Welcome to Liminal!

Liminal Experiences, Inc. is headquartered in Los Angeles, California. This privacy policy describes the different ways we may collect, use, and share information on, through, or in connection with the Liminal Services (see “What are the Liminal Services?” below). If you have any questions, you can always reach out to us as described in “Contact Us” below.

When we refer to “Liminal” (or any similar terms like “we” or “us”) in this privacy policy, we mean the Liminal Experiences entity that controls and is responsible for your information, including Liminal Experiences, Inc. and its subsidiaries that help provide and support the Liminal Services. You can also find details about the data controller for personal information we collect through different Liminal Services in “Contact Us” below.

1. WHAT ARE THE LIMINAL SERVICES?

We use the term “Liminal Services” to describe any Liminal products or services that directly link to this privacy policy. These include, for example:

• games like Liminal:Skies;

• websites, and applications such as www.liminal.gg; and 

• live events where this privacy policy is posted.

Note that your use of the Liminal Services may also be subject to additional terms and conditions. For example, you must review and accept the Liminal End User License Agreement to play Liminal:Skies.

Please read this entire privacy policy. You should also carefully review any other agreements that apply to the Liminal Services you use, and confirm you understand and agree to them, before using those products or services.

2. WHAT INFORMATION DO WE COLLECT?

The types of information we collect depend on how you interact with us. Generally speaking, we collect information in three main ways: A) when you provide it to us, B) automatically when you use the Liminal Services, and C) from service providers and third parties.

A. Information You Provide

You can provide us with different kinds of information depending on how you interact with the Liminal Services. Sometimes we’ll ask you to provide specific pieces of information, such as when we require it to provide parts of the Liminal Services to you (for example, by prompting you to provide your date of birth or complete an online registration process). If we ask you to provide us with information in these cases and you choose not to, you may not be able to access the relevant Liminal Services and/or some features may not operate as intended.

For instance, in order to make purchases in Liminal:Skies and to play the game, you’ll need a Liminal account. To create one, you’ll need to provide us with basic registration information like your name, a public-facing display name, password, the country you live in, and email address. If you want to make a purchase, we may ask you to provide payment-related information (like your credit card number and expiration date) to complete the transaction. In addition, many of our services require your date of birth to determine which features we can offer you and which settings to apply to your account based on your age and location.

We also collect the information you voluntarily provide to sign up for email alerts, use social features like forums or chat, register for early access to our games, use our developer tools (including to create and publish games and other content), enable two-factor authentication, register for or attend our events, complete surveys, or contact us through Player Support requests or customer service. We collect whatever information you choose to provide to us in those or other similar cases.

B. Information We Collect Automatically

We collect some information automatically when you visit, access, or use the Liminal Services. This includes information about your gameplay or application usage, purchases, entitlements, and other activity in the Liminal Services, that are typically associated with your account (if you are logged into your Liminal account or use a third-party account to access the Liminal Services) or with an identifier we have assigned to your device or profile. While the specific types of information that we automatically collect may vary, they generally include:

• Usage information and statistics about how you interact with the Liminal Services, including the application you used or the game you played, how long you used or played it and when, gameplay attempts, progression and results, saved preferences, crash reports, the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, and platform type;

• Technical information about your computer, device, hardware, or software you use to access our services, such as IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and

• The general location of your device, which we typically derive from your device’s IP address.

The Liminal Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools that may be stored on your device. They help us, our service providers, and third parties recognize your device and provide information about how you use and interact with the Liminal Services. For example, they support our ability to authenticate users, remember preferences, manage advertising, personalize experiences, and conduct data analytics.

Please note that if certain features on the Liminal Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Liminal Services, their services, or others’ websites over time. For example, when you use Liminal Services that include third-party software, those third-party providers may collect information through their technology. These features are subject to those third parties’ privacy notices and policies.

C. Information We Collect from Other Sources

In some cases, we may also receive information about you from service providers and third parties in connection with your use of the Liminal Services or your interactions with us on other platforms.

For example, some other developers allow you to use your Liminal account to log in to their service. And if you choose to link your Liminal account with your account on a third-party social media (like Discord), gaming (like Steam), or other similar website or service, or if you interact with an ad for one of the Liminal Services on an external website or service, the company that operates that website or service may share some information with Liminal in accordance with their own privacy practices. Your privacy settings on the other company’s website or service typically control the specific types of information they can share with Liminal, so please be sure to review and update them regularly. Common examples for linked accounts might include your third-party account display name and user ID, as well as associated device information, name, and email address. 

You can also buy, download, or access some Liminal Services on or through services operated by third parties. If you do, they may provide us with information to facilitate your access to and use of the Liminal Services. This typically includes information like your display name, user ID, and device and region information. For example, you can choose to download and play games like Liminal:Skies on gaming consoles (like PlayStation®, Microsoft Xbox, and Nintendo Switch) through your gaming console account. When you do, the company operating that platform or service may share some information with us, which helps us do things like facilitate your gameplay and track your progression and entitlements.

D. Fraud Prevention & Anti-Cheat

Providing users with a fair, balanced, and competitive experience on the Liminal Services is extremely important to us. We strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity on the Liminal Services. We use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about your computer and the software on your computer to detect cheating and may be provided by Liminal or by service providers.

3. HOW DO WE USE INFORMATION?

As a general matter, we use the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and promote the Liminal Services. This includes using it for purposes such as:

• Creating, verifying, and managing user accounts and features;

• Providing the Liminal Services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates);

• Developing, delivering, and improving the Liminal Services and other offerings, some of which may be offered in partnership with other parties;

• Personalizing your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests (for instance, if you frequently play games in a certain genre, we may infer that you’d be interested in that genre and suggest similar games to you);

• Promoting the Liminal Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events;

• Managing alpha, beta, or early access tests (and collecting feedback);

• Conducting data analytics (like analyzing how the Liminal Services are used so we can better understand, improve, and personalize them);

• Complying with our legal or contractual obligations and enforcing our terms;

• Securing the Liminal Services, such as by detecting fraud and otherwise protecting Liminal and other users from illegal or harmful actions; and

• Improving technologies or processes used to accomplish these purposes (like training machine learning models used to help detect or moderate toxic, illegal, or harmful content or conduct and enforce our terms and policies like our Community Rules).

We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. But please note that this privacy policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.

4. HOW DO WE SHARE INFORMATION?

We may share some of the information we collect to help operate and improve the Liminal Services. Depending on how you interact with us, common examples might include sharing:

• With console and platform partners (for example, to facilitate gameplay when you access the Liminal Services through a third-party console provider);

• With other users (like if you use social features such as chat);

• Publicly (for example, your display name, content you create or share, basic game statistics, and other similar information may be generally accessible to others);

• With service providers that operate on our behalf to help support the Liminal Services in accordance with our instructions (for example, cloud storage providers, payment processors, or marketing and advertising partners);

• When we believe we must in order to comply with the law or to protect you, Liminal, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of our terms or policies, or if necessary to protect others from death or serious harm to body or property);

• With other Liminal entities (including to help provide support for the Liminal Services internationally);

• In connection with certain types of corporate transactions (like in the event of a restructuring or the sale of all or a significant part of our business);

• With your permission (for example, if you link external accounts with your Liminal account, or use your Liminal account to sign in to third-party games and services or participate in cross-promotional events); and

• We may also share information that does not identify you with third parties, including aggregate or de-identified information.

No mobile phone numbers provided to Liminal for security purposes will be shared with third parties or affiliates for marketing/promotional purposes.

To the extent that we share your personal information with third parties, we endeavor to ensure these third parties provide the same or substantially similar protections as those that Liminal describes in this privacy policy.

Third parties you interact with through Liminal Services may have different privacy practices than Liminal, so we encourage you to review their privacy policies before sharing your information with them.

5. YOUR CHOICES AND CONTROLS

We seek to provide you with meaningful choices about the personal information we collect. The specific choices available to you often vary depending on the exact nature of our relationship with you, such as the Liminal Services you use. Common examples include:

• You can request that we provide access to, or that we correct or delete, personal information we’ve collected from you. Please submit requests to access, update, or delete personal information associated with your Liminal account by reaching out to us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request.

• If applicable, you may also have the option to appeal or otherwise request human review of decisions made by automated means.

• You can change your email marketing preferences at any time, such as by using the opt-out mechanism provided in our marketing emails, updating your Liminal account settings, or contacting us with your request (see “Contact Us” below).

• You can change your privacy settings on other parties’ websites (such as social networks) or platforms (like console providers) to limit the information they may share with us.

• You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause the Liminal Services not to work as intended and some features may not be available.

• If you’re under the age of 18 and have a Liminal account, you can ask that we remove or anonymize certain content you’ve provided on the Liminal Services. Please direct requests to help delete or edit content on the Liminal Services to Liminal as described in “Contact Us” below.

Some parts of the world provide individuals with specific choices related to their personal information by right under local law.

6. RETENTION

Because the specific personal information we process and our reasons for doing so often vary depending on how you use the Liminal Services, how long we retain it can also vary. We generally store personal information for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless a longer retention period is required or permitted by law.

The main criteria we consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of information in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the information is required to prevent fraud or similar abuse of the Liminal Services (including to enforce prohibitions against cheating and other unauthorized behavior). For example, if you create a Liminal account, we will generally store the personal information associated with your Liminal account for as long as needed to maintain your account, provide the Liminal Services you requested, enforce any terms that apply and govern your use of the Liminal Services, and maintain appropriate records to reflect how we deliver the Liminal Services to you.

To learn more about requesting that Liminal delete your personal data, please see “Your Choices and Controls” above.

7. SECURITY

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected. If we become aware of unauthorized disclosure of your personal information, we will notify you as required by law and take steps to help secure your information.

8. UPDATES

We’ll update this policy from time to time to reflect changes in our practices or relevant laws. When we do, we’ll change the date noted at the top of the policy. In some cases, we may also notify you of the relevant changes by email or within the Liminal Services. Please review this policy regularly to make sure that you understand your relationship with Liminal and the ways we may collect, use, and share information in connection with the Liminal Services.

9. OUR GLOBAL OPERATIONS

Liminal Experiences, Inc. is based in the United States, but we operate globally to help provide users all around the world with a better experience on the Liminal Services. This means that Liminal may process the information we collect in connection with your use of the Liminal Services in places outside the region where you reside.

A. Data Transfers

When you use the Liminal Services, your information may be transferred to or stored in the United States or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you’re authorizing Liminal to process your information in any of the locations where we operate (including the United States) by using the Liminal Services.

To learn more about the Liminal entity responsible for operating the Liminal Services you use, see “Contact Us” below.

B. US State Comprehensive Privacy Laws

For California Residents

The California Consumer Privacy Act or “CCPA” provides residents of California with certain rights to their personal information. Terms used in this subsection are defined by the CCPA.

If you are a California resident, you have the right to:

• know and access what personal information we collect about you, including the categories of personal information collected and sources, the business or commercial purposes for collection, the categories of third parties with whom we disclose personal information, and the specific pieces of personal information collected;

• correct your personal information; and

• deletion of your personal information.

We will delete your personal information, unless retention is necessary for operational or legal reasons, including to:

• provide the Liminal Services you requested, complete transactions, or perform our contract with you;

• ensure the security or integrity of the Liminal Services, or debug the Liminal Services;

• exercise legal rights on behalf of ourselves or others;

• enable internal uses aligned with user expectations; or

• comply with a legal obligation.

We may also limit how we respond to your requests, including when necessary to:

• handle legal claims;

• comply with applicable laws or legal obligations; or

• cooperate with law enforcement.

As described in greater detail in “What Information Do We Collect?” section above, the specific information we collect from you typically depends on how you choose to interact with us on or through the Liminal Services. In the past 12 months, we’ve collected the following categories of personal information:

• identifiers (e.g., email address);

• commercial information (e.g., entitlements or purchase history);

• internet or other electronic network activity information (e.g., gameplay or website usage details);

• audio, electronic, visual, or similar information (e.g., voice chat);

• geolocation data (e.g., as may be derived from your IP address or included in your billing information);

• characteristics of protected classifications under California or federal law (e.g., age);

• personal information described in Section 1798.80(e) of the California Civil Code (e.g., name or credit or debit card information);

• in some cases, sensitive personal information (e.g., account log-in credentials and, if you list, sell, or trade creative content in one of our marketplaces, government ID); and

• inferences drawn from any of the above categories (e.g., the genres of games you may prefer to play based on your purchase history).

Liminal does not use or disclose sensitive personal information for purposes other than those that are necessary to provide the Liminal Services or permissible under the CCPA. Liminal also does not sell or share the personal information it collects. This includes for users for whom we have actual knowledge are under 16.

For more information on (1) the categories of sources from which your personal information is collected, please see “What Information Do We Collect?” section above; (2) the business or commercial purposes for collecting your personal information, including sensitive personal information, please see “How Do We Use Information?” section above; and (3) the categories of third parties to whom we disclose your personal information, please see “How Do We Share Information?” section above.

For Other US State Residents

Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia have each enacted a comprehensive privacy law, providing residents of those states with certain rights to their personal data. Terms used in this subsection are defined by the applicable privacy law in your state of residence.

If you are a resident of those states, you have the right to:

• know whether we are processing your personal data;

• access and obtain a copy of your personal data;

• correct your personal data (except for residents of Utah and Iowa); and

• deletion of your personal data.

Certain legal obligations and operational needs may limit how we respond to your requests. These exceptions may include:

• providing the Liminal Services you request or performing our contracts;

• conducting research to develop or improve the Liminal Services;

• identifying and fixing technical issues;

• performing other internal operations consistent with user expectations;

• preventing or responding to security incidents, fraud, identity theft, or other illegal or harmful activities;

• handling legal claims;

• complying with applicable laws or legal obligations; or

• cooperating with law enforcement.

Liminal does not sell personal data it collects or process it for targeted advertising. Liminal also does not profile its users through automated means to make decisions that have legal or similarly significant effects. This includes for users for whom we have actual knowledge are under 18.

For more information on (1) the categories of personal data processed by us, please see “What Information Do We Collect?” section above; (2) our processing of sensitive data from a known child under the age of 13, please see “Children’s Privacy” section above; (3) our purposes for processing personal data, please see “How Do We Use Information?” section above; and (4) the categories of third parties with whom we share personal data and the categories of personal data we shared, please see “How Do We Share Information?” section above.

Exercising Your Privacy Rights

To exercise your privacy rights, use one of the methods listed in the “Contact Us” section below. Only you (or an authorized representative on behalf of a California resident) may submit a verifiable request, which must include enough information for us to confirm your identity and understand the request. If you have an Liminal Experiences account, we may ask you to log in to verify your identity. Authorized agents of California residents must include written permission signed by the resident, who may also need to verify their identity directly. Requests may be denied if we cannot verify your identity or authority. Appeals can be submitted using the same contact methods listed in the “Contact Us” section below.

We will not discriminate against you for exercising any of your privacy rights under applicable law.

C. Residents Of The European Economic Area, The United Kingdom, And Switzerland

If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

Data Subject Rights

You may have the right to access, correct, or delete personal data we have collected about you through the Liminal Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. If applicable, you can request human review or contest decisions made by automated means. Where you have provided your consent to our data processing, you have the right to withdraw consent.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please see the “Contact Us” section below to learn more about reaching out to Liminal with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:

• EEA: European Data Protection Authorities

• UK: Information Commissioner’s Office

• Switzerland: Federal Data Protection and Information Commissioner

Basis for Processing

The legal bases we rely on to process your personal data depend on the Liminal Services you use and how you interact with them. They primarily include:

• Contractual Necessity: we process personal data to perform the Liminal Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the Liminal Services; detect and prevent fraud, cheating, or other similar misuse; facilitate features like cross-progression that allow you to play a game on one platform and continue your progress on another, which may require us to share your information with third-party partners; and contact you about your account, transactions, or other updates. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.

• Legitimate Interests: we process personal data as needed for Liminal’s business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the Liminal Services and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; manage (in-game) purchases; secure and protect the Liminal Services; supporting auditing, data analysis, and other legitimate business operations; prevent or moderate fraudulent, toxic, harmful, or illegal content or conduct that breaches our terms. To support these business purposes, we may build, improve, and use machine learning technologies to help identify harmful, toxic, or fraudulent content in our services. The content identified by these technologies may be subject to human review. Otherwise, if applicable, you may have the ability to request human review of automated decisions.

• Legal Obligations: we process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes; to identify or moderate illegal content or conduct on the Liminal Services; or processing date of birth to facilitate compliance with applicable youth protection laws.

• Consent: we process personal data when you provide us with your consent to do so. You aren’t required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.

10. CONTACT US

If you have questions or concerns about the Liminal Services (such as game-related issues, trouble accessing your Liminal account, bugs or other technical problems, payment matters, or content and entitlement issues), please contact our Player Support teams.

If you want to learn more about our privacy practices or this policy, or exercise your data subject rights, please email privacy@liminal.gg.

You can also contact us via postal mail (marked “Attn: Legal Department”) to Liminal Experiences, Inc., located at Unit 989, 5630 Venice Blvd., Los Angeles, CA 90019, USA.