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Privacy Policy

SWG: VISION OF HOPE PRIVACY POLICY
(Last Updated: August 08, 2017)

YOUR USE OF OUR WEBSITE, SUBSITES AND SERVICES IS SUBJECT TO YOUR AGREEMENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.

SWG: Vision of Hope (“VoH” or “we” or “our”) respects your privacy and is committed to protecting the Personal Information (as defined below) that you may provide us while using the Services (as defined below). Your use of the Services is subject to your agreement to the terms and conditions of this Privacy Policy (the “Privacy Policy ”) and our Terms of Service (the “VoH: Terms of Service”).
This Privacy Policy sets out the basis on which we process the Personal Information and Other Information (as defined below) that we collect from or about you and is intended to notify you of our privacy practices concerning the following topics:

THE WEBSITE, SUBSITES, AND SERVICES COVERED BY THIS POLICY.
The Privacy Policy applies to the websites, software applications or programs, games, HTML email messages, information we collect through social media pages, and other properties and services that are operated by us and that link to this Privacy Policy (collectively, the “Services”). Please note that when visiting SWG: Vision of Hope’ pages hosted on social media websites (e.g., Facebook, Twitter, YouTube, Google+) or any other third-party websites, you should refer to their privacy policies and terms of use, for more information about how they handle your information.

We currently operate the following web sites (the "Sites"):
www.swghope.com

In addition, we utilize many other subsites that may redirect to the homepage of www.swghope.com and/or content-specific "subsites". Examples of subsites are:

www.bugs.swghope.com
www.chat.swghope.com
www.forums.swghope.com
www.support.swghope.com
www.wiki.swghope.com
From time to time, we may add new web sites that may or may not be listed above, but they will provide a link to this policy, and will be governed by these terms and conditions.

OUR PARTICIPATION IN THE ONLINE PRIVACY PROGRAMS.

This Privacy Policy confirms that SWG: Vision of Hope is enforcing the ESRB Privacy Certified Program. We are in the process of voluntarily, undertaking, this privacy initiative and the Services are in the process of being reviewed by the ESRB Privacy Certified Program to meet established online information collection and use practices. As part of this program, we will be subject to frequent audits of the Services as well as other enforcement and accountability mechanisms, which will be administered, independently by the ESRB.

If you have any questions, complaints, or comments regarding this Privacy Policy, please contact Privacy Support Services at privacy@swghope.com. For complaints, you can also contact the ESRB Privacy Certified Program directly at privacy@esrb.org or by mail at Attn: Privacy Certified Program, 420 Lexington Avenue, Suite 2024, New York, NY 10170.

PERSONAL INFORMATION WE COLLECT FROM AND ABOUT YOU

A. General
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including for example, your name, e-mail address, postal address, phone number, and payment card information. We do not collect any Personal Information from you unless you provide it to us voluntarily (e.g., through interaction or registration with the Services). We may combine the Personal Information we receive from you with information we receive about you from other sources, such as our affiliates, public databases, joint marketing partners, social media platforms, from people with whom you are friends or otherwise connected on social media platforms, and from other third parties. For example, if you elect to connect your social media account to your Services account, certain Personal Information from your social media account may be shared with us, such as your name, email address, photo, and location. This Personal Information may be combined with other information that is part of your profile or your friends’ profiles.

B. Memberships and Registration
Some areas of the Services, may allow you to visit as a guest and remain anonymous, but you may not be able to access all the content and features of those areas without registering (e.g., in order to play our subscription-based games, information such as your real name and billing information is required). Important information regarding account registration procedures and the security of your account is set out in the Terms of Service.

C. Sweepstakes, Contests, and Promotions
To participate in some of our sweepstakes, contests, surveys, and other promotions, you may be asked to provide additional Personal Information such as your physical mailing address. This information may be collected by SWG: Vision of Hope and/or by third parties such as co-sponsors or vendors for the promotion. Potential winners will be required to provide additional Personal Information for the purpose of verifying eligibility, awarding prizes, and for tax purposes. The names of third parties such as co-sponsors (other than vendors hired by SWG: Vision of Hope to conduct, administer, and execute a promotion on behalf of SWG: Vision of Hope) will be disclosed to you when you are asked to sign up for the promotion. You should review such third parties’ privacy policies to see how they may use any information that they collect.

D. Technical Support
When you sign up to play one of our games, we will require that you provide us with the necessary information, such as your username, email address, etc., so that we may provide the content, game, or service. In order to resolve issues related to customer service, billing questions, technical, and computer support, etc., we may also require you to provide us with some Personal Information so that we may resolve such issues properly.

E. Hosting of Third-Party Services
Certain Services may be provided to you in conjunction with a third party. During the registration process for any such Service, you may be notified that such third party wishes access to some of your Personal Information and you will be given an opportunity to decline to share that information with that third party. If you decline, you may not be able to use the relevant Services. A third party’s use of the shared Personal Information will be governed by the third party’s own privacy policy, and SWG: Vision of Hope’ use of such information will be governed by this Privacy Policy.

F. Consent to Store & Monitor
Please note that, when running, some of our games may monitor your computer’s random access memory (“RAM”), media access control (“MAC”) address, configuration files and system files, etc., for unauthorized third party programs running concurrently with your game which, in SWG: Vision of Hope’ sole determination: (i) enable or facilitate cheating of any type; (ii) allow users to modify or hack the applicable SWG: Vision of Hope game interface, environment, and/or experience in any way not expressly authorized by SWG: Vision of Hope; or (iii) intercept, “mine” or otherwise collect information from or through the applicable SWG: Vision of Hope game (each, an “Unauthorized Third Party Program”). In the event that a SWG: Vision of Hope game detects an Unauthorized Third Party Program, (a) the SWG: Vision of Hope game may communicate information back to SWG: Vision of Hope, including without limitation, your SWG: Vision of Hope account username, details about the Unauthorized Third Party Program detected and the activities or functions performed thereby, and/or details about your computer, and/or (b) SWG: Vision of Hope may exercise any or all of its rights and remedies, including, without limitation, its rights and remedies under the Terms of Service and/or the SWG: Vision of Hope end user license agreement without prior notice to the user linked to such Unauthorized Third Party Program.

When you communicate with another game player or with us within the Services (e.g., through live chat, instant message services, message boards, and the like), even when you believe you are doing so “privately” with another person, you do so with the understanding that those communications go through our servers, and you expressly agree to waive any rights of confidentiality that you may have in and to such communications, you agree you have no expectation of privacy in such communications and, accordingly, where and to the extent permitted by applicable law, you expressly consent to our (or our agents’) monitoring of the communications that you send and receive through the Services (including, without limitation, technical support and customer service communications). You also acknowledge that any and all character data that is stored and is resident on our servers may be monitored by us or our agents (to the extent permitted by applicable law).

G. Business Capacity and Resume Submissions
SWG: Vision of Hope allows for the online submission of resumes or job applications. Please be advised that information (including Personal Information) contained a job applicant’s resume, or otherwise submitted to SWG: Vision of Hope in a business capacity is not subject to the terms of any other section of this Privacy Policy. The information obtained in these instances will only be used for the purpose for which it was collected (i.e., accepting and evaluating your submission for a job, contacting you, etc.).

H. Collection of Personal Information about Other Individuals
SWG: Vision of Hope may collect from you Personal Information relating to certain third parties, such as your family members and friends. Except as provided by applicable laws and/or as described in this Privacy Policy, you will not give any such Personal Information to us or our service providers without the relevant individual’s consent.


OTHER INFORMATION WE COLLECT FROM YOU
We and our service providers may collect information that does not reveal your specific identity or does not directly relate to an individual (“Other Information”). Because Other Information does not personally identify you, we may use and disclose it for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for all the purposes for which we use and disclose Personal Information.

We may combine the Other Information we collect from and about you with Personal Information. If we do, we will treat the combined information as Personal Information for as long as it is combined.

We and our service providers may collect Other Information in a variety of ways, including:

A. Browser and Device Information
Certain information is collected by most browsers or automatically through your device or with session information, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.

In addition, when you play our games or use the communication features available through the Services, we may collect your IP address. When any SWG: Vision of Hope game is updated or “patched,” our patch routine may check your computer to see that you have the most recent version of SWG: Vision of Hope game-specific files. When you log into one of the SWG: Vision of Hope’ games, we may collect your system specifications (such as RAM, video card, monitor, system configuration, crash data, etc.) for the purposes of analyzing and optimizing your SWG: Vision of Hope game experience and in order to provide you with customer service.

B. Through your use of our apps
When you download and use one of our applications, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.

C. Information collected through cookies, pixel tags, and other technology
We and our service providers may use cookies, pixel tags, and other tracking technology when you visit or use the Services. Please see our Cookie Policy for details on our use of these technologies and instructions on how you may manage them.

We assign a unique identifier to every user of our websites and launchpad (i.e., our game launchers). The unique identifier allows us to recognize the same user when he or she uses our various Services, including through different devices, and to track his or her use of the Services, thereby giving us a full picture of the user’s activity across our Services. If we have collected your Personal Information, or if we collect your Personal Information in the future, we will combine it with the information we have collected through our use of the unique identifier. We use the information collected for analytics purposes and to serve targeted SWG: Vision of Hope offers and content to you when you are on the Services.

We and our service providers may also use cookies and other technologies to automatically collect the website or advertisement from which you reached the Services, to track responses to our online advertisements, and to collect information across your use of different SWG: Vision of Hope websites. We do not track your behavior on third-party websites or other online services.

SWG: Vision of Hope does not control cookies in third party ads and visitors are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. The ads appearing on the Services may be delivered to you by third-party advertising companies. These companies may use information about your visits to the Services and other sites or online services in order to provide advertisements on the Services and other sites about goods and services that may be of interest to you.

We use Google Analytics, which uses cookies and similar technologies to analyze how users use the Services, compile statistical reports on Services activity, and provide other services related to the Services. Google Analytics may also collect information about our users’ use of other websites. For more information about Google Analytics, or to opt out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.

D. Physical location
We may collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you do, we may not be able to provide you with the applicable personalized services and content.

E. Demographic information and other information provided by you
In connection with some Services, or through surveys or polls, we may ask you to provide information that does not personally identify you. For example, we may ask you to provide information concerning your entertainment preferences, purchasing habits, and the like. This information is generally optional. SWG: Vision of Hope requests this information to understand you better and to also bring to your attention new services, programs, or offers that may be of interest to you. Unless combined with Personal Information, this information does not personally identify you.


HOW WE USE AND SHARE THE INFORMATION THAT WE COLLECT FROM YOU

A. How we use information that we collect from you
In addition to the uses described in the sections above, we may use the Personal Information we collect from and about you to enable us:

To provide you with technical support, customer service, and account maintenance;
To learn what you like and tailor your experience accordingly;
To improve and develop the Services and our other products and services;
To provide services or products you request;
To allow you to participate in or use our communication features;
To allow you to download and/or play one of our games;
To allow you to benefit from any other promotions or offers, such as sweepstakes and contests;
To manage your SWG: Vision of Hope account and fulfill your orders and respond to your requests;
To inform you of any changes made to the Services or send other administrative information to you;
To inform you of products, services, promotions, and offers which you may find interesting, including by serving advertisements to you when you are on third-party sites, services, and social media platforms; and
For our internal business purposes, such as data analysis, audits, fraud monitoring and prevention, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

B. Information disclosed to third parties
We may disclose your Personal Information to other companies that we have engaged to provide services to us and whom we subject to confidentiality requirements. This may include, but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, ad serving services, and other third party service providers.

We may disclose your Personal Information to identify you to anyone to whom you send messages through the Services.

You may disclose your Personal Information on message boards, chat, profile pages, and other services to which you are able to post information and materials. Any information you post or disclose through these services will become public information and may be available to other users of the Services and to the general public. Please be careful when deciding to disclose your Personal Information, or any other information, on or through the Services.

We may use or disclose your Personal Information if we believe such disclosure is necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.


INFORMATION ABOUT LINKS
We may provide links to third party websites. This Privacy Policy does not apply to any such websites, and we are not responsible for them, so we encourage you to review the policies of all such sites carefully. Additionally, there may be unauthorized third party websites that may be providing links from their sites to the Services without our knowledge or control. We are not responsible for the content of any third party websites, expressly disclaim any statements or assertions made on such websites, and deny all liability associated with your use of, and the content on, such other sites or advertisements contained therein.


HOW YOU MAY ACCESS, CHANGE, OR DELETE THE INFORMATION YOU HAVE PROVIDED TO US
Subject to security and privacy concerns (e.g., regarding your username, password and email address), your SWG: Vision of Hope account will give you the ability to access, change, delete, and/or update the Personal Information you have provided, and adjust your communications preferences. If you choose to have your Personal Information removed from our active databases, we will try to do so within a reasonable time after your request and we will take reasonable steps to ensure that your Personal Information is not used (except as may be required by law) by SWG: Vision of Hope after your notification to us.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.


OUR POLICIES CONCERNING CHILDREN
SWG: Vision of Hope actively complies with the Children's Online Privacy Protection Act (COPPA) and all other applicable laws and regulations, concerning children and the internet.

Children under the age of 13
Because our website, subsites, or services are directed to all ages of children, including children, under the age of thirteen (13), SWG: Vision of Hope does provide memberships to persons, under the age of thirteen (13), you may create an accounton the website, only with explicit permission via COPPA Parental Authorization. Once registered, your account will be flagged as a COPPA Account and will not be acitvated until such authorization from a parent or legal guardian is received by CSR Staff, upon which time, the account can be activated.

Children between the ages of 13 and 18
If you are between the ages of 13 and 18, please let your parent or legal guardian know about this policy, and retrieve his or her authorization before you give us any of your personal information, before you use any of our website, subsites, or services. Don't post your real name on a web site or message board, and never tell anyone online, anything private, about yourself, or your family, including your phone number and address. Use screen names at all times.

Information for Parents & Legal Guardians
SWG: Vision of Hope encourages parents and legal guardians to spend time online with their children, to become familiar with the types of content available on the internet, include our online game. Parents and Legal Guardians should regularly oversee their children's use of email and other online communications and transactional features. Control tools are available from online services and software manufacturers, which can help provide a safe online environment for children.

If you are a parent or legal guardian who has discovered that your child has submitted his or her personal information without your permission or consent, SWG: Vision of Hope will take reasonable steps to remove that information from the SWG: Vision of Hope Database, at your request. To request removal of your child's information, please send us an email (to the address below) and be sure to include your message: the same username, password, email address that your child submitted, you can contact us immediately at accounts@swghope.com


INFORMATION FOR PERSONS OUTSIDE THE UNITED STATES
The Services are operated and controlled by us from the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside your country of residence, including the United States, which may have different data protection rules than your country.


OUR COMMITMENT TO SECURE THE PERSONAL INFORMATION WE HAVE COLLECTED
In order to provide you with added protection, SWG: Vision of Hope employs a security technology known as a secure-socket-layer (“SSL”) to protect the transmission of payment information to the Services. Unless otherwise specified herein or on the Services where you make a purchase.

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no website data transmission or storage system can be guaranteed to be completely secure. SWG: Vision of Hope urges you to take steps to keep your Personal Information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your user account, and closing your web browser when you are finished using the Services. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.


NOTICE OF CHANGES TO THIS PRIVACY POLICY
SWG: Vision of Hope reserves the right to modify this Privacy Policy from time to time and to provide you with notice of such modifications by any reasonable means, including, without limitation, by making available the revised version of the Privacy Policy through the Services. You can determine when the policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. Your continued use of the Services following our making available any revised version of this Privacy Policy will mean that you accept that revised version; however, any material change to this Privacy Policy will not apply retroactively to any claim or dispute between you and us in connection with this Privacy Policy that arose prior to the “Last Updated” date applicable to that version of this Privacy Policy in which we included such material change. If we make any material changes in the way we collect, use, or share your Personal Information, we will notify you by prominently posting notice of the changes on SWG: Vision of Hope’ home page. If you do not agree to any changes made to this Privacy Policy, you may not access or use the Services.