Scope

The titles are available to users all around the world. Accordingly, throughout the document, we try to harmonize our approach and the language of the privacy policy as much as possible. However, sometimes we refer to specific laws that require further disclosures. For example,  whenever you see throughout the policy the annotation “The GDPR angle”, it means that the purpose of such section is to satisfy the transparency requirements of the General Data Protection Regulation (the “GDPR”), and therefore it applies only to personal data (as defined by the GDPR) associated with devices who we deem to be located in the European Economic Area, United Kingdom, or Switzerland. If you are a resident of California, Virginia, Connecticut, or Colorado, please see “State Privacy Rights” section of this privacy policy for information related to privacy laws in these states.

Information We Collect

Information collected through our Titles, and information provided to us by advertising and analytics partners:

• Identifiers:
1. Advertising ID – Advertising ID refers to the Google Advertising ID (“GAID“) on Android devices, or ID For Advertising (“IDFA“) on iOS devices. The Advertising ID is a resettable persistent identifier generated by Android or iOS that allows online advertising companies to recognize a device across apps, for advertising purposes. Additional information about how to limit our use of the Advertising ID can be found under “How to Control Information”.
2. IP address of the device.
3. A unique ID generated by our advertising partners to recognize a device in a specific Title.
4. ID of a device which is unique only to our Titles.
• General technical information about a device – Technical information such as:
1. The device type and language, operating system name and version.
2. The device’s time zone.
3. The amount of free memory on the device.
4. The name and version of the Title.
5. Battery status.
6. The name of the mobile carrier.
7. The device’s internet connection type (e.g., Wi-Fi).
• Activity in connection with the Title: Transactions and in-app purchases made in the Title, progress or movement in the Title, and in-game events.

Information received from advertising and analytics partners:

• Campaign information – An indication if an ad of a Title was viewed or clicked.
• The total amount of revenues received as a result of advertising served to a specific device.

How We Use the Information We Collect:

We use the information we collect mainly to provide services to players of our Titles. In addition, we use the information for the following purposes:

• to improve and optimize the Titles and our players’ experiences;
• to provide players with information about our Titles, including in-game updates, new Titles, and promotional offers;
• to provide technical support;
• to protect the safety and well-being of our players;
• to prevent fraud or potentially illegal activities;
• to manage and deliver advertising, including for the purpose of analytics, measuring the effectiveness of ads, limiting the number of ads served, generating aggregated reports, and attribution;
• to administer rewards, or other promotional activities or events sponsored or managed by us or our business partners;
• to conduct marketing campaigns across our advertising and marketing partners, including campaigns that use audience lists created based on player interactions with the Titles;
• to comply with our legal obligations, resolve any disputes we may have with players, and to enforce our agreements with third parties;
• to conduct research.

The GDPR Angle:

Under the GDPR, we rely on the following legal basis for the processing of personal data:

• We process personal data for providing services to players of our Titles for the performance of our contract with them.
• We process personal data for the purposes of preventing fraud or potentially illegal activities, protecting our rights and property, serving advertising (except for personalized advertising), conducting marketing campaigns (except for audience lists based campaigns), improving and optimizing the Titles, providing information and promotional offers to players of our titles, administering rewards and conducting research, based on our legitimate interests.
• We, or our advertising partners, may process personal data for the purpose of serving personalized advertising, game usage analytics, or conducting marketing campaigns based on audience lists and creating such audience lists, if we, or our advertising partners, obtained that player’s consent.
• We may also process your personal data for compliance with applicable legal obligations.

Maximum Information Retention Period:

We store information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy policy, for a maximum period of one year from its collection. In some circumstances we may store information for longer periods of time, for instance when the information is required for us to establish or exercise our rights or to defend against legal claims.

How We Share Information:

We share information with:

Other advertising partners – for the purpose of receiving, or delivering, advertising campaigns from such advertising partners.

Our corporate affiliates – from which we receive services, such as IT, security, storage, and other internal operations.

Advertisers – for the purposes of attribution.

Analytics partners – for the purpose of receiving analytics services.

Service providers – We share your information with our service providers for the purpose of receiving services such as fraud detection and prevention, analytics, reporting, and storage.

We may also disclose information if we have a good faith belief that disclosure of such information is reasonably necessary to:

1. Comply with any applicable law, regulation, legal process or governmental request.

2. Enforce our agreements and policies, including investigations of potential violations thereof.

3. Investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues.

4. Establish or exercise our rights to defend against legal claims.

5. Prevent harm to the rights, property or safety of us, our users, yourself or any third party.

6. Collaborate with law enforcement agencies or in case we find it necessary to enforce intellectual property or other legal rights.

7. When we are undergoing any potential or actual change in control, including by means of merger, acquisition, or purchase of all or substantially all of our assets.

How to Control Information:

Collection of device data – Updated versions of iOS, and Android, enable you to control how apps can collect the Advertising ID. please follow the below instructions:

iOS devices (iOS 14+): go to Settings > Privacy > Tracking > Allow Apps to Request to Track. Please note that if you use more than one device, you need to opt-out separately in each device

Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/1660762 (under Mobile Controls). Please note that if you use more than one device, you need to opt-out separately in each device.

The GDPR Angle:

Withdraw consent – You have the right to withdraw the consent you provided to us from within each of our Titles (this will affect only our processing within the specific Title), or by following the instructions above on how to control collection of device data (this will affect our processing of data in all our Titles on your device).

Third-Party Services

Our services may link to other websites or mobile apps. Please be advised that we are not responsible for the privacy practices of such other websites or mobile apps as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or mobile apps and we shall not be responsible for any use of such websites and/or mobile apps.