about VAC here: https://partner.steamgames.com/doc/features/anticheat
Friend Group = Currently always “None”. We may later split it to “Steam Friends” and “Non-Steam Friends”. If we add other integrations, we may include that, too (such as “Twitch Friends”). Would be used for filtering.
Stat - Times Logged In = Helps determine how often users login the game for analytical purposes (generally the number of “sessions”). Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Will likely also be an achievement soon.
Stat - Number of items purchased = Total number of items purchased in the gold (gp) store. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Will likely also be an achievement soon.
Stat - Games Played [Per-Mode] = Total number of games played. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Some are per-mode stats. Will also likely be an achievement soon.
Stat - Games Quit Alive = Helps determine moderation trends whether a user quits alive or not since quitting alive is gamethrowing if done on purpose. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Some are per-mode stats.
Stat - Gold (gp) spent = Total In-game currency spent on customization unlockables. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Some are per-mode stats. Will probably also be an achievement soon (spent x gp).
Stat - Total Gp Earned = Total gp earned from playing games (every match you gain gold/gp). May also be included in upcoming achievements (earned x gp). Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics.
Stat - Played [+Dynamic wins per-class/faction] = Total games played [or dynamically, like GamesPlayedAs<ClassName>]. May also be used to determine ranking in future game modes. May also be included in upcoming achievements (play x games). Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics.
Stat - Wins [+Dynamic wins per-class/faction] = Total wins. May also be used to determine ranking in future game modes. May also be included in upcoming achievements (win x times). Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Helps also determine balance.
Stat - Losses [+Dynamic losses per-class/faction] = Total losses. May also be used to determine ranking in future game modes. May also be included in upcoming achievements (maintain an x:x win:loss ratio after y games). Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Helps also determine balance.
Stat - Leaves While Alive, Not Won = Helps determine moderation trends if the user leaves often and won while alive. Deprecated stat, probably removed soon. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics.
Stat - Start Class <Class or Faction> Play/Win/Loss Count = Dynamic stats for determining play/win/loss counts with certain classes or factions. Helps also determine balance. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics. Also helps diagnose “class spawning” issues.
Stat - TImes Converted [May later add per-class dynamic “Converted” stats] = Number of times you were “converted” from good to evil via game mechanics. Will soon show to the user in an upcoming “stats update”, as it’s also simply “interesting”, like most public game statistics.
We also use GameAnalytics = Mentioned above ( http://gameanalytics.com/ ) for analytics purposes. Imperium42 uses it to analyze anonymous information, such as errors, crash reasons, aggregated number of players, trends and funnels such as retention (how often you play), and to track aggregated balance information so we can ensure the game is fun for everyone and to also ensure we’re not going broke by looking at trends/statistics! We have also considered an auto-balance feature pulled from aggregate stats (we’ll see). More GA information can be found here: https://gameanalytics.com/gdpr-faq

Although GameAnalytics can sometimes be used for the purpose of marketing, Imperium42, LLC only partakes in the analytics-side to improve the game. If we ever decide to use it for marketing, we’ll update the privacy policy and add an “opt-in” option, default off.

We may rarely share aggregate (anonymous) data to investors for the purpose of… well, potential investment, if they like our numbers! Investors means higher budget so we can improve the game even more, similarly to our v1.1 UI revamp as the result of a higher budget.
Server-side Error/warning/debug logs = Helps us find errors. Some calls may have your ID so we can contact you more information if something is wrong (let’s say this is the only player that gets this error and everyone else is good). Sometimes we may not need to contact you if we can resolve the issue. For example, let’s say players aren’t getting gold … we can search that error and for each player ID, grant gold reimbursement. We delete the logs when we resolve an issue. Note these logs are NOT the same as the ones on your local computer generated by Unity (our game engine): You’d have to specifically pass those along, if requested and you give them to us to review at your own consent.
GDPR - Is Opt Out = Whether you opt out or not so our game logic doesn’t crash trying to access values that don’t exist -- also to ensure we don’t save unnecessary information that you opted out of that isn’t core to the game. If you are opt out, some features may be disabled. Let’s say a friend wants to see a statistic - we’ll have to detect this and deny.
GDPR - Is Erased = Whether your identifiable persona was completely erased or not. Helps server records, for example, if errors are returned due to information being blank/redacted/anonymized/pseudonymized. Also if something is buggy, we can check to see if it was because of the revamp for GDPR.
GDPR - Erase Date = Proof of erasure attached to a pseudonymized ID. Cannot be identified unless the original party has some form of proof via their own, local logs. Held on in case the erasure was ever contested.
GDPR - Erase Time = Proof of erasure attached to a pseudonymized ID to accompany the date. Cannot be identified unless the original party has some form of proof via their own, local logs. Held on in case the erasure was ever contested.
GDPR Malicious Disciplinary Actions Retained = If a user requests erasure and if the user is considered potentially malicious (determined if the user has ever received a suspension or greater disciplinary action), suspension data (mentioned here above) may be retained for security/anti-exploitation purposes/to prove breach of contract (EULA/Terms of Service). More about this below under ERASURE.
We may present proof of game identity and/or proof of disciplinary action if contested, appealing, challenged, dishonest (ultimately slandering Imperium42, such as saying suspended for a reason that is untrue) to prove that we were fair and just with our moderation practices / disciplinary actions. Proof may be uploaded to an image hosting service since we do not have our own dedicated image hosting service (such as imgur.com). This is information considered public only. For example, we will never show private data in these proof images. As a specific example, we’ll never show a full mac or IP address within a proof image. This proof may also appear in Discord’s #justice channel for proof of moderation, as some games only pretend to moderate.
GameSparks system Backups are retained for up to 7 days are then automatically deleted.
Twitch - Link/User Information (+8/29/2018) = We store Twitch user information to bring Twitch features to the game, such as broadcaster type, channel description, display name, id, login name, offline image url, profile image url, type, and view count. You can view the scope of the requests we ask when you link your account via oAuth2 on Twitch’s website. See Twitch’s privacy policy here: https://www.twitch.tv/p/legal/privacy-policy/
Discord - Link/User Information (+8/29/2018) = We store Discord user information information to bring Discord features to the game, such as userId, username, discriminator, and avatar. This is automatically saved if you enable Discord’s RPC service (rich presence - where it shows your live game info in your profile). See Discord’s privacy policy here: https://discordapp.com/privacy
Player Match Info (+8/29/2018) = We store the last roomID [history/list] (room lookups, stats, moderation, diagnostics), last start class [history/list] (so we can reduce the chances you get the same class), lastIGN [history/list] (moderation, query, diagnostics), last journal left/right (for upcoming Twitch plugin, debug, and moderation).

We make automated decisions for/about you:


We wouldn’t be a very fun video game (or a video game at all) if we didn’t!


Various in-game fulfillments of core gameplay logic based on both realtime, retained data (mentioned here), or cached (temporarily saved - just for the session) data, such as “if you buy an item and you don’t have enough gold, prompt a popup that says you don’t have enough gold” or “if you already used x ability, don’t allow to press it again until the cooldown is fulfilled”. Very standard video game automated decisions. Let us know if you have specific questions about this via the contact information below for Imperium42.
If you are suspended, we check to make sure you are not ban evading by checking IP/Mac address/Steam Family Share/DeviceIDs to determine if you are evading or not. If you are suspension evading, your evading account will be suspended for a generous amount of time (currently 30 days).
If you are suspended, we will eliminate the ability to login per our EULA/ToS.
We will silence certain messages that are sent to you if you are currently in-game and will queue it up for when you return to the lobby to prevent breaking immersion. Unless it’s super critical.
If you have not yet taken the tutorial, we will force the tutorial on you.
If you left the game alive, we will force you to at least attempt a reconnection since it’s gamethrowing if you do not attempt this (against our EULA/ToS).
If you opt out, some features may be disabled.
If you are new, we will prompt you to register generally via Steam oAuth ( https://partner.steamgames.com/doc/features/auth ) and your email. We may use other ways to register/login in the future.
We only allow you to request your GDPR data automatically from within the game once every 15 days or we’ll automatically lock the button. If it’s within the “locked out” timeframe, it is considered “excessive” to request it again so soon and we may charge a reasonable fee for requests outside of this timeframe. In that case, please see our contact information below to make a special request.
We may share your public information with other staff members and/or other volunteer community members (such as Guides, Judges and Moderators) for moderation purposes: To prevent/catch players from cheating, breaking the above Code of Conduct or any other parts of our Terms of Service / EULA. This information may also be available in Discord, but comes from the same database.

Any other information/data not explicitly listed here will still be considered Public data.


C - OPT-IN/OUT


You’re all good! We have never used your in-game information for marketing purposes. If we do in the future, we’ll add opt-in features for that.


D - ERASURE


You may erase most all of your information from the game. The easiest way to do this follows (after the 1.1.4+ patch):


Securely login to the game via 1-click Steam login (token-based authentication) to minimally validate your identity.
Click the “Account” header section at the top.
Click the “Delete My Account” (or similarly named) button.
Read the warning popup to confirm this is what you want to do. Note that deleting your account (“Erasing” yourself) will remove all ties to your account with minor exceptions (stated below), forfeit existing in-game currency gold (gp), wipe all game statistics, and more. Note that some information may still be retained that are core to the experience of others, such as core disciplinary identifiers to prevent abuse such as ban evasion and shared, public information such as friends/match info. Please note that if you erase yourself and make a new account under the same name, you may experience unintended side effects - please report your bugs to Discord #bugs channel: https://discord.gg/tol
Once erased, please note there is no way for us to restore the removed data. Our systems are not designed to handle reversal.


What is NOT Erased?


Disciplinary Action Retention
If the user was suspended before, this is considered a potentially malicious user (generally issued after a warning is given, unless the reason was significant):

Potentially malicious user mac(s) address(es), IP(s) address(es), device ID(s) and warning/suspension/ban/disciplinary report records (which include game logs and report information) will be retained for security, anti-exploit (such as suspension/ban evasion), proof/disciplinary action justification, and proof of breach of contract (EULA/ToS) in case of relevant, real-life litigation.
Incoming player reports against the player are retained for security and proof/disciplinary action justification in case of relevant, real-life litigation. This is beyond reasons than simply “game” disciplinary action, but also for proof of disciplinary action justifications in case a suspension case ever reached real-life litigation. Private information, such as Mac(s) and IP(s) are NOT stored under player reports. This information may also appear in a private section of our forum (see the same “ERASED” section of the Forum policies below for the exact info).
Receipts
Mentioned above, we will keep transactional information such as receipts in case ever contested (proof of receipt) and for general retention laws/best practices to keep receipts.

E - REQUEST YOUR DATA


You may collect your data at any time via your own profile. Note that report data cannot be directly collected here, if you play Throne of Lies online game. To get report data, Instead, scroll up and review Throne of Lies Game’s “E” (Data Collection) section. The original data comes from the Throne of Lies database. Please further note that not all information may be delivered that would expose third-parties.




Throne of Lies Forum (Imperium42 Forum):


A - WHEN DO WE AGREE TO THE COLLECTION OF INFORMATION?

When you first register at https://forum.imperium42.com , you agreed to our ToS, EULA and privacy policy. We use “Discourse”, an open-source forum and use their standard policies.


Read more about Discourse privacy policies here: https://www.discourse.org/privacy


B - WHAT SPECIFIC DATA IS COLLECTED IS COLLECTED ABOUT ME / PRIVACY SCOPE? WHY?


We collect the default data used by Discourse: Read more about Discourse privacy policies here: https://www.discourse.org/privacy


Aside from this, custom data collection includes:


Discord ID (optional - only input by the customer if they want others to publicly see their Discord name)
IP Address -- detects duplicate sand for overall security/anti-exploit.
There is likely cookies to save your session, covered in Discourse’s own privacy policy when you sign up.

Discourse makes automated decisions about you!

Discourse works on “trust levels” and with IP addresses. If the robot detects you may be a bad person, a duplicate or a BOT, you may be temporarily flagged/blocked until a staff member can review.


OPT-IN/OUT


We use default Discourse operations. According to Discourse’s privacy policy, you may opt out. To pull a small snippet from their page regarding opting out,


You can change your account data at any time by visiting the profile settings page for your account.


Read more about Discourse privacy policies here: https://www.discourse.org/privacy


D - ERASURE


We use default Discourse operations. According to Discourse’s privacy policy, you may erase yourself. To pull a small snippet from their page regarding opting out,


The settings for a particular forum may also allow you to close your account, on the settings page for your account. Closing your account starts a process of erasing or anonymizing CDCK's records of data you provided for your account. Forum administrators can also erase and anonymize accounts.

Depending on the settings for your particular forum, you may also be able to edit, anonymize, or erase your posts. When you edit posts, CDCK will keep all versions of your posts. Forum administrators can view old versions of posts, and optionally make them visible to other forum visitors.

Read more about Discourse privacy policies here: https://www.discourse.org/privacy


Once erased, please note there is no way for us to restore the removed data.


What is NOT Erased?


Throne of Lies Online Game Report Data (at https://forum.imperium42.com)


Incoming player reports against the player are retained for security and proof/disciplinary action justification in case of relevant, real-life litigation. This is beyond reasons than simply “game” disciplinary action, but also for proof of disciplinary action justifications in case a suspension case ever reached real-life litigation. Private information, such as Mac(s) and IP(s) are NOT stored under player reports.

If you were were ever reported or reported someone else, you may appear in a private section of our forum for Imperium42, LLC staff members and/or volunteer community members (such as Guides, Judges and Moderators) to review reports for disciplinary action reasons.
Transparent moderation practices can be found here: http://throneofli.es/moderation
Information is publicly shared with others, including:
Room name = Necessary to reference for the match in question
Accused Info / Reporter Info >>
Account display name = Necessary for speedy references to process fast since 10’s of thousands of reports have come in since launch. Reports may involve a username being extremely racist/offensive, aiding in moderation. Also helps if a user is appealing a disciplinary action.
Account pid = Used to look up account info. Useless if already erased -- no additional information will be found. More about this data is mentioned in the “Throne of Lies” game section. Also helps if a user is appealing a disciplinary action.
Single-use in-game name = In game name - temporary use. One-time. More about this data is mentioned in the “Throne of Lies” game section. Reports may involve an in-game name being extremely racist/offensive, aiding in moderation. Also helps if a user is appealing a disciplinary action.
Is guide? = Used to reference if they were a guide at that time to prevent abuse. More about this data is mentioned in the “Throne of Lies” game section. Also helps if a user is appealing a disciplinary action.
Warning count history = Used to demonstrate past history, often used for justification of disciplinary action severity. Also helps if a user is appealing a disciplinary action. Also helps if a user is appealing a disciplinary action.
Ban count history = Used to demonstrate past history, often used for justification of disciplinary action severity. Also helps if a user is appealing a disciplinary action. Also helps if a user is appealing a disciplinary action.
Incoming report count history = Used to demonstrate past history, often used for justification of disciplinary action severity. Also helps if a user is appealing a disciplinary action.
Outgoing report count history = Used to demonstrate exploitation of the report system history, often used for justification of the likelihood of “real” report information. Also helps if a user is appealing a disciplinary action.
Games played history = Often players will claim to be having their first game when someone is about to be reported. Here, we can tell if they were truly breaking the code of conduct or if it was a mistake. Also helps if a user is appealing a disciplinary action. Also helps if a user is appealing a disciplinary action.
Display Name History = Some players will immediately change their name after to avoid punishment. This helps prevent this -- also, players often use racist names or extremely offensive. This holds proof of that. Also helps if a user is appealing a disciplinary action. Also helps if a user is appealing a disciplinary action.
Links to others reporting the accused = Used to demonstrate past history and proof of that history, often used for justification of disciplinary action severity. Also helps if a user is appealing a disciplinary action. Also helps if a user is appealing a disciplinary action.
Display Name History
Match Info >>
Player connection = Sometimes the player leaves the game while alive, which is against our Code of Conduct.
Start Class = Some classes get an ability to use words through others, potentially blaming them for someone else’s misconduct. This helps aid us in determining who really said what. Also, intentions. Helps find “gamethrowers”.
Start Faction = Some players will “gamethrow” and learning their starting faction
Won = Helps determine motive. If they won, they are less likely to have “gamethrowed”.
In-Game chat logs for the relevant match = We’re a social game -- everything is chat logs. This helps us determine the truth of a report for who said what.

IP addresses for anti-exploit/security may be stored. Check with Discourse to see their privacy policy: https://www.discourse.org/privacy


Also, due to the very nature of a “forum”, posts generally aren’t designed to be deleted, much like Reddit - content posted belongs to the forum operator (Imperium42, LLC). While you may delete your own posts/replies/content, you would have to do this manually as this content would remove vital context from other users. We advise you do not delete your own posts. Please note that some posts cannot be removed due to the nature of Discourse. We use Discourse for our forum -- see how they handle erasure here: https://www.discourse.org/privacy


E - REQUEST MY DATA


You may access your own data at any time in your profile / account settings, self-served.




Throne of Lies Website (Official Site):


A - WHEN DO WE AGREE TO THE COLLECTION OF INFORMATION?

When you load the website, you will be prompted with a disclosure.


B - WHAT SPECIFIC DATA IS COLLECTED IS COLLECTED ABOUT ME / PRIVACY SCOPE? WHY?


We used Google Analytics and Facebook Pixel for marketing/remarketing/retargeting/analytical purposes to attempt to get your attention to purchase our game. After all, we sell video games! See more about Facebook and Google privacy policies:


https://support.google.com/analytics/answer/181881

https://support.google.com/analytics/answer/6004245

https://policies.google.com/privacy

https://www.facebook.com/about/privacy/update


C -OPT-IN/OUT


For Google Analytics, you may use Google’s opt-out extension:


https://support.google.com/analytics/answer/181881


Facebook instructions (We currently don’t use FB as of May 28, 2018, but maybe one day):


https://www.facebook.com/help/568137493302217


For more information about opting out:


https://support.google.com/analytics/answer/6004245

https://policies.google.com/privacy

https://www.facebook.com/about/privacy/update


D - ERASURE


Please contact Google and Facebook for erasure:


https://www.facebook.com

https://www.google.com




Imperium42 Email List (MailChimp)


A - WHEN DO WE AGREE TO THE COLLECTION OF INFORMATION?

When you register in-game, per our privacy policy and terms of service, you will be sent an email asking if you’d like to signup for our email list. If you ignore it, you never hear from us again (unless it’s critical). However, if you double opt-in, we may send occasional emails. Generally once/month, but lately it’s been quarterly.


B - WHAT SPECIFIC DATA IS COLLECTED IS COLLECTED ABOUT ME / PRIVACY SCOPE? WHY?


Email = Can’t have an email list without an email! We use this to send you information such as new update information or what we have been up to and/or alert you for anything critical. We don’t share your email with anyone - just us and MailChimp (your email is stored on MailChimp servers).
Signup Source = For example, did you sign up in-game? At an event? On the website? We use this to determine what service you use for analysis to see what’s working and what’s not. Currently, 100% of everyone’s signup source is “Game”.

C - OPT-IN/OUT


Simply click the “Unsubscribe” button at the bottom of any email to opt-out. We have always used double opt-in, so you have already confirmed your opt-in pre-GDPR and there’s no need to opt-in a second time.


(If you are wondering why you are receiving emails from other companies begging you to opt-in, that may be because they didn’t start with double opt-in and just added you to their list without your knowledge)


D - ERASURE


Please contact MailChimp for erasure: legal@mailchimp.com


E - REQUEST YOUR DATA


Your signup source will always be “Game”, unless we change it. Your email is simply your email we delivered the email to. There is no other data stored - our mailing list is very basic. For more information, email legal@mailchimp.com




Note: There may be further privacy disclosures above the GDPR section in this document -- the GDPR section was specific to GDPR.




FURTHER INQUIRIES


For Imperium42 / Throne of Lies,
Discord (live chat): https://discord.gg/tol - Xblade#4242
Email: legal@imperium42.com
Physical Mailing Address (USA):
Imperium42®
848 N. Rainbow Blvd.
Unit #8058
Las Vegas, NV 89107 - 1103
For Discourse forum: https://www.discourse.org/contact
For Facebook: https://www.facebook.com
For Google: https://www.google.com
For Photon: https://www.photon.info/en/contacting-photon
For GameSparks: https://www.gamesparks.com/contact/
For GameAnalytics:
https://gameanalytics.com/contact
https://gameanalytics.com/gdpr-faq
For Discord: https://support.discordapp.com/hc/en-us
For Twitch: https://help.twitch.tv/customer/portal/emails/new
For MailChimp: legal@mailchimp.com