Privacy Policy
 
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SONY ONLINE ENTERTAINMENT INC.

PRIVACY POLICY

(Revised 4th April 2005)

YOUR USE OF OUR SERVICES AND WEB SITES IS SUBJECT TO YOUR AGREEMENT TO THE TERMS OF THIS PRIVACY POLICY.

Sony Online Entertainment Inc. ("SOE") respects your privacy and is committed to protecting the personal information that you may provide while using our web sites and services. This Privacy Policy (the "Policy") is intended to provide you with notice of the following:

Our participation in and certification by the ESRB Online Privacy Program

This Policy and the certification seal located above confirm that SOE is a valid licensee and participating member in the Entertainment Software Rating Board's Privacy Online Program: ESRB Privacy Online. To protect your privacy to the maximum extent possible, we have voluntarily undertaken this privacy initiative and our web sites have been reviewed and certified by ESRB Privacy Online to meet established online information collection and use practices. As part of this program, we are subject to frequent audits of our sites and other enforcement and accountability mechanisms administered independently by ESRB.

If you have any questions, complaints, or comments regarding this Policy, please contact SOE Customer Service at support@soe.sony.com. For complaints, you can also contact ESRB Privacy Online directly at www.esrb.org or by regular mail at 317 Madison Avenue, New York, NY 10017.

The web sites and services covered by this Policy

We currently operate the following web sites (the "Sites"):

www.station.com (the "Station") store.station.sony.com (the "Store")

In addition, we own many other domain names (e.g. www.everquest.com) that may redirect to the home page of the Station and/or content-specific "subsites" of the Station. Examples of subsites are:

everquest.station.sony.com
eqlive.station.sony.com
starwarsgalaxies.station.sony.com
planetside.station.sony.com

From time to time, we may add new Sites that may not be listed above, but they will provide a link to this Policy and will be governed by its terms.

Our policies concerning children

SOE complies with the Children's Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet.

Children under the age of 13

Because our Sites are not directed to children under the age of 13, SOE does not provide memberships to persons under age 13. If you are under the age of 13, you may not create an account on the Site, you may not sign up for any subscription service or buy anything through the Store, and you are not eligible to enter any of our sweepstakes or promotions. Except as may be required by law, SOE will not knowingly collect, maintain, or disclose any personal information from children under the age of 13.

Kids between the ages of 13 and 18

If you are between the ages of 13 and 18, please let your parent or guardian know about this Policy and get his or her permission before you give us any of your personal identifiable information, before you use any of our message board, instant message or chat features, before you sign up for any subscription game services, and before you buy anything from the Store. 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. If you win a sweepstakes that has a prize, your parent or guardian will have to mail or fax us a signed note at the address or fax number listed in the rules for the specific contest that says it was OK for you to enter, and tells us they will accept the prize for you. Some areas of the Site may have special rules for children under the age of 18. When you are in those areas, you must follow those rules.

Information for Parents/Guardians

SOE encourages parents and guardians to spend time online with their children to become familiar with the types of content available on the Internet, including our online games. Parents and guardians should regularly oversee their children's use of e-mail and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.

If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, SOE will take reasonable steps to remove that information from the SOE database at your request. To request removal of your child's information, please send us an e-mail (to the address below) and be sure to include in your message the same user name, password, and email address that your child submitted. If your child has used your credit card on our web sites without your permission, contact us immediately at accounts@soe.sony.com.

What personal information we collect from you

General

We do not collect any personal information from you, unless you provide it to us voluntarily. If you decide to provide us your personal information (e.g., name, email address, and mailing address), we will only collect the personal information which is needed to fulfill your requests and our legitimate business objectives. If you refuse to divulge your personal information when requested, you will not be able to access certain areas on the Sites (such as chat rooms and message boards).

Memberships and Registration

In order for you to register with the Station, we require you to provide us with an email address, state and country of residence, zip/postal code, birth date and gender; we allow you to elect whether to also provide your real name. Some areas of the Station 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 (in order to play our subscription based games, additional information, such as your real name and billing information, will be required).

You may be asked to choose a user or member name and password. Please do not use your real name or the real name of another person when selecting a user name. Please note that your user name will be available to the Internet's general public while you participate in some services, like chat rooms or message boards, so you should exercise discretion when using these services. Personal information disclosed by you within our chat areas, instant message service, message boards, or during game play can be collected by other users of such services and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our services (e.g. sending your telephone number to another user through the chat service). To the extent that you create a public profile that may be available to others on our sites and services, you are solely responsible for its content and accuracy at all times. To edit, change, or delete such information, follow the instructions on the web site.

Email Newsletters and Friend to Friend Promotions

You must have a membership account in order to receive emails from us. You may be asked for additional personal information when you subscribe. You can opt out of receiving future emailing from us by following the directions contained in the email to "unsubscribe." Also, except in jurisdictions where it may be prohibited by law to do so, some SOE sites and Services may ask you to submit information about other people. For example, we may offer "Send to a Friend" promotions, like electronic postcards on our sites or through our newsletters. In these situations, users are asked to provide the e-mail address and, sometimes, the name of a friend. After the "Send to a Friend" transaction is completed, that information is deleted. You might also submit a person's name and other information if you purchase a gift and want to have it sent directly to the recipient. A record of that transaction will be maintained as allowed and/or required by law.

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 mailing address. In each such case, no new personal information will be collected from you without your consent. This information may be collected by SOE or by third parties such as co-sponsors or vendors for the promotion. SOE's use of any such information will be governed by this Policy. The names of third parties such as co-sponsors (other than vendors hired by SOE to conduct, administer, and execute a promotion on behalf of SOE) 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.

Online Purchases and Technical Support

When you sign up to play one of our fee based games or you make an online purchase from the Store, we will also require that you provide us with the necessary billing information such as your real name, credit card information, street address, etc., so that we may provide the game, service, or product to you (according to the terms of the sale, including for example the end user license agreements and terms of use for our fee-based games). Issues related to customer service, billing questions, technical and computer support, etc. may also require you to provide us with some personal information so that we may resolve the issue properly.

Online Games

When you play any of the games offered and/or served by SOE, or use any of the communication features on the Sites, your IP address (the Internet protocol address from which you access any of the above) may be stored in our records. When any game is updated or "patched," our patch routine may check your computer to see that you have the most recent version of game-specific files; when you communicate within any game or any other communication feature within the Station (e.g. live chat, instant message services and the like), even "privately" to another person, you do so with the understanding that those communications go through our servers, can be monitored by us, you have no expectation of privacy in any of those communications and, accordingly, you expressly consent to monitoring of communications (including technical support and customer service communications) that you send and receive. When you log into one of our online games, your system specifications (such as OS, RAM, video card, monitor, system configuration, etc.) may be reviewed/recorded by us for the purposes of analyzing and optimizing your game experience and in order to provide you with customer service.

Resume Submissions and Business Capacity

SOE allows for the online submission of resumes. Please be advised that information (including personal information) contained in a job applicant's resume or otherwise submitted to SOE in a business capacity is not subject to the terms of this Privacy Policy. The information obtained from your resume will only be used for the purpose of accepting and evaluating your submission for a job and contacting you in connection with that purpose.

What non-personal information we collect from you

General, aggregated, demographic, and non-personal information may be collected by SOE. It will not be linked to any of your personal information, through cookies or other means, without your consent. This type of anonymous, aggregated profiling and session data may include information that you have provided to us through surveys, polls, etc., but will not be tied to any personal information, without your consent. It may also include aggregated anonymous information about site usage and the customer base.

As part of the registration process for some services, you may be asked to provide information that does not personally identify you. For example, you may be asked to provide information concerning your entertainment preferences, purchasing habits, and the like. This information is generally optional but may be included in your account profile and tied to personal information. SOE 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.

In many cases, SOE will automatically collect certain non-personal information about your use of its sites and services. SOE might collect, among other things, information concerning the type of Internet browser or computer operating system you are using, the domain name of your Internet service provider, your "click path" through the SOE site, and the web site or advertisement that was linked to or from the SOE site when you visited. To do this, SOE may use cookies and other technology (see below). Your visits to our web sites, and information provided through these technologies, will be anonymous unless you provide us with personal information or have provided such information in the past. For example, if you've created a membership account, your account information (including name, email address, and billing and shipping information) may be linked to the items you purchased at our online store (i.e., purchase order history).

Information on cookies and related technology

SOE web sites, and some services and advertisements on such sites, may contain "cookies." A cookie is a piece of data that is sent to your browser, which will store the cookie on your computer if your browser is enabled to accept cookies. Clear gifs (also known as "web beacons") assist in the delivery of cookies.

SOE uses cookies, clear gifs, frames, server log analysis and other technology to customize your experience with our sites and services. Personal information collected through the use of these technologies will be handled according to this Policy.

Most internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or "Help" screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the SOE web sites and services may not function properly.

SOE 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 our Web sites may be delivered to you by MaxWorldwide or other third-party advertising companies. These companies may use information about your visits to this and other web sites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please click here http://www.networkadvertising.org/optout_nonppii.asp.

How we use and share the information that we collect from you

Personal information which we collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Policy. For example, if you make an online purchase from The Store, and unless you have given us permission to do otherwise, we will only collect and save the personal information you provided to us, including your billing and delivery information, in order to (1) complete the sale, (2) comply with tax and other applicable statutes, (3) maintain accurate business and financial records (in accordance with accepted standards), and (4) assist with customer service and returns.

When you have provided personal information to us for a particular purpose, we may disclose your information to other companies that we have engaged to assist us in fulfilling your request. This may include, but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, and other third party service providers. We may also disclose any of your personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of SOE.

We may use the information we collect from you for the purpose of providing you with technical support, customer service, and account maintenance. We use the information we collect to learn what you like, tailor your experience accordingly, and to improve web sites and our other products. We send e-mail to our members who want to receive e-mail from us. However, if you don't want to receive e-mail from us, you can "opt out" of receiving it at the time you register as a member on our web sites or each time we request information from you. If you change your mind and wish to stop receiving e-mails from us, you may also choose to opt out by following the steps described in each such e-mail.

Except as described in this policy, we will not give any of your personal information to any third party without your express approval, and the only personal information we will ask you if you want us to share with third parties is your name, your mailing address and e-mail address. If you don't want us to share your name, mailing address and e-mail address, you can tell us that by clicking on "No" in the box at the time you register as a member on the Station or each time we request information from you or at other points. We sometimes share general, demographic, or aggregated (not personal) information with third parties about our user base, but that information does not include any personal information.

You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the Sites, of any personal information contained in the SOE database for such site, if SOE or one of its companies assigns all of its rights and obligations regarding the use of your personal information at the time of a bankruptcy, merger, acquisition, sale of all or substantially all of SOE's or such SOE company's assets to a subsequent owner or operator, or similar event.

Information about Sony Family Initiatives

When you provide us with personal information, you may be given the option of receiving information about other Sony products and/or services. If you choose to receive such information, you may be contacted directly by members of the "Sony Family" as defined below, and they will handle your information in accordance with their respective privacy policies.

If you allow us to do so, we may share information about you with the "Sony Family" which consists of (i) any company in which 25% or more of its outstanding shares are owned by Sony Corporation, directly or indirectly, and any company with "Sony" as part of its trade name. Likewise, the aforementioned Sony companies may provide us information about you in accordance with their respective privacy policies. So, for instance, if you opt in to have your information shared within the Sony Family, we may share basic name and point of contact information (email address, physical address, and/or phone number) with Sony Corporation of America, who may in turn provide personal information about you to other members of the Sony Family in order to facilitate the management of your account, and to notify you of products and services that may be of interest to you; we may also share that information directly with other members of the Sony Family.

Information about Co-Published Games

Certain SOE games, such as Star Wars Galaxies, may be provided to you in conjunction with a third party publisher. During the registration process for such games, you may be notified that such third party wishes access to some of your Personal Information. In such a situation, you will be given an opportunity to decline to share that information before any such information is shared. For example, you may have agreed, when you registered to play Star Wars Galaxies, that your name, address, and email information could be shared with SOE's publishing partner Lucas Arts, a division of LucasFilm Entertainment Company Ltd. ("LucasArts"). As described in the registration process, a third party's (such as LucasArts') use of the shared Personal Information will be governed by its privacy policy and SOE's use of such information shall, of course, be governed by the terms of this Privacy Policy. You may change your preferences concerning the sharing of your information by going to the Edit Registration page.

Information about links and third parties related to our sites and services

This Policy applies only to information collected online by SOE through web sites maintained by SOE and affiliated companies that SOE may own or control. From time to time, we may provide links to third party web sites. This Policy does not apply to third party web sites, whether we provide a link to such sites or not, so we encourage you to review the policies of all such sites carefully, as your rights will be governed by those third party policies and not by SOE's. Additionally, there may be unauthorized third party web sites that may be providing links from their sites to our web sites without our knowledge or control. We are not responsible for the content of any third party web sites, expressly disclaim any statements or assertions made on such web sites, 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

If you change your mind and do not want to receive e-mails from us and/or to have us share your name and e-mail address (or other personal information) with third parties, you may send an e-mail to us at accounts@soe.sony.com. Subject to security and privacy concerns (e.g., regarding your password and credit card number), we will give you the ability to review, correct, delete, and/or update your information. To do so, you may send us an e-mail at accounts@soe.sony.com. You may also contact us via mail at: Attn: SOE Privacy Officer, 8928 Terman Court, San Diego, CA 92121. If you choose to have your personal information removed from our active databases, we will do so within a reasonable time after your request and we will take reasonable steps to ensure that your personal data is not used (except as may be required by law) by SOE after your notification to us.

Other important agreements that govern your use of our sites and services

In addition to this Policy, your rights and obligations concerning our web sites, services, and online games are governed by the applicable web site terms of service, the applicable game's end user license agreement and/or terms of use, and other applicable policies, guidelines, and requirements. When you sign up to use our services, please review each such agreement carefully, as you must agree to be bound by each such agreement before you may use the service.

Information for persons outside the United States

By consenting to this Policy, you confirm that your command and knowledge of English (or in some cases, French, German, or Spanish) is sufficient to understand the terms and conditions set forth herein.

For persons in European Union countries, as used herein, terms such as "personal information" refer to "personal data" as defined by the Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("Directive"). We will not collect any personal data from you unless you provide it voluntarily by providing us with your freely given specific and informed consent. By using SOE websites or services, you agree that we may transfer your personal information outside the European Union in connection with the purposes stated in this Policy. Your personal data may be transferred to the United States (and/or other non-EU jurisdictions, as applicable).

In certain countries other than the United States, some of our online games and the services related thereto, may be provided to you by third party distribution partners. To the extent that a third party distributor is providing services related to your account, you understand and agree that each such distributor will collect and use your personal information in accordance with its own privacy policies (which you will have access to when you register to play). To the extent that SOE collects or retains any of your personal information, its use will continue to be governed by the terms of this Policy. For example, in EU countries, to the extent that Ubi Soft SA and/or its subsidiaries (collectively, "Ubi Soft") are performing services related to your account, we elect Ubi Soft as SOE's representative (as defined in the Directive) in each such country with respect to the online games for which Ubi Soft is the distributor and the related personal data collected for such game. Ubi Soft has agreed to maintain such personal data in accordance with its privacy policy, available on its website.

Our commitment to secure the personal information we have collected

While SOE takes precautions against possible breaches in its web sites and customer databases, no web site or Internet transmission is completely secure. Consequently, SOE cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the SOE sites and services is at your own risk. SOE 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.

Whenever you give SOE sensitive or confidential information (for example, credit card numbers for purchases), SOE will take commercially reasonable steps to protect the information by establishing a secure connection with your web browser. SOE employs a security technology known as a secure-socket-layer ("SSL") to protect the transmission of payment information to the site. Unless otherwise specified herein or on the site where you make a purchase, credit card numbers are used only for payment processing and are not retained for marketing purposes.

Notice of changes to the Policy

SOE reserves the right to change this Policy at any time by notifying registered users via e-mail of the existence of a new Policy and/or posting the new Policy on the SOE sites. All changes to the Policy will be effective when posted, and your continued use of any SOE site or service after the posting will constitute your acceptance of, and agreement to be bound by, those changes.

Last Updated: 4th April 2005

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