This Privacy Policy applies to your use of the website https://jeffluntgames.com, as well as any video games therein (collectively, the “Site,” as further defined below) that are created by Jeff Lunt Games LLC (hereinafter “we,” “us,” etc.). This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Site. This policy describes the types of information we may collect from you or that you may provide when you visit the Site, and our practices for collecting, using, maintaining, protecting, and disclosing that information.
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Definitions. The following definitions shall apply to all capitalized uses of the terms defined, and to any other use where the definitions provided would reasonably apply.
1.1. Cookies. Small data files placed on your computer or other device by the Site when you visit certain parts of the Site and/or when you use certain features of the Site. (See Section 5.2 below.)
1.2. Data. All information that a User submits to us via the Site. This definition includes, where applicable, the definition of "Data" provided in any applicable Data Protection Law.
1.3. Data Protection Law. Any applicable law relating to the collection, processing, retention, or distribution of personal Data, including but not limited to state laws, federal laws of the United States, and the EU General Data Protection Regulation (GDPR) if a court of competent jurisdiction finds that the laws of that jurisdiction apply to any Data submitted subject to this Privacy Policy.
1.4. Privacy Policy. The very document that you are reading, which may be updated from time to time
1.5. Site. The website https://jeffluntgames.com, as well as any video games found thereon, as well as any games created or published by us including that are linked on that website. For the sake of clarification, even though we are using the term “Site,” we are using that as shorthand to include not only the website, but also associated video games.
1.6. User. Any person who accesses the Site, either on that person’s own behalf or on behalf of another person or entity, and is not an employee or other agent of ours.
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Scope. This Privacy Policy applies only to our actions and those of Users with respect to the Site. Except for our games that are linked on the Site, this Privacy Policy does not extend to any other websites that can be accessed from the Site, including, inter alia, any links that we may provide to social media websites, regulatory websites, or the websites of other service providers. For purposes of applicable Data Protection Laws which use this term, we are the “data controller.” This means that we determine the purposes for which, and the manner in which, your Data are processed.
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Data Collected. We may collect the following Data, which may include personal Data, from Users or third parties:
3.1. Information about your browser.
3.2. Your IP address.
3.3. An anonymous player ID that one or more games within the Site automatically assigns to you, but which will not be visible to you.
3.4. Device hardware specs.
3.5. Device operating system.
3.6. Any Data that a User voluntarily provide to us.
3.7. Additionally, for certain premium features, we require a valid e-mail address and a method of payment (e.g. credit card information).
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Data Collection. We may collect Data in the following ways:
4.1. By Users. Data may be given to us by Users themselves; for example:
4.1.1. When a User contacts us through e-mail or any other means.
4.1.2. When a User elects to receive communications from us.
4.1.3. When a User uses any other service provided by us.
4.1.4. Additionally, some of our video games on the Site may involve role-playing and live-chat options. A User may disclose Data in the course of playing a game. PLEASE DO NOT DISCLOSE ANY REAL-LIFE PERSONAL INFORMATION IN CHAT WHILE PLAYING A GAME. Role-playing is encouraged, but we do not need or want any personally-identifiable information about you.
4.2. Third Parties. Data may be received from other sources including third parties and publicly available sources, such as marketing information service providers.
4.3. Automatically. Data may be collected automatically from Users of the Site during their use of the Site. (See Section 5 below.)
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Data Collected Automatically.
5.1. Data Examples. To the extent that Users voluntarily access the Site, we may collect certain User Data automatically. For example:
5.1.1. Visitor Data. We automatically collect some information about User visits to the Site. This information helps us to make improvements to the Site, and may include IP addresses, the dates and times at which Users access the Site, the frequency with which Users visit the Site, and the way in which Users use and interact with content found on the Site.
5.1.2. Cookies. We may collect User Data automatically via Cookies, in line with the cookie settings on the User's browser. The Site may store and retrieve certain Cookies on User devices used to access the Site. Games on the Site may use Cookies to allow a User to return to a persistent game world, and to allow Users to resume progress where they left off. We will take reasonable steps to ensure that User privacy is protected and respected at all times in association with the use of Cookies. All Cookies used by the Site shall be processed in accordance with applicable law to the extent such law is reasonably known to us.
5.1.3. Chat Logs. Certain games on the Site may involve chatting with NPCs via text, and our servers will log an encrypted version of these chats. Specifically, the denial or deletion of Cookies will eliminate a gameplay session and make it impossible to return to that session once the session closes.
5.2. User Choices. Before the Site places Cookies on a User's device, the User will be presented with a message requesting consent to place those Cookies. Users may deny consent to the placing of Cookies but this may affect the usability of the Site. Users can choose to enable or disable Cookies in the software they use to access the Site. Users should be aware that, by default, most such software accepts Cookies. Users are directed to the help function of their access software for more information. Users can delete Cookies at their discretion. Just be aware that this may affect functionality including loss of Data previously provided and gameplay previously experienced.
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Use of Data. Any or all of the aforementioned Data may be required by us from time to time in order to provide Users with the best possible service and experience when using the Site. Specifically, we may use Data for the following reasons:
6.1. Internal record keeping.
6.2. Improvement of our products and services.
6.3. Cyber-security.
6.4. Customer support purposes.
6.5. To fulfill other purposes for which a User provides Data to us.
6.6. To provide a User with notices about that User’s account or about the Site.
6.7. For any other purpose with a User’s consent.
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Sharing Data. We may share User Data with the following persons for the following reasons:
7.1. Agents. Our employees, professional advisors, and other agents, in order to provide benefit from our services to Users.
7.2. Law Enforcement. Regulatory and law enforcement authorities, in order to facilitate the detection of unlawful activity or regulatory non-compliance.
7.3. As Needed. Such other persons or entities as are necessary, in our reasonable judgment, in order to provide the benefit of our services to any given User for minimum cost, upon reasonable notice to such Users.
7.4. Gemini. Game chat logs may be run through Google Gemini's API. In order to provide the in-game chat experience, Google Cloud services also has access to your chat logs, and copies of them may be retained for up to three years on Google Cloud services. Once again, we ask that you NOT input any personally identifiable information into the chat. For purposes of applicable Data Protection Laws which use this term, Google may therefore be considered to a “data processor.”
7.5. Consent. To any third party, with a User’s consent.
7.6. Payment. For Users who wish to access premium features, your payment information is used to pay for those features and is processed through a third-party processor. Your payments are handled by the processor, and your payment information is not visible to us.
We may use User Data for the above reasons if we deem it necessary or desirable to do so for a legitimate purpose. If a User is not satisfied with this, then the User has the right to object in certain circumstances. (See Section 11 below.)
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Data Retention.
8.1. Generally. Unless a longer retention period is required or permitted by law, we will only retain User Data as long as reasonably necessary to provide our products and services to a given User subject to this Privacy Policy or until a given User request that User Data be deleted. Users are advised, and agree to accept, that even if we delete any given piece of User Data, that piece of User Data may persist on backup or archival media for legal, tax, or regulatory purposes.
8.2. Gameplay Logs. Chat logs from gameplay will be backed up daily and set to automatically delete after 30 days. But, you shouldn’t be putting any sensitive personal information into the chat in the first place, right?
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Data Security. We will use commercially reasonable methods in order to protect User Data. Nevertheless, if a User suspects any misuse or loss of, or unauthorized access to, User Data, then immediately contact us at jeff@jeffluntgames.com
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Declining or Withdrawing. Users may decline to provide Data, or, after agreeing, may subsequently withdraw permission for us to collect Data. However, by declining or withdrawing, certain functionality may decline in quality or become unavailable.
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User Rights. Users have the following rights in relation to User Data:
11.1. Right to Access. The right to request copies of the information that we hold about that User at any time, or to request that we modify, update, or delete such information. We will not charge a User for access to the data that we have about that User, unless the request is unreasonable or duplicative. We may, in our discretion, refuse such a request where the law allows. If we refuse such a request, the User may further request an explanation for the refusal.
11.2. Right to Correct. The right to have a User's Data corrected if such Data are inaccurate or incomplete.
11.3. Right to Erase. The right to request that we delete or remove that User's Data from our systems. But see Section 12 below.
11.4. Right to Restrict Use of User Data. The right to "block" us from using User Data, or to limit the ways in which we can use it. However, certain limitations may cause functionality to decline in quality or become unavailable.
11.5. Right to Data Portability. The right to request that we move, copy, or transfer a User's Data.
11.6. Right to Object. The right to object to our use of a User's Data, including where we use it for otherwise legitimate reasons.
11.7. Further Rights. You may have additional rights depending on the jurisdiction in which you live or from which you access the Site, such as California, The European Economic Area, Switzerland, and the United Kingdom. Contact your local authorities or a lawyer licensed in your jurisdiction to learn more about your rights.
To ask questions regarding a User’s Data, to exercise any of the User Rights set out above, or to withdraw a User's consent to the processing of User Data (where consent is our basis for processing that User’s Data), that User should contact us at jeff@jeffluntgames.com
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Chat-Log Data. Regarding personal Data divulged in the in-game chat logs, the anonymous nature of play sessions will make it difficult to identify a User or ensure that the person requesting deletion is the User who generated the chat logs and provided the Data. You agree to comply with all reasonable requests from us to help ensure that you are the proper User who provided the Data in chat. You agree to hold us harmless in the event that your Data are deleted without your consent if we reasonably believed that you requested such deletion.
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Minors. The Site is intended only for those who are 17 years old or older. Our games are decidedly not for children under the age of 13, and we do not knowingly collect Data from anyone under the age of 13. Normally, we have no way to know the age of any particular User. Moreover, the gameplay involves a significant aspect of role-playing, so we generally have no way of knowing whether information input into a game via chat is true or fictitious. (And please, keep it fictitious.) However, if we learn that we have collected Data from someone under the age of 13 without parental consent, then we will take steps to delete those Data. Parents can learn more about how we handle data by contacting jeff@jeffluntgames.com.
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Transfers Outside the European Economic Area. Users located in or subject to the jurisdiction of the European Economic Area (EEA) are advised that Data collected by us may be stored and processed in and transferred to countries outside of the EEA. Please note that our principal place of business is located within in the United States of America. Therefore, for the avoidance of doubt, Users should assume that User Data will be stored in, processed in, and transferred to countries outside of the EEA. Users who do not or cannot accept this should not use the Site.
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External Content. Whether on the Site or in other forms of communication, we may provide links to other websites or other games. We have no control over websites and games created or operated by third parties, and we are not responsible for the content of such websites and games or any actions with regard to Data provided to them by Users or by third parties. This Privacy Policy does not extend to the use of such websites. Please read the privacy policies of other websites and games prior to using them.
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Changes of Ownership and Control. We may expand or reduce our business, and this may involve the sale or other transfer of control of all or part of the Site. Data provided by Users will, where it is relevant to part of our business being transferred, be transferred along with that part, and the recipient shall be permitted to use the Data for the purposes for which they were originally supplied to us. We may also disclose User Data to a prospective purchaser of its business or any part thereof, so long as we use reasonable diligence regarding such purchasers and provide reasonable safeguards for the protection of such Data.
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Choice of Law. This Privacy Policy shall be governed by, and construed according to, the laws of the United States and the State of Illinois, without regard to conflicts of laws principles. All actions hereunder may be brought only in a U.S. state or federal court having jurisdiction in Cook County, Illinois, and the User hereby consents to venue in these fora.
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Transfer of Rights. Users may not transfer any of their rights under this Privacy Policy to any other person, although those rights shall attach where reasonable to legal entities and their agents when those agents use the Site in the course of their duties. We may transfer its rights under this Privacy Policy where we reasonably believe that User rights will not be materially affected.
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Severability. If a court of competent jurisdiction ultimately determines that any portion of this Privacy Policy is unenforceable, then that provision shall be rewritten, interpreted, or otherwise modified to include as much of its nature and scope as will render it enforceable. If that provision cannot be so modified as to be enforceable in any respect, then it shall be severed from this Privacy Policy, and the remainder of the Privacy Policy shall be enforced as if the offending provision were not included.
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Changes and Revisions. We reserve the right to revise this Privacy Policy as we, at our sole discretion, may deem necessary or advisable from time to time. Any revisions will be posted on the Site and will apply to any given User upon that User’s first accessing the Site after such revisions are posted. Users may contact us by e-mail at jeff@jeffluntgames.com to ensure that they have the latest version of this Privacy Policy.
This policy is effective as of 15 September 2024.