Square Enix Online Services Privacy Policy

I. Background

We, Square Enix Limited ("SEL"), are committed to respecting the privacy rights of those customers, visitors, users and other participants (collectively, "Users") who use our online, membership-based entertainment service(s) ("Services"). The Services include, without limitation, our FINAL FANTASY® XIV, PlayOnline® and CIS® online services and any other online services accessible via our Square Enix Account system. The Services also include certain multi-player online games, as well as such other, new, replacement and/or alternative functions, products and services as we may elect to make available to Users from time to time.

THIS POLICY SUPPLEMENTS, AND FORMS PART OF, OUR GENERAL PRIVACY POLICY, WHICH CONTAINS IMPORTANT INFORMATION ON HOW YOUR PERSONAL INFORMATION IS COLLECTED, STORED AND USED.

This Policy, which also forms an important part of each of the member agreements and/or terms of use applicable to the Services (collectively, the " Member Agreement"), describes the information SEL collects from Users, and how and why that information is collected, stored and used. As a User of the Services, you acknowledge that SEL will collect information from you, some of which may be personally identifiable information. By accessing and using the Services , you consent to the collection and use of that information in accordance with this Policy and SEL’s general Privacy Policy. In addition, you understand and agree that, by using the Services to play online games, certain information about you will be available to other Users (as explained in this Policy or in the documentation applicable to such online games), and SEL cannot control, and will have no responsibility for, the actions of such other Users with respect to that information about you.

II. Use of the Services by Users under the age of 18

SEL strongly encourages parents and legal guardians to take an active role in supervising internet use by their children, protecting their children’s privacy and preventing inappropriate uses of information about their children. Parents and legal guardians are fully responsible for compliance with this Policy and for any use of the Services by their children, and are further responsible for educating their children as to the data collection practices of SEL and the importance of protecting personally identifiable information at all times. An additional resource on use of the internet by children is available on the UK government’s Directgov website located at http://www.nidirect.gov.uk/keeping-children-safe-online .

A child under the age of 18 may use the Services if he or she is at least 12 years old, provided that a parent or legal guardian first provides his or her consent to such use and agrees to supervise (and accepts all responsibility for) such child's use of the Services. We reserve the right to suspend the account of any User who provides access to the Services in violation of this Policy or of the Member Agreement.

III. SEL Data Collection and Use

A. What personal information does SEL collect?

As a User, information about you will be collected (i) during the registration process, when you provide us with personally identifying information, (ii) by our Services technology, which automatically collects information on your use of the Services as you access the various products and services and (iii) through your relevant membership webpage(s) and/or any applicable viewing functionality (collectively, "Account Page"), which stores any information that you voluntarily provide and tracks your usage as you access and participate in interactive products and services such as online games, email, chat rooms and friend lists. These various kinds of information are described in more detail below.

1. Information collected during the registration process

We require Users to register with us in order to access a number of the products and services offered on the Services. During registration, we ask you to provide us with certain information that personally identifies you (referred to below as "Personal Information"). Personal Information may include your name, date of birth, telephone number, mailing address, email address and credit-card account information, as well as any other information that may be used to identify you. Personal Information is collected so that we can provide you with the Services you requested, contact you to verify your Personal Information or Services account activities, notify you if there is a problem with your account, and enhance the services that we provide to you. After registration, you will be given a member ID and asked to choose your own password. We strongly suggest that Users not choose passwords that can be easily recognized or guessed by others, and that they take steps to protect the confidentiality of their password information.

2. Collection of traffic data

SEL may also collect certain anonymous usage data, such as pages visited and services used within the Services (collectively, " Traffic Data"). This information is not Personal Information and generally is not aggregated with Personal Information. We generally use Traffic Data to improve our services to you and to customize and enhance your experience of the Services.

3. Information provided during usage

The Services may include email services, friend lists, chat rooms and/or other functions where Users may voluntarily post or exchange information, including (but not limited to) Personal Information. Users can also communicate with each other through their players and characters while using the Services to play online games. While Users have complete discretion over whether they share Personal Information with other Users while enjoying the Services, SEL strongly suggests that Users not reveal their Personal Information in this way. Please note that such Personal Information is stored by SEL as non-public information. SEL reserves the right to access and/or monitor Users’ personal files, emails and chat-room and online-game conversations.

While using the Services to access online content, Users (including children) may receive or be exposed to information that is offensive, hostile or unsuitable to them. SEL has addressed this problem, in part, by providing an automatic (i.e. unmonitored) filtering system in chat rooms and online games that allows Users to elect to block such information while they are using these services. Although we believe that the filtering system will eliminate some exposure to offensive and inappropriate material, we cannot promise that all such material will be eliminated, and we strongly encourage parents and legal guardians to oversee the activities of children. SEL is not and will not be responsible for the disclosure or exchange of any Personal Information by Users in connection with use of the Services, or the receipt of any inappropriate or offensive materials by any Users, including (but not limited to) children, in connection with any use of the Services .

The Services may, from time to time, include certain features for Users (such as the ability to take “screen shots” of a game), which Users can utilise while playing certain online games or using other services. Information obtained by use of these features may include information concerning you and/or other Users (including, but not limited to, Character Data, Player Data and any other information voluntarily provided by Users). SEL cannot control the acts of Users, the information that Users may include, display or transmit by use of these features, or how any such information is otherwise handled by Users. You understand that Users may obtain, display, distribute and perhaps even alter materials (including, without limitation, screen shots) that contain your Character Data, Player Data or other information concerning you. In no event will SEL have any responsibility or liability to you for any conduct involving, or claims or losses arising from, Users’ utilising features of the Services (whether or not similar to those described in this paragraph), nor will SEL have any liability to you or to any third party for any information, images or other data disclosed, distributed or otherwise made available through or as a result of utilising any features of the Services (whether or not similar to the features described in this paragraph).

B. How do we use the information we collect?

1. Use of information by SEL

SEL uses Personal Information to respond to your requests for help or information, to complete transactions such as purchases or monthly billing, to verify that you are qualified to use the Services, and for other purposes relating to our operation of the Services. We may also use Personal Information to notify you of changes in Services features, Member Agreement terms, or other related SEL agreements, and to send you updates or newsletters about our company and services and other promotional materials via your registered email address. In addition, SEL may use or disclose Personal Information and other User information in response to any subpoena or other legal disclosure obligation, or in the event that a User is participating in (or suspected of participating in) prohibited, illegal or inappropriate activities or threats, including, without limitation, any activities that may endanger any individual's life or property while using the Services as well as any other activities that SEL determines (in SEL’s sole discretion) to be inappropriate.

SEL may use information on User-created players and characters (including, but not limited to, names and location) for marketing and promotional activities, and may do so without any notice to the Users whose players and characters are used. Such activities may include, without limitation, posting player and character information on SEL websites.

2. Information shared with third parties

We may share your Personal Information with our affiliates, advertisers or other business partners, who may be responsible for responding to your requests for information, support or assistance. These business partners must agree to protect the confidentiality of all Personal Information they receive from us, as described in paragraph 3 below.

3. Confidentiality of Personal Information

Except as otherwise provided in this Policy, we will keep your Personal Information confidential and will not share it with third parties, unless SEL reasonably believes use of your Personal Information and/or such disclosure is necessary so that we can:

(a) comply with any law, such as in response to a court order or subpoena;

(b) protect our rights or any property that we own, operate or control;

(c) enforce any Member Agreement or other terms of use applicable to the Services; and/or

(d) protect the safety and/or security of Users or third parties.

4. Security of Personal Information

We take those steps we deem reasonably necessary to protect the security, integrity, accuracy and privacy of the information our Users share with us, including setting up processes to avoid any unauthorised access or disclosure of this information. We will provide you with the capability to transmit your Personal Information via secured and encrypted channels. We will take reasonable steps to protect Personal Information and Traffic Data from unauthorised third parties. We endeavour to maintain accurate Personal Information collected from our Users, and are grateful for your assistance in maintaining the accuracy of that information while you remain a User of the Services. We also take reasonable steps to require that third parties with whom we share any data provide sufficient protection of that Personal Information.

IV. User ability to access, update and correct Personal Information

Your Personal Information is available for review from the relevant information/support section of your Account Page. You may access your personal profile at any time from that section to review and update your Personal Information.

V. How you can protect your Personal Information

We are committed to protecting the privacy of your Personal Information, and we urge you to play an active role as well by following these measures when you are using the Services:

(a) never give out your member ID or password, or permit anyone else to access the Services using your ID and password;

(b) immediately report any unauthorised use of your member ID or password by using the form available in the "Service & Support" section of your Account Page;

(c) immediately report any unauthorised use of your credit-card information to the Square Enix Information Centre; and

(d) always sign off from your account and log out from the Services when you have finished a Services session – these actions will help to prevent others from gaining access to your information. SEL will never ask you to disclose your password in any email or chat room, and if you ever receive such a request from someone purporting to be with SEL, please report it to us immediately.

VI. Changes to this Policy

SEL reserves the right, at any time and without notice to you or to other Users, to update or modify this Policy, simply by posting such update or modification on the "Information" section of your Account Page and on the applicable official Services website(s). Any such update or modification will be effective immediately upon posting on these locations, and your continued use of the Services after such posting shall constitute evidence of your acceptance of the update or modification

In the event that SEL is acquired by or merged with a third party, or any of the Services is sold or transferred to another party, or is otherwise no longer under SEL's control, we reserve the right, in any of these circumstances, to sell or otherwise transfer the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your Personal Information is treated, transferred, or used. Therefore, you should know that in such event, your Personal Information may be treated like any other asset of our company, and sold, transferred or shared with third parties, or used in ways not contemplated or permitted hereunder, without notice to you or your consent.

VII. Our contact information

If you have any questions or comments regarding this Policy or the Services, please contact us using the forms available under "E-mail Support" in the "Service & Support" section of your Account Page.