Privacy Policy

Effective date: February 9, 2022

We are Numinous Games. (“us”, “we”, “Numinous”, or alternative first person reference), and we want to thank you for your interest in Area Man Lives. If you are here, you have either been directed here through our website, located at areamanlives.com (the “Website”), or through a digital storefront.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service, and your rights to your data under US and International Law, including but not limited to EU Directive 2002/58/EC and the EU General Data Protection Regulation (“GDPR”), the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 (“CAN-SPAM”), the US Children’s Online Privacy Protection Act (“COPPA”), and the California Consumer Privacy Act (“CCPA”). This Privacy Policy applies to Area Man Lives (a “Service”) where this Privacy Policy is referenced, regardless of how you access or use them, including through mobile devices. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Service.

We use your data to provide and improve the Services. This Privacy Policy is solely intended to inform you of our data collection practices and your rights to any of your data that we may collect.

This Privacy Policy describes:

  • The information we collect, how we collect such information and the purposes of our collection;

  • How we use and with whom we share such information;

  • How you can access and update your information; and

  • How we protect the information we store about you.

Disclosure to California Residents: In our efforts to comply with applicable regulation, we ask and advise that California residents review the “CCPA Disclosure” at the end of this document. Although we do not sell user data, we will provide notice if at any time those circumstances change.

 

Definitions

Personal Data

Personal Data means information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, a device identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Data Controller and Data Protection Officer

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Where we have a legal obligation to do so, we have appointed data protection officers (DPOs) to be responsible for our privacy program. You can contact our DPO via the Contact Us information detailed below in this privacy policy.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is you! The individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

 

Information Collection And Use

We collect different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Services, we do not ask you to provide us with personally identifiable information.

Usage Data

We, or third parties operating through Area Man Lives, may also process or collect anonymized information concerning your access and use of the Service (“Usage Data”). This Usage Data may include information such as:

  • Audio data of your voice, recorded using your microphone, and sent encrypted via HTTPS directly to Google for speech recognition using Google Cloud Speech. This audio data is not accessed by Numious. It is not retained by Google, but processed anonymously in real-time and converted to a text transcript estimate. The estimated text is then sent back to your device, as you speak. After the text is delivered back to you, the audio data is destroyed on Google’s servers, since data collection is disabled.

  • An estimate of a text transcript based on audio data recorded of your voice, as mentioned above, received from Google Cloud Speech. This text is then sent to Wit AI, which processes it anonymously to infer “intents” of your speech (for example, good vs bad, person/place/thing, etc). The intents are then sent back to your device and processed locally on your device to infer a response from an in-game prompt. The anonymized text result is collected by Wit AI, so that we can use transcripts of text responses to improve the experience of the game (such as to make characters appear smarter, or more funny, etc).

  • Estimates of inferred “intents” of your speech, as mentioned above.

  • Audio data saved locally to your device, which may be played back later for entertainment purposes.

 

Use of Data

We use your information to fulfill a contract with you and provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:

  • To provide and maintain our Services;

  • To notify you about changes to our Services;

  • To allow you to participate in interactive features of our Services when you choose to do so;

  • To provide customer support;

  • To prevent, detect, mitigate, and investigate fraud, theft, intellectual property infringement, security breaches or other potentially prohibited or illegal activities.

 

Retention of Data

We will retain your Usage Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Usage Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies, or for internal analysis purposes.

 

Transfer Of Data

Your information, including Usage Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we may transfer the data to the United States and process it there.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Usage Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other information. The transfer of such data is for the purpose of fulfilling our contract with you, as specified above.

 

Disclosure Of Data

Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your anonymized Usage Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

We may disclose your Usage Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation

  • To protect and defend our rights or property

  • To prevent or investigate possible wrongdoing in connection with the Service

  • To protect the personal safety of users of the Service or the public

  • To protect against legal liability

Change of Control

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy policy with respect to your Usage Data.



Security Of Data

We protect your Usage Data using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use may include firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. The security of your Usage Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Usage Data, we cannot guarantee its absolute security.

 

Your Rights

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Usage Data. However, since your data is anonymized, we may not be able to determine with sufficient certainty that it is your data. In the event we can be certain data you request is yours, the following applies:

How to Control Your Information

You have the right to:

  • Access your user data

  • Correct the data you have provided to us

  • Have information provided to you in a portable format

  • Request the deletion of the data we have collected

  • Restrict processing

  • Object to processing or the legal basis on which we rely to process your data

Please note that we may ask you to verify your identity before responding to such requests.

You may send an e-mail to info@numinousgames.com with your request to exercise any of the rights identified above. Place the reason for your request (e.g. “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and e-mail address in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes.

We are unable to delete data controlled solely by third parties; for example, if you purchase our game(s) through a console or content delivery platform, we won’t be able to delete your game from your library, nor the data collected by the console or platform operator in connection with your purchase. Similarly, if you access any our of Services through third party social media or service platforms, such as Facebook, or if you are routed to a third party service provider’s web page through our Services, you will need to make any deletion requests to those respective third parties separately.

 

Opt Out Options

Opting out of Promotional Communications

You can choose to opt out of receiving promotional e-mails and product updates from us by clicking on the “unsubscribe” link in any such e-mail. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, usually within ten (10) business days.

Opt Out Limitations

Please note that if you opt-out of our promotional communications or other forms of communication, we may still e-mail or communicate with you from time to time if we need to: provide you with information and updates concerning this Privacy Policy, respond to a customer support or technical support inquiry, notify you of changes to your account (including suspension or deactivation), respond to any customer service or technical support inquiry, request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons.

 

Service Providers

We may employ third party companies and individuals to facilitate our Services (“Service Providers”), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services are used.

These third parties have access to your Usage Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Web Services, Payment Processing and Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Wit.AI

Wit.AI is a Facebook service that provides Natural Language Processing of text input. Information about Wit.AI’s Data Processing Terms can be found here: https://wit.ai/terms/#dp

Google Cloud Speech

Google Cloud Speech is a web service offered by Google that performs speech recognition of audio data.

For more information on how Google processes data for Google Cloud services, you may visit: https://cloud.google.com/terms/data-processing-terms

 

 

Links To Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every website you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services.

 

Children’s Privacy

Area Man Lives is intended for a general audience and not intended for children under the age of 13. We do not knowingly collect neither Usage Data nor personal information from users deemed to be children under their respective national laws. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission. We recognize a special obligation to protect personal information obtained from young children.

That being said, our products are family friendly and we encourage parents and guardians to use our Services with their children. However, we take children’s privacy very seriously, and we do not collect any personal information from children through Area Man Lives. We strive to comply with the Children’s Online Privacy Protection Act of 1998, the US law that protects the privacy and information of children. We strongly encourage parents and guardians to learn more about this important regulation. For more information, you can visit: https://epic.org/privacy/kids/#introduction.

We may also aggregate your or your child’s information with information about other users in a way that does not directly identify you or your child.

We also may share aggregated or de-identified information with third parties, including to help us develop, analyze and improve content and Services. It is possible that the third parties may use this aggregated or de-identified information to develop their own products and service offerings.

 

Changes To This Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. If we decide to make material changes to our Privacy Policy, we will notify you and other users by placing a notice on areamanlives.com, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective. We may supplement this process by placing notices in our games. You should periodically check areamanlives.com and this privacy page for updates.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • Reach our Data Protection Officer by email: info@numinousgames.com

  • By phone number: 1+5157082257

  • Or my mail at:

Numinous Games

900 Keosauqua Way, Ste 471

Des Moines, IA 50309-1513, IA



California Consumer Data Rights

To the extent applicable, Numinous Games complies with the California Consumer Privacy Act of 2018 (CCPA), effective January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.

Categories of Data we Collect and their Uses

In addition to the details provided in our Privacy Policy, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

Reason for Collection

(specifically identify business purpose if for business purpose)

Is Information “Sold” to 3rd Pty?

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

No

N/A

N/A

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

No

N/A

N/A

Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

N/A

N/A

Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

N/A

N/A

Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

N/A

N/A

Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

No

N/A

N/A

Geolocation data.

Physical location or movements.

No

N/A

N/A

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

N/A

N/A

Professional or employment-related information.

Current or past job history or performance evaluations.

No

N/A

N/A

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

N/A

N/A

Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

N/A

N/A



Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our end users. For example, from customers who engage us for customer support or to provide customer feedback.

  • Indirectly from our end users. For example, through information we collect from our end users in the course of providing customer support to them.

  • Directly and indirectly from activity in Area Man Lives.

Your Rights and Choices

We do not collect personal information about you in Area Man Lives. But if we did, these would be your rights:

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

We generally do not sell our player data. However, if we do sell your personal information for a business purpose, we will also disclose to you:

  • The personal information that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete any transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products, including our website and games, to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.



Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at: 1 (515) 7082257

Visiting: numinousgames.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.