Update, July 12th: this article has been updated to reflect comments made at the July 12th ton hall meeting at which Tilia Inc., and its role with regards to Second Life. A summary of that event, with audio extracts and video will be available in this blog soon.
Update, July 2nd: Linden Lab have started a new forum thread designed to directly address questions. Answers to questions will be placed in the original post in the thread to save having to scroll through question. The new thread can be found here: Official Tilia Q&A Forum Thread.
Update: some 90 minutes after this article was published, Linden Lab issued a further forum post on the subject. Among other clarifications, this further reiterates that L$ purchases, L$ balances, use of L$ to pay tier or Premium fees will all not be affected by these changes.
Also, as clarifications are still being given, some of the wording in this blog post may be revised to match LL’s feedback so as to maintain the accuracy of the information given here. However, do please keep an eye on Lab posts to the forum thread, as additional information, separate to the points I’ve highlighted below may also be given.
On Monday, July 1st, Linden Lab issued a blog post announcing important changes to how Second Life accounts are to be handled with regards to the Lab’s subsidiary, Tilia Inc (which the blog post officially introduces for the first time) and credit processing.
Tilia Inc is a wholly owned subsidiary of Linden Lab, which was established in 2014/15, and focused on payments and the compliance work associated with operating virtual economies. Since its formation, the company has been involved in becoming a registered Money Transmitter throughout the United States, and many SL and Sansar users may have had some awareness of its existence as the Tilia Inc., logo appears on both the SL and Sansar web pages related to L$ account purchases and Sansar account management.
The blog post issued by Linden Lab, Important Changes to your Second Life Account – Introducing Tilia, should in particular be read in full and carefully noted by anyone who currently withdraws funds from Second Life through the credit process mechanism. This following is merely a short summary of the key points:
- On August 1st, 2019, Tilia Inc., will assume responsibility for managing users’ USD denominated accounts, which will be referred to as their Tilia Account.
- This means that users with US Dollar accounts and / or who cash-out (“credit process”) money from Second Life, will be required to agree to the Tilia Terms of Service and Privacy Policy. Doing so will automatically create a Tilia Account that will be associated with the user’s Second life account and use the same user name and password.
- Most importantly: users wishing to process a credit – that is, withdraw money from Second Life via their US dollar account – after August 1st, 2019 must be prepared to supply the following information directly to Tilia Inc: name, address, date of birth, and social security number (or government-issued identification for non-US citizen).
- Note that if you have previously supplied this information to Linden Lab, you may still have to re-supply it to Tilia Inc.
- This information should only need to be supplied once, and will be retained on file by Tilia Inc., (as is currently the case through Second Life at the moment)
- Some users may be required to provide additional information to complete a transaction.
- Again, only those cashing out of their USD balance are required to meet the ID verification requirements.
- These changes should not impact the average time it takes for credit to be processed (around 3-5 working days) for most SL users, once the required identification documentation has been verified.
- The fees for inactivity mentioned in the blog post, etc., are still TBD, but again, they only apply in cases where USD have been cashed out, but the account has been dormant (i.e. no cash-out / no logging-in) for 12+ months. They do not affect L$ balances.
- These changes do not impact or change the purchase and use of Linden Dollars with Second Life or on the Marketplace. So you do not need to provide personal information in order to buy L$.
- Additional information can be found in the Lab’s official Tilia Inc FAQ.
The blog post has already led to a growing forum thread on the matter, which voices some genuine confusion on matters, coupled with no small amount of misunderstanding. This prompted the Lab to add further clarification, and additional replies many be forthcoming from LL over the next day or so to try to address additional concerns / answer further questions. Note that I cannot address specific concerns or answer questions posted to this blog, as I do not represent Linden Lab.
As an aide, I first wrote about Tilia Inc., almost five years ago. At that time, I lot of what I had to say was highly speculative. However, there is now more to say and consider – but to avoid conflating my commentary about Tilia Inc., with news of this announcement, I’ll leave that to a separate blog post.
Inara Pey: Living in a Modemworld 
“Stop polishing the brass rails and rearranging the deck chairs,” said Captain Smith. “Let’s start a bank!”
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Or…
“OK we have significant expertise in money handling and transmission and the handling of token-based micro-currencies that others are probably going to want. Let’s take that experience, build it into a business and see if we can leverage it for revenue. If it works, it might eventually help us to offer passengers a better cruising experience on our flagship!”
Kinda depends on how you’re looking at the glass (to thoroughly mix analogies!).
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It seems clear that all SL users have to get (or activate) a Tilia account, as we all have to agree to the terms to continue using SL into August.
I have read through the LL post and also searched the Tilia terms but an aspect of the Inactivity Fee seems unclear:
Given that “L$ purchases, L$ balances, use of L$ to pay tier or Premium fees will all not be affected by these changes. ”, will my Tilia account not become inactive automatically if I don’t cash out?
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Further to this someone on the forum has said that the inactivity fee only applies if a US dollar balance is left in the account https://community.secondlife.com/forums/topic/439384-tilia-takes-over/?do=findComment&comment=1929675
Having read the terms again it says it applies… “If you have funds in your Stored Value Balance”. It was not initially clear to me this meant US dollars and not a L$ balance.
LL should make this clearer and not just buried in the terms in my opinion.
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“Some one said” – the Lab actually clarified that point in the first of their replies in the Forum thread, linked to in the article.
I’m actually a little surprised over the manner in which some people got bent out of shape over parts of this; to me it was perfectly evident the changes a) only apply to any USD account balance held by a SL user; b) would most significantly impact those who use credit-processing to pull moee out of SL. Ergo, I never saw the announcement or the fees applying to anything other than “dormant” USD balances. My questions are more around the actual schedule of fees, etc., which somewhat unfortunately, people are being told to “wait and see”.
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OK, so by “someone” I meant ‘LittleMe Jewell’ in the comment I linked to directly.
RE: “to me it was perfectly evident the changes a) only apply to any UAD account balance held by a SL user;”
To be honest I got a little bit lost because the link in your post took me to a comment by yourself and I was unable to find the LL update itself when browsing on my phone yesterday. I have found that Linden Lab comment now, a long way further down the page from ‘LittleMe Jewell”s comment on page 7. I’m not always the best at taking in large amounts of information on first pass, feels like a lot to take in here.
But for sure your blog post helped to clear things up so thank you 🙂
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“I got a little bit lost because the link in your post took me to a comment by yourself and I was unable to find the LL update itself when browsing on my phone yesterday”
Ah, my bad… the link was defaulting to the top of the page, rather than the comment. My fault, it was heading towards 4:00am my time when the Lab issued the 2nd update, so I must’ve mis-copied the link, and in my need for bed, didn’t test it prior to hitting Publish. Corrected.
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No worries at all, and thanks again 🙂
I was using my phone, it was taking a long time to scroll and I gave up before getting that far down the page! Probably would have found it easily on my laptop 🙂
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“It seems clear that all SL users have to get (or activate) a Tilia account, as we all have to agree to the terms to continue using SL into August.”
– Yes, as per the 2nd bullet point, although I should have perhaps framed that point a little better / clearer myself.
Account inactivity, etc., covered above.
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From the same page seven post you referenced at the top of your article it says:
“In general, most Residents will not need to resubmit the information if it has been previously provided. However, there may be some instances where Tilia may need to collect and verify the documentation again. ”
So your statement about having to supply the personal info again appears to be incorrect :D. Just letting you know.
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Yup.. some of the later clarifications did that – clarify, hence referencing them 🙂 . The article’s bullet points were based on the original blog post. I will be endeavouring to revise that wording to match LL’s statements as I can – but do have other work to take care of as well 🙂 .
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I doubt I shall ever have enough gained from Second Life to ever want to “cash out”, but I’ve seen past hassles about compliance affecting non-US residents, and the weaknesses of the past seem to be continuing. Linden Lab sometimes seems to struggle with the idea of any of their customers being outside the USA, and when somebody asked about the effects of the GDPR on Tilia the response was, at best, vague.
But I am biased. I have had experience of professionals in a business area misinterpreting standard contracts, and having to pay lawyers to tell me “No, you can’t do what they told you to do.” Some of the wording in the Tilia Terms of Service inclines me to wonder if any layman can give the informed consent expected under GDPR.
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There is a lot of misunderstanding about the GDPR on the forum thread that isn’t helping – such as claims that the data on EU SL users “must” / “can only” be stored in Europe – which is incorrect. The GDPR does not limit the sorting of data pertaining to EU nationals to servers in the EU. It applies to
However, the right of access to data held against you, your right to review that data, your right to have that data corrected, your right to have that data deleted (even if it means doing so effectively denies you access to said service). This isn’t clear in the Tilia Inc privacy policy – LL requires people click through to the Lab’s core privacy policy and then scrolling through it. This linking is also why some on the forums might be getting confused as well.
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A little off topic BUT….I wonder is LL has to abide by the General Data Protection Regulations (GDPR) for non EU citizens and allow me access to (change) data they have held against me? I am still worried about info I gave when signing up for SL account which I need to change/verify (so if I get locked out for any reason, I can prove who I am).
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Yes, they do. The relevant details can be found here:
Linden Lab Terms of Service – Privacy and Your Personal Information
These Terms of Service encompass Second Life, Sansar, Blocksworld and Tilia Ince (the latter’s Terms of Service now reference this fact clearly).
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I read Tilia’s FAQ, and what REALLY bothers me is the demand for my SOCIAL SECURITY NUMBER as “proof of identity.” That is WAY intrusive; LL already has my RL name, contact info and credit card number. There is NO reason Tilia has any right to my SSN. I don’t need to provide my SSN if I’m making a purchase on Amazon.com, transferring money between bank accounts and PayPal, or making any other online transaction that “crosses state lines or national borders.” Even medical offices can’t ask for SSNs. Unless Tilia drops the demand for SSNs, I will be seriously considering whether to get rid of all the SL land I own and drop all premium accounts. BTW, I also have accounts in seven virtual worlds outside of SL, and NONE of them have made such demands for personal info.
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First off, Tilia Inc only requires this information where users are cashing out USD amounts from their Second Life accounts. It *does not* apply if you are simply *buying* Linden Dollars and spending them in-world. Nor does it apply to any L$ balance you have associated with your account.
So, if you are *not* cashing-out USD amounts from Second Life, there is no requirement for you to provide your SSN (or any other ID information beyond what the Lab already has on file for you).
“I read Tilia’s FAQ, and what REALLY bothers me is the demand for my SOCIAL SECURITY NUMBER as “proof of identity.” That is WAY intrusive;”
Actually, no it isn’t, given the circumstances for which it is required – that of cashing out real USD amounts from SL.
Remember, up to US $65 million is cashed out from SL in the course of a year – that’s a lot of money flowing out of a single “game” platform, one guaranteed to raise eyebrows in places like the US Treasury’s FINCen (who regard the L$ as a virtual currency with real-world value). As such, there are going to be questions around risks of money laundering, fraud, etc., (again, the money is betransferred both across state in the US and to places around the world.
Hence, Linden Lab has been working hard for several years now to ensure it can demonstrate that at both the US state and federal level, it is acting within the legal requirements to ensure such volumes of money are correctly handled and compliant with all state and federal laws related to the transfer of money. Tilia, really, is the outcome of all that work: it is a legally-certified Money Transmitter, a sub-set of Money Services Businesses (MSBs) that are governed by federal law 18 USC § 1960, and is in compliance with the laws of the 49 US states that regulate Money Transmitters (Montana beng the only exception).
This actually requires that they collect and hold valid means of identification from those withdrawing money from them platform – and perhaps the most valid form of ID in the United States in this regard *is* the SSN (hence why you are required to provide your SSN when opening a bank account, for example). It certianly isn’t something the Lab (through Tilia) is doing just for the sake of being intrusive.
“Unless Tilia drops the demand for SSNs, I will be seriously considering whether to get rid of all the SL land I own and drop all premium accounts.”
Again, you only need to supply the information if you *cash out* real money from SL.
“BTW, I also have accounts in seven virtual worlds outside of SL, and NONE of them have made such demands for personal info.”
This could be for a variety of reasons – do they allow cashing out of real USD value? If so, is their in-world currency seen by the likes of FinCEN as a virtual currency having real USD value? And so on. Just because W, X and Y hasn’t done something, doesn’t actually mean Z is somehow “wrong” for doing it; it’s a matter of, among other things, circumstance, scale and volume – and even security – theirs and yours.
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Reblogged this on KULTIVATE.
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