Guidelines for Legal Requests of User Data
Effective date: October 20, 2020
Are you a law enforcement officer conducting an investigation that may involve user content hosted on Worlds Unending? Or maybe you're a privacy-conscious person who would like to know what information we share with law enforcement and under what circumstances. Either way, you're on the right page.
In these guidelines, we provide a little background about what Worlds Unending is, the types of data we have, and the conditions under which we will disclose private user information. Before we get into the details, however, here are a few important details you may want to know:
We will notify affected users about any requests for their account information, unless prohibited from doing so by law or court order.
We will not disclose any private user data or content, without a valid subpoena, court order, or search warrant.
1 About these guidelines
Our users trust us with their creative works. Maintaining that trust is essential to us, which means keeping user data safe, secure, and private.
While the overwhelming majority of our users use Worlds Unending services to create narratives and entertaining games, we recognize that there are bound to be a few bad apples in the bunch. In those cases, we want to help law enforcement serve their legitimate interest in protecting the public.
By providing guidelines for law enforcement personnel, we hope to strike a balance between the often competing interests of user privacy and justice. We hope these guidelines will help to set expectations on both sides, as well as to add transparency to Worlds Unending’s internal processes. Our users should know that we value their private information and that we do what we can to protect it. At a minimum, this means only releasing data to third-parties when the appropriate legal requirements have been satisfied. By the same token, we also hope to educate law enforcement professionals about Worlds Unending’s systems so that they can more efficiently tailor their data requests and target just that information needed to conduct their investigation.
2 Worlds Unending terminology
Before asking us to disclose data, it may be useful to understand how our system is implemented. Worlds Unending hosts collections of text, images, and structured data about fictional worlds -- facts about the people, places, items, plots, and other information necessary to conduct a tabletop roleplaying game. Each of these collections is called a “universe.” Universes may be public or private. Users that make their universes public may still restrict visibility of content within their universes.
Users - users are represented in our system as personal Worlds Unending accounts. Each user has a personal profile and can own multiple universes. Users can create or be invited to join organizations or to collaborate on another user’s universe.
Collaborators - a collaborator is a user with read and write access to a universe who has been invited to contribute by the universe’s owner.
Organizations - organizations are a group of two or more users that typically mirror real-world organizations, such as businesses or projects. They are administered by users and can contain universes.
Universes - a universe is one of the most basic Worlds Unending elements. They may be easiest to imagine as a project’s folder. A universe contains all of the notes, character biographies, place and item descriptions, images, maps, and other content related to a tabletop roleplaying game. Universes can have multiple collaborators and, at its owners’ discretion, may be publicly viewable or not.
3 User data on Worlds Unending
Here is a non-exhaustive list of the kinds of data we maintain about users and projects on Worlds Unending.
Public account data - There is a variety of information publicly available on Worlds Unending about users and their universes. User profiles display information about when the user created their account as well their public activity on Worlds Unending and social interactions. Public user profiles can also include additional information that a user may have chosen to share publicly. All user public provides display:
Display name
Universes that the user is following
Other Worlds Unending users that the user follows
The users that follow them
Optionally, a user may also choose to share the following information publicly:
Their real name
An avatar
An affiliated company
Their location
A public email address
Their personal web page
Organizations to which the user is a member (depending on either the organizations' or the users’ preferences)
Private account data - Worlds Unending also collects and maintains certain private information about users as outlined in our Privacy Statement. This may include:
Private email addresses
Payment details
Security access logs
Data about interactions with private universes
Organization account data - Information about organizations, their administrative users and publicly shared universes is publicly available on Worlds Unending. Public organization profiles can also include additional information that the owners have chosen to share publicly. All organization public profiles display:
The organization name
The universes that the owners are following
All Worlds Unending users that are owners of the organization
Optionally, administrative users may also choose to share the following information publicly:
An avatar An affiliated company
Their location
Members
Collaborators
Public universe data - You can browse almost any public universe to get a sense for the information that Worlds Unending collects and maintains about universes. This can include:
Notes
Character journal entries
Character sketches and biographies
Descriptions of fictional places and items
Pictures and other artwork
Maps
Comments and conversations about game world content
Analytic insights about game content
Other file attachments
Private universe data - Worlds Unending collects and maintains the same type of data for private universes that can be seen for public universes, except only specifically invited users may access private universe data.
Other data - Additionally, Worlds Unending collects analytics data such as page visits and information occasionally volunteered by our users, such as communications with our support team and survey information.
4 We will notify any affected account owners
It is our policy to notify users about any pending requests regarding their accounts or universes, unless we are prohibited by law or court order from doing so. Before disclosing user information, we will make a reasonable effort to notify any affected account owner(s) by sending a message to their verified email address providing them with a copy of the subpoena, court order, or warrant so that they can have an opportunity to challenge the legal process if they wish. In (rare) exigent circumstances, we may delay notification if we determine delay is necessary to prevent death or serious harm.
5 Disclosure of non-public information
It is our policy to disclose non-public user information in connection with a civil or criminal investigation only with user consent or upon receipt of a valid subpoena, civil investigative demand, court order, search warrant, or other similar valid legal process. In certain exigent circumstances (see below), we also may share limited information but only corresponding to the nature of the circumstances, and would require legal process for anything beyond that. Worlds Unending reserves the right to object to any requests for non-public information. Where Worlds Unending agrees to produce non-public information in response to a lawful request, we will conduct a reasonable search for the requested information. Here are the kinds of information we can produce:
With user consent - Worlds Unending will provide private account information, if requested, directly to the user (or an owner, in the case of an organization account), or to a designated third party with the user's written consent once Worlds Unending is satisfied that the user has verified his or her identity.
With valid legal process - If served with a valid subpoena, civil investigative demand, or similar legal process issued in connection with an official criminal or civil investigation, we can provide non-public account information, which may include:
Name(s) associated with the account
Email address(es) associated with the account
Billing information
Registration date and termination date
IP address, date, and time at the time of account registration
IP address(es) used to access the account at a specified time or event relevant to the investigation
Account or private universe settings (for example, which users have certain permissions, etc.)
User- or IP-specific analytic data such as browsing history
Security access logs other than account creation or for a specific time and date
Content in private universes
Contribution and collaboration records for private universes
Communications or documentation in private universes
Any security keys used for authentication or encryption
In the case of organization accounts, we can provide the name(s) and email address(es) of the account owner(s) as well as the date and IP address at the time of creation of the organization account. We will not produce information about other members or contributors, if any, to the organization account or any additional information regarding the identified account owner(s) without a follow-up request for those specific users.
Please note that the information available will vary from case to case. Some of the information is optional for users to provide. In other cases, we may not have collected or retained the information.
Under exigent circumstances - If we receive a request for information under certain exigent circumstances (where we believe the disclosure is necessary to prevent an emergency involving danger of death or serious physical injury to a person), we may disclose limited information that we determine necessary to enable law enforcement to address the emergency. For any information beyond that, we would require a subpoena, search warrant, or court order, as described above. Before disclosing information, we confirm that the request came from a law enforcement agency, an authority sent an official notice summarizing the emergency, and how the information requested will assist in addressing the emergency.
6 Cost reimbursement
We reserve the right to seek reimbursement for administrative costs associated with responding to requests for information, as allowed by law.
7 Data preservation
We will take steps to preserve account records for up to 90 days upon formal request from U.S. law enforcement in connection with official criminal investigations, and pending the issuance of a court order or other process.
8 Submitting requests
Please serve requests to World Unending LLC’s resident agent as identified in our Articles of Organization filed with the state of Maryland.
You may also send a courtesy copy to support@worldsunending.com.
Please make your requests as specific and narrow as possible, including the following information:
Full information about authority issuing the request for information
The name and badge/ID of the responsible agent
An official email address and contact phone number
The user, organization, universe name(s) of interest
The URLs of any content of interest
The description of the types of records you need
Please allow at least two weeks for us to be able to look into your request.
9 Requests from foreign law enforcement
As a United States company based in Maryland, Worlds Unending is not required to provide data to foreign governments in response to legal process issued by foreign authorities. Foreign law enforcement officials wishing to request information from Worlds Unending should contact the United States Department of Justice Criminal Division's Office of International Affairs. Worlds Unending will promptly respond to requests that are issued via U.S. court by way of a mutual legal assistance treaty (“MLAT”) or letter rogatory.
10 Questions
Do you have other questions, comments or suggestions? Please contact support@worldsunending.com.