Lucasfilm Privacy Policy
Last updated: July 16, 2012
Lucasfilm values your privacy and we want to ensure your experience with Lucasfilm Ltd. and its affiliates, subsidiaries, and related corporate entities (collectively, "Lucasfilm," "we," or "us") and our websites, mobile applications, and games are as satisfying and safe as possible. We have established this Privacy Policy (this "Policy") to explain how we collect, use and share information. By accepting this Privacy Policy, you expressly consent to the information handling practices described in this Policy.
TRUSTe Program Compliance
Lucasfilm has been awarded TRUSTe's Web Privacy Seal signifying that this privacy policy and the practices described in this Policy have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program covers information collected through all websites that this policy appears on. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@lucasfilm.com. If you are not satisfied with our response you can contact TRUSTe here.
Quick Reference:
1. Information We Collect
2. How We Use Information
3. When We Disclose Personal Information
4. Third Party Advertising Technologies
5. Children Under 13
6. Your Choices
7. Security
8. Data Integrity and Data Retention
9. Access to Personal Information
10. Third Party Login Functionality
11. Third Party Services and Links
12. International Users & U.S.-EU Safe Harbor
13. California Privacy Rights
14. Changes and Updates to This Policy
15. Contacting Us
1. Information We Collect
In describing our collection, use, and sharing of information in this Policy, we refer to our collection and use of "Personal Information." "Personal Information," as used in this Policy, is personally identifiable information, which is information that directly identifies an individual, such as first and last name, mailing address, email address or other online contact information, or telephone number. We collect Personal Information, as well as non-personally identifiable information on Lucasfilm websites, mobile applications, and games.
We collect Personal Information in two ways. First, we collect information you provide to us in optional, voluntary submissions, such as in registration forms, user profiles, promotional signups, sweepstakes/contest entries, requests for customer service, and resume submissions. Second, some Personal Information may be collected automatically. This is described below in "Passive Data Collection."
We may also obtain information, including Personal Information, from third party sources. If we directly combine information from third parties with Personal Information that we have collected, we will treat the combined information as Personal Information and handle it in accordance with this Policy. In addition, please note that we may solicit third parties to collect Personal Information on our behalf and in such cases we instruct those third parties to comply with this Policy and all applicable data protection laws.
Please be aware that we are prohibited from conditioning a child's participation in any activity on that child disclosing more personal information than is reasonably necessary to participate in that activity. You are under no obligation to provide, and can decline to provide, any requested information at any time. However if you decline to provide personal information that is reasonably necessary to participate in certain activities, you may not be able to participate in those activities on certain websites.
Passive Data Collection
We may receive passively-collected information through a variety of methods including but not limited to:
Cookies and Web Beacons. We may use a variety of methods, including "cookies" and "Web beacons," to collect information. A cookie is a small data file that is transferred to an Internet user's browser by a web server. Cookies are designed to store basic information, such as a user's preferences. A Web beacon (sometimes referred to as a "clear GIF") is a small string of code placed in a web page, email message or other media format in order to gather statistical usage information.
The information that we collect with cookies, Web beacons, and other passive methods may include your IP address, information about how you interact with advertisements and other content, browser type, system type, device type, the content and pages that you access, the date and time you view pages, and the page from which you navigated.
Click-through URLs. In some of our email messages, we may use a "click-through URL" linked to content on a website. When you click one of these URLs, you pass through a separate web server before arriving at the destination page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Location-Based Services. We may collect, use, and share (with Lucasfilm partners, service providers and licensees) precise location data, including the real-time location of your mobile or fixed location device.
Analytics Tools. We use analytics tools and other third party technologies to collect non-personal information in the form of various usage and user metrics when you use our online products and services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, game use metrics and statistics, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.
The third party analytics companies who collect information on our websites, mobile products and other online products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.
In addition to our use of technologies as described here, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of Lucasfilm products and services and to otherwise collect and use data about your use of Lucasfilm products and services. For more information about this practice, please see the "Third Party Advertising Technologies" section below.
2. How We Use Information
Generally, we use Personal Information to establish and enhance our relationship with our users through four main channels: (1) Communication; (2) Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some specific examples of how we use the Personal Information and other information we collect.
Communication and Responding to Requests. We use user information, including Personal Information to provide users with customer support, process transactions, respond to users' requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to Lucasfilm products and services, and to products and services of our partners and licensees.
Optimization. We use user information, including Personal Information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our sites and services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
Advertising. We use user information, including Personal Information, behavioral metrics, geo-location data, demographic data and marketing preferences to personalize and display advertisements and other content for you.
Sharing Features. We use user information, including Personal Information and any other information you submit directly or through passive means to provide you with various ways to connect and share content (e.g., web content, media, games, special offers, services and other products) with third parties. For example, we may provide you with the opportunity to email a link to certain content to another person. To use this feature, we may require you to provide certain Personal Information including your email address and the email address of each person to whom you send the link.
We also may allow you to share links to content with users of various third party services (e.g., social networking, search and sharing services). When sharing links using one of these third party services, if you are not already logged in to the third party service, you will need to supply login credentials for it. If you are not a registered user of the third party service, you will need to sign up for it. You are supplying the registration information or login credentials for the third party service directly to that third party, and not to us. By using any of these third party services to share links to content, you permit us to access, use and disclose any information relating to your account on each such third party service (such as your user name and profile information) that is available to us through the third party service, including through its application programming interface (API) pursuant to this Policy.
3. When We Disclose Personal Information
We do not share Personal Information with third parties except in the limited circumstances described in this Policy.
Subscription Services. We may provide you with the option to sign up for third party subscription services, including mailing lists, account registrations and user profiles. In such events, we will seek to obtain your consent at the place where the information is collected, or notify you that third party information collection practices may apply. Each of these promotional partners may have their own privacy policies. We do not control and are not responsible for these other parties, their privacy policies or their use or treatment of your Personal Information or other information. We and our affiliates make no representation regarding how any third parties use, manage, store, treat or maintain your Personal Information or other information and you should therefore carefully review all such third parties' privacy policies. If you consent to receiving communications from any of these third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.
Service Providers. We may provide Personal Information to third parties for their use in performing internal business functions (e.g., payment processing, customer service, maintenance, security, data analysis, email transmission, beta testing, or data hosting) on our behalf. Additionally, some third party service providers may collect information, including Personal Information, on our behalf. Whenever possible, we require such third-parties to only collect and use Personal Information in accordance with this Policy, to maintain the confidentiality, security, and integrity of such Personal Information, and for no purpose other than providing us with our requested services.
Partners. When you visit or use a part of any website, mobile application, game or other consumer product that is co-branded or that is a part of a joint promotion involving Lucasfilm and one or more third parties (each a "Co-Branded Party"), you are providing and consenting to provide and are transmitting your Personal Information and other information provided to, or collected, or obtained by Lucasfilm and any Co-Branded Parties involved, to Lucasfilm and each of the Co-Branded Parties without any other notice or further consent. Please note that we do not control any Co-Branded Parties' use or treatment of information you provide to them and you should consult each of their privacy policies or any separate Co-Branded privacy policy posted on or linked from the Co-Branded site to determine your rights with respect to their use and treatment of your information. You will need to communicate with us and each Co-Branded Party directly, as applicable, if you decide you no longer wish to receive communications or if you wish to change any information you have supplied.
Legal Requirements. We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena, warrant, or other judicial or administrative order or otherwise required by law. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms of Use, or our other agreements; take precautions against liability; protect our rights, property, or safety, or those of a partner, any individual or the general public; maintain and protect the security and integrity of our services or infrastructure; protect ourselves and our services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government regulatory agencies.
Change of Ownership. Information about our users, including Personal Information, may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. In the event of such a transaction in which your Personal Information would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of Personal Information on our website and, if we have your email address, we will send notice of the transfer of Personal Information to that email address.
Interactive Features. If you use a forum, blog, bulletin board, chat room, user commenting features, or other interactive or social features that may be offered through any of our products or services, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction. To request removal of your personal information from our blog or community forum, contact us at the information provided at the end of this Policy. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
4. Third Party Advertising Technologies
In addition to using cookies and related technologies as described above, we also may permit certain third party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on our services (e.g., to allow them to tailor ads on third party services). These companies may deliver ads that might also place cookies and otherwise track user behavior. These companies may use information about user behavior in order to provide customized advertisements across various services and products. In the course of providing these services, products or placing advertisements, these third party companies may place or recognize a unique cookie on your computer, and may record information to these cookies based upon your activities on any of our websites and on third party websites. Each of these companies uses this cookie information according to their own privacy and security policies. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by going to http://preferences.truste.com. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
5. Children Under 13
We do not knowingly seek or collect Personal Information from users under the age of 13. Users under 13 years of age may set up a Lucasfilm account without submitting any Personal Information. In addition, under certain circumstances for certain products, parents may enable additional functionality (e.g., e-commerce, social, media viewing, gaming) if they choose to link their parental account to the under 13 account. If we determine we have inadvertently gathered Personal Information from a user under the age of 13, we will promptly delete any and all such Personal Information from our records.
6. Your Choices
Submitting Personal Information. If you do not want to submit Personal Information that is necessary to provide or use a service or to fulfill your request, you will not be able to access and/or participate in certain Lucasfilm products and services. For example, you will not be able to register for an account with us or participate in certain contests or promotions, or access and/or use certain Lucasfilm product features or online services. In addition, your refusal to submit Personal Information may limit our ability to respond to your customer support inquiry in a timely fashion.
Editing Personal Information. You may, at any time, update, correct, or delete certain Personal Information that you have provided to us by updating your preferences on the Account Settings page or by contacting us at the mailing or email address provided at the end of this Policy.
Marketing Choices. If you want to remove yourself from individual communications, including marketing promotions, advertisements, updates and email newsletters, simply click the unsubscribe link in the communication or access your Account Settings page when logged in. You also acknowledge and agree that there may be instances where we may elect to notify you about administrative notices regarding your account with us, such as to inform you about changes to our terms, conditions, and policies, that your account may be expiring, or to provide you with other relevant administrative information about your account. Because this information is important to your interaction with us, you may not opt out of receiving these communications.
Account Deletion. If you submit Personal Information, you may delete your account with us at any time. If you delete your account, your Personal Information and any and all other account related information including but not limited to user profile data, purchasing history, game play data and any other data, credits, or content specifically associated with your account are also permanently deleted. Deletion of your data may take up to 30 days from accessible systems and up to 90 days from backup systems. If you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
7. Security
We take reasonable measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all Personal Information that we collect. Our efforts include procedures designed to avoid unauthorized access, alteration, misuse or disclosure of Personal Information.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Lucasfilm products and services covered by this Policy and providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage.
8. Data Integrity and Data Retention
We collect and use Personal Information in accordance with this Policy and only for the purposes stated in this Policy and/or at the time we request such Personal Information from our users, or for such purposes to which a user may otherwise consent. We do not use or share our users' Personal Information in a way that is incompatible with the purposes for which such Personal Information was requested and authorized for use by us. We retain Personal Information for no longer than is commercially useful to carry out our business purposes, or as we believe may be legally required. When Personal Information is deleted or updated by you, it may take up to 30 days from accessible systems, and up to 90 days from backup systems, for us to delete such Personal Information.
9. Access to Personal Information
You may view, correct, or delete the Personal Information Lucasfilm stores about you. Most of your Personal Information may be accessed and corrected by simply logging into your account and accessing your profile. If you wish to obtain a report of the Personal Information Lucasfilm has about you, please send us a written request at the address in the "Contact Us" section of this Policy.
10. Third Party Login Functionality
We may permit users with accounts on certain third party services including but not limited to gaming, social networking, search, sharing, and other services delivered by third-parties, to bypass the standard registration process. If you connect through an authorized third party service, you will be able to use your third party login information to log in to your Lucasfilm account or access Lucasfilm content and products. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third party services that may be triggered by using these third party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access any Lucasfilm content or products.
By using any third party services to log in to your Lucasfilm account or access Lucasfilm content and products, you permit us to access, store and use all information related to your third party account that may be accessible to us through the third party service, including through its application programming interface (API), pursuant to this Policy.
11. Third Party Services and Links
Lucasfilm's content, including games, products, services, newsletters and communications that we send to our users, may contain links to content provided by third-parties. For example, our communications may contain links to third party merchants from whom you may purchase products. To purchase products from these third party merchants, you may be required to provide Personal Information, including your credit card or other payment information.
In connection with some of our products and services we may use or offer services from third parties such as, location-based services. In such instances, we and/or our partners and/or licensees may collect, use, and share precise location data, including the real-time geographic location of your mobile phone or device to provide and improve location-based products and services including but not limited to delivering to you targeted advertising. Third party websites and services are not associated with or authorized by us, unless otherwise specifically indicated by us in this Policy or in communications that we send. We are not responsible for any content appearing on third party websites or for third-parties' privacy or security practices regarding any information, including Personal Information gathered at those third party websites or services. Any Personal Information or other information you provide on third party sites or services, including your contact details and/or geographic location with application providers when you opt in to their location services, and any Personal Information or other information collected by third parties through such third party sites or services, is provided directly to that third party and is subject to its policies governing privacy and security. We encourage you to learn about third parties' privacy and security policies before providing them with Personal Information or other information.
12. International Users & U.S.-EU Safe Harbor
Lucasfilm products and services are hosted in the United States. If you use Lucasfilm products and services from the European Union, or any other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data outside of those jurisdictions to the United States. The United States does not have the same data protection laws as the European Union and other regions. By providing Personal Information under this Policy, you consent to the use of your Personal Information in accordance with this Policy and the transfer of your Personal Information to the United States.
Lucasfilm complies with the U.S.-E.U. Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries. Lucasfilm has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Lucasfilm's certification, please visit http://www.export.gov/safeharbor.
13. California Privacy Rights
In addition to the rights set forth in this Privacy Policy, California Civil Code Section 1798.83 permits California residents who are individual consumers or users of Lucasfilm Ltd. Products or services to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via mail or email at the address identified in the "Contacting Us" section.
14. Changes and Updates to This Policy
We may update this Policy from time to time. If we do, we will update the "effective date" at the top of the Policy. If we make material changes to how we use Personal Information, we will attempt to notify you of the change and to give you the opportunity to exercise choice as to how your Personal Information is used. We will post the updated Policy on the affected sites, products and services, and if we have your email address, we will send notice of the update to that email address.
We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of any content, games, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.
15. Contacting Us
If you have questions about this Policy, you may contact us at privacy@lucasfilm.com.
You may also write to us at:
Lucasfilm Ltd.
Privacy Officer
Business Affairs
P.O. Box 29901
San Francisco, CA 94129-0901
privacy@lucasfilm.com
If you do not receive acknowledgement of your inquiry or your inquiry has not been addressed satisfactorily, you should then contact the TRUSTe Watchdog Dispute Resolution Program at http://watchdog.truste.com/pvr.php?page=complaint.
TRUSTe will serve as a liaison with us to resolve your concerns relating to this Policy or other privacy issues.
© 2012