KingsIsle Privacy Statement

Last Updated: September 25, 2020

Please take the time to read this notice carefully

SCOPE AND YOUR AUTHORIZATION

This Privacy Statement ( "Privacy Statement" ) applies to KingsIsle Entertainment, Inc. ( "KingsIsle," "we," "us," or "our" ) mobile games and apps and any other games/environments that collect data and display or link to this Privacy Statement (collectively, "Mobile Games/Apps" ). This Privacy Statement does not apply to (•) websites, games, products, services or other environments that do not display or link to this Privacy Statement or that have their own privacy statements, or (•) information collected from you offline (unless you are a California resident, in which case our Supplemental Privacy Policy for California Consumers applies to information collected from you offline as well, as noted below).

This Privacy Statement describes (•) who we are and how to contact us, (•) the information we collect from or about you through or in connection with our Mobile Games/Apps, and how and why we use this information, (•) with whom we may share your information, (•) the choices you can make regarding how we collect and use your information, (•) how we keep this information secure, (•) the transfer and/or storage of your information in the United States, (•) the collection and use of information from children, (•) important information regarding links to third-party websites and your ability to share information with other users of our Mobile Games/Apps, (•) how you can correct or update your information, and (•) our processes for updating this Privacy Statement if necessary.

We take your privacy rights very seriously and we will only use your information as described in this Privacy Statement. By using this Mobile Game/App or otherwise providing information to us, you agree to the collection, use, sharing and transfer of your information as described in this Privacy Statement. As a result, please be sure to read this Privacy Statement carefully before using our Mobile Games/Apps or submitting information to us.

If we ever change the way in which we collect, use, share or transfer your information, we will first update this Privacy Statement to reflect the changes. Please check this Privacy Statement periodically for updates because your continued use of our Mobile Games/Apps constitutes acceptance of such changes. See the "CHANGES TO THIS PRIVACY STATEMENT" below for more information.

If you reside in the United States, you must be at least 13 years old to use our Mobile Games/Apps. If you reside in Europe, you must be at least 16 years old to use our Mobile Games/Apps.

CALIFORNIA RESIDENTS: If you are a California resident, please review our Supplemental Privacy Policy for California Consumers (“California Privacy Policy”) below. The California Privacy Policy provides additional information regarding our collection (both online and offline) and use of personal information about California consumers, and describes the privacy rights granted to California consumers under California law. The California Privacy Policy applies to California residents only.

ABOUT US AND HOW TO CONTACT US

KingsIsle is based in Texas, United States, and develops and publishes high quality online games that appeal to a wide audience. We are responsible for and control the information collected from or about you in connection with our Mobile Games/Apps subject to this Privacy Statement. You can contact us at any time if you have any questions:

KingsIsle Entertainment, Inc. (•) P.O. Box 5997 (•) Round Rock, TX 78683, United States (•) E-mail: Privacy@KingsIsle.com

For residents located in the EU:

We value your data subject rights under GDPR and have appointed GDPR-Rep.eu as our representative according to Art. 27 GDPR, through which you can easily submit privacy related requests. If you want to make use of your data subject rights, please visit: https://gdpr-rep.eu/q/17904698, or contact GDPR-Rep.eu at the following address:

GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o KingsIsle Entertainment Incorporated
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 17904698

INFORMATION WE COLLECT / USE OF YOUR INFORMATION

KingsIsle collects information that can be used to identify or contact a particular person (we refer to this type of data as "personal data" ). Personal data may also include information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our Mobile Games/Apps and which if combined with certain other information could be used to identify you.

The information we collect includes information you actively provide to us through our Mobile Games/Apps, certain information collected passively through your use of our Mobile Games/Apps, and information collected from other third-party sources. In addition, we may allow select third-party partners to passively collect certain information from you through your use of our Mobile Games/Apps.

Information You Actively Provide

On our Mobile Games/Apps, we collect information from you when you choose to share it with us for the following purposes:

  • Create an Account. To play any of our Mobile Games/Apps, you may create an account with us. To do so, you may be required to provide us with certain information which may include, but not necessarily be limited to, (•) a username and account password, and (•) any other information requested at the time information is collected. We use this information for purposes of (•) managing your account, (•) providing you with customized Mobile Game/App content, targeted offers, and advertisements, (•) contacting you regarding polls and surveys, (•) addressing problems and reviewing the usage and operations of our Mobile Games/Apps or business, and improving our content, products, and services, (•) fulfilling and tracking orders, and processing payments, (•) providing you with access to forums and chat rooms, and (•) responding to your inquiries. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Mobile Games/Apps, improve your experience while using our Mobile Games/Apps, promote our products and services, and provide customer support.
  • Respond to Polls, Surveys, or Promotional Offers. From time to time, we may ask you to participate in a poll or survey, or provide you with promotional offers. If you choose to participate in our polls and surveys, or select our promotional offers, you may be required to provide us with certain information which may include, but not necessarily be limited to, (•) poll and survey responses, (•) the promotional offers you select, and (•) any other information requested at the time information is collected. We use this information for purposes of (•) developing new products or services, and improving existing products and services, (•) addressing problems and reviewing the usage and operations of our Mobile Games/Apps or business, and (•) providing you with customized Mobile Game/App content, targeted offers and advertisements. The relevant legal basis under European law (where applicable) is our legitimate interest to improve your experience while using our Mobile Games/Apps, promote our products and services, develop new products and services, and better understand users and their preferences.
  • Purchase Our Products and Services. When you purchase goods or services through our Mobile Games/Apps, you may be required to provide us with certain information which may include, but not necessarily be limited to, (•) your name, (•) address, (•) telephone number, (•) e-mail address, (•) credit/debit card number and/or other payment information, and (•) any other information requested at the time information is collected. We use this information for purposes of (•) processing your payment and providing you with the purchased goods or services, (•) protecting the security or integrity of our Mobile Games/Apps and our business, (•) providing you with customized Mobile Game/App content, targeted offers and advertisements, and (•) contacting you.
  • Contact Us/Submit an Inquiry. Any time you contact us or submit an inquiry, you must provide us with certain information which may include, but not necessarily be limited to, (•) your name, (•) address, (•) telephone number, (•) e-mail address, (•) any information you choose to include when contacting us or submitting an inquiry, and (•) any other information requested at the time information is collected. We use this information for purposes of (•) responding to your questions or comments, (•) managing your account and relationship with us, and improving your experience when you use our Mobile Games/Apps, and (•) contacting you. The relevant legal basis under European law (where applicable) is our legitimate interest to provide, manage and optimize our products and services (including our Mobile Games/Apps), promote our products and services, provide customer support, develop new products and services, and better understand users and their preferences.

Information Collected Passively // Cookies and Other Tracking Technologies

As you navigate through our Mobile Games/Apps and participate in the gaming environment, other information may be passively collected through use of technologies which are common among mobile apps and mobile environments. These technologies include cookies, Web beacons (also known as pixel tags or clear GIFs), software development kits, and similar technologies. A "cookie" is a unique numeric code that is transferred to your computer or device to track your interests and preferences and to recognize you as a return visitor. A "Web beacon" is a transparent graphic image placed on a Website that enables the monitoring of things such as user activity and site traffic. "Software development kits" (also called SDKs) function like third-party cookies and web beacons, but operate in the mobile app environment where cookies and beacons cannot function as effectively. These technologies help remember your preferences on Mobile Games/Apps and allow us to bring you the content and features that are likely to be of greatest interest to you, on the basis of your previous activities on our Mobile Games/Apps. They also allow us to collect "clickstream" data which reflects activities on Mobile Games/Apps such as the features you visit and in what order.

The information collected through these technologies may include, but not be limited to, (•) Internet Protocol ( "IP" ) address, (•) type of web browser and operating system you use, (•) the name of your Internet Service Provider, (•) software versions, (•) course geolocation information (for example, based on IP address or location of cellular tower used for the connection), (•) the domain name from which you accessed our Mobile Games/Apps, (•) browsing behavior, such as the date and time you visit our Mobile Games/Apps, the areas or pages of our Mobile Games/Apps that you visit, the amount of time you spend viewing or using our Mobile Games/Apps, and the number of times you return to our Mobile Games/Apps, (•) e-mails or ads that you open, forward or click-through to our Mobile Games/Apps, (•) account and Mobile Game/App preferences, (•) social network or platform account and profile information, (•) device, advertising, or push token ID, and (•) MAC address. Within the gaming environment, we may also collect information on your in-game activities, character development and character interaction.

We use this information for purposes of (•) remembering your device, and personal preferences on Mobile Games/Apps, (•) bringing you content and features that are likely to be of greatest interest to you, (•) tracking accurately numbers of users or referring websites or advertisements to our Mobile Games/Apps, (•) remembering your personal selections, such as information that you have entered into data fields on our Mobile Games/Apps, answers that you have provided in response to our surveys, or sections of our Mobile Games/Apps that you visit frequently, (•) confirming whether you have read or clicked on certain e-mail communications we send to you so that we can make our communications more useful and interesting to you, (•) keeping track of your in-game activities, character development and character interaction, (•) improving our products and services, (•) allowing our Mobile Games/Apps to interact with third party social networks or platforms (where you have chosen to allow such interaction), (•) protecting the security or integrity of our Mobile Games/Apps and our business, and (•) addressing problems and reviewing the usage and operations of our Mobile Game/Apps, mobile environments or business.

The relevant legal basis under European law (where applicable) is—in addition to the legitimate purposes identified above—our legitimate interest to guarantee the stability and security of our Mobile Games/Apps, provide, manage and optimize our products and services (including our Mobile Games/Apps), improve your experience while using our Mobile Games/Apps, promote our products and services, provide customer support, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

Information Collected from Other Sources

We may obtain information about you from other sources, including commercially available sources, such as data aggregators and public databases. This information may include, but not be limited to, (•) name, (•) demographic information, (•) interests, and (•) publicly-observed data, such as from social media and shopping behavior.

Sign-In Services // Social Media

Our Mobile Games/Apps may allow you to log in using sign-in services such as Facebook Connect, Apple's Game Center, Google Play, Google +, Amazon, or an Open ID provider. These services will authenticate your identity and may provide you the option to share certain personal data with us such as your name, e-mail address, and photo to pre-populate Mobile Game/App forms. Once your identity has been authenticated, we may collect certain information such as the sign-in service used and a unique identification code associated with the sign-on service.

Our Mobile Games/Apps may also contain functionality which enables you to import profile information or contacts from third party services (e.g., LinkedIn, Facebook, Twitter, Gmail, FourSquare, Instagram, Vine, etc.) (collectively, "Third Party Social Media Accounts" ). If you choose to do this, you may have to log into the applicable Third-Party Social Media Account, using such account's username and password. The copy of the information received by us shall be subject to this Privacy Statement. However, any data maintained by such third-party service and your use of that third-party service will be subject to that third party's terms of use and privacy policy.

You may have the ability to share information from our Mobile Games/Apps to your Third Party Social Media Accounts (including, without limitation, by taking advantages of features such as the Facebook "like" button or "Share to Twitter" button appearing on our Mobile Games/Apps). Mobile Games/Apps that allow you to do this use social plugins (e.g., the Facebook "Like" button) to enable you to easily share information with others. When you visit our Mobile Games/Apps, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Mobile Games/Apps. If you are logged into the Third Party Social Media Account (e.g., Facebook) while browsing on our Mobile Games/Apps, the social plugins allow applicable social media websites to receive information that you have visited our Mobile Games/Apps. The social plugins also allow social media websites to share information about your activities on our Mobile Games/Apps with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our Mobile Games/Apps to your Facebook friends. Facebook Social Plugins also allows you to see your friends' Facebook activity on our Mobile Games/Apps. KingsIsle does not control any of the content from the social media plugins, but we do receive aggregated statistics, e-mail addresses, and profile information.

All such postings are also subject to the terms of use and privacy statement of the applicable third parties as well as the terms of this Privacy Statement. You should consider carefully what information about yourself you choose to share with others when you use your Third-Party Social Media Accounts.

The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Mobile Games/Apps, provide, manage and optimize our products and services (including our Mobile Games/Apps), improve your experience while using our Mobile Games/Apps, promote our products and services, provide customer support, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

Combining Information

We may combine the information we receive from and about you, including personal data and non-personal data collected through our Mobile Games/Apps, for any of the purposes discussed above, including but not necessarily limited to, (•) managing your account, (•) providing you with customized Mobile Game/App content, targeted offers, and advertisements, (•) contacting you regarding polls and surveys, (•) addressing problems and reviewing the usage and operations of our Mobile Games/Apps or business, and improving our content, products, and services, (•) fulfilling and tracking orders, and processing payments, (•) providing you with access to forums and chat rooms, (•) protecting the security or integrity of our Mobile Games/Apps and our business, (•) addressing problems and reviewing the usage and operations of our Mobile Game/Apps or business, (•) sharing game information across your devices and/or accounts, and (•) responding to your inquiries.

Information Collected by Our Ad Partners

We may also use third-party advertising partners to deliver advertisements on our behalf, place ads on our Mobile Games/Apps, measure and improve the effectiveness of ads and Mobile Games/App features, and control the frequency of ads. Some of these advertisers and ad networks may use technologies such as cookies and Web beacons, and SDKs (see the "Information Collected Passively // Cookies and Other Tracking Technologies" section above for more information) when they engage in these activities, which may send these advertisers and ad networks information such as your IP address, device ID, advertising ID, push token ID, MAC Address, your Internet Service Provider, the browser you used to visit our Mobile Games/Apps, and whether you have Flash installed. Some of these advertisers and ad networks also may use anonymous data, such as demographic data, received from third parties to assist in the delivery of advertisements to you. These advertisers and ad networks use this information to provide you relevant advertisements based on your online behavior, activities on our Mobile Games/Apps and on other third party sites, and demographic information relevant to your general location, so that the advertising you see on our Mobile Games/Apps more closely reflects your interests and needs. This information is also used for campaign performance tracking and player engagement with in-game ad tracking.

KingsIsle currently uses the following ad partners:

  • AppsFlyer. More information about AppsFlyer and its privacy practices can be found here. To opt-out from having data from your device sent to AppsFlyer, please click here.
  • Facebook. More information about Facebook and its privacy practices can be found here. To learn how can you control Facebook's use of cookies to show you ads, please visit here.
  • TapJoy. More information about TapJoy and its privacy practices can be found here.
  • Choozle.More information about Choozle and its privacy practices can be found here.

The relevant legal basis under European law (where applicable) is our legitimate interest to improve your experience while using our Mobile Games/Apps, promote our products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We will not sell or otherwise disclose personal data about you, except as described here.

  • Service Providers. In the course of doing business, we employ other companies and individuals to perform a variety of functions on our behalf. For example, we may provide your information to companies that host our Mobile Games/Apps or process credit card information. These service providers may have access to personal data about you if it is needed to perform their functions for us, but they are not authorized by KingsIsle to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.
  • Social Media. As discussed in the "Sign-In Services // Social Media" section above, you may have the ability to share information from our Mobile Games/Apps to your Third Party Social Media Accounts. Mobile Games/Apps that allow you to do this use social plugins (e.g., the Facebook "Like" button) to enable you to easily share information with others. When you visit our Mobile Games/Apps, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Mobile Games/Apps. If you are logged into the Third Party Social Media Account (e.g., Facebook) while browsing on our Mobile Games/Apps, the social plugins allow that social media websites to receive information that you have visited our Mobile Games/Apps. The social plugins also allow the social media website to share information about your activities on our Mobile Games/Apps with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our Mobile Games/Apps to your Facebook friends.
  • Ad Partners. Please see the "Information Collected by Our Ad Partners" section above.
  • Legally Required. We reserve the right to disclose information if required to do so by law or by a regulatory authority. We may also disclose your information as part of an investigation or enforcement action relating to improper or illegal conduct in connection with our Mobile Games/Apps, including, without limitation, any situations that may potentially involve threats to the safety or privacy of any person, misuse of Mobile Games/Apps or violation of our Terms of Use.
  • Sale or Bankruptcy. During the normal course of our business, KingsIsle may sell or purchase assets. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data provided through our Mobile Games/Apps in a manner that is consistent with this Privacy Statement.
  • Aggregated and Non-Personal Data. KingsIsle may maintain aggregate data or other non-personally identifiable information about you, such as usage statistics, online traffic patterns and user feedback. In addition to using this information for the purposes discussed above, KingsIsle may disclose this information to third parties without restriction.

YOUR CHOICES ABOUT HOW WE COLLECT, USE AND DISCLOSE INFORMATION

You have four categories of choices. These include:

  • Providing No Information. You may choose not to provide any personal data to KingsIsle by electing not to enter any personal data into a form or data field on our Mobile Games/Apps, and by not using any personalized services provided by our Mobile Games/Apps. However, many of our Mobile Games/Apps are available only to individuals who provide certain information.
  • Limiting Uses and Disclosures. Some KingsIsle Mobile Games/Apps may request your permission to use and disclose personal data about you in order to add you to our contact lists, to enable you to list yourself in a directory or a social media resource, and to identify and offer additional services and promotions that we believe you might find interesting. You can limit the use of personal data about you by checking or un-checking options provided at the time that you enter that information or that we may offer to you in the future. Additionally, you may change your communications preferences (such as to opt-out of communications you requested previously) by contacting us at the information contained in the "ABOUT US AND HOW TO CONTACT US" section above.
  • Limiting Tracking. Our Mobile Games/Apps do not limit, or provide a mechanism to limit, non-identifiable uses of tracking technologies. However, depending on the Internet browser you are using, or the type of mobile device, you may be able to control the use of certain tracking technologies, such as cookies and advertising identifiers, through your Internet browser or mobile device. Some Internet browsers enable you to limit or disable the use of cookies for individual websites. Other browsers allow you to select cookie settings for all websites that you visit. If you are concerned about the use of cookie technology, please read our section above on "Information Collected Passively // Cookies and Other Tracking Technologies" to understand the ways that KingsIsle uses tracking technologies. If you limit or disable cookies, certain functions of our Mobile Games/Apps may not work properly, including access to some of our registration-based Mobile Games/Apps. For more information on how to disable tracking for certain web browsers and mobile devices, visit http://allaboutdnt.com/.
  • If you would like to opt-out of the cookies set by other companies who deliver e-mail communications on our behalf or place KingsIsle advertisements on other websites, you may be able to do so by following the options provided by the Network Advertising Initiative at: http://www.networkadvertising.org/optout_nonppii.asp, the Digital Advertising Alliance at: http://www.aboutads.info/choices/, Apple at https://support.apple.com/en-us/HT202074, or Android at https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en).

If you reside in Europe, please visit here.

  • DO NOT TRACK SIGNALS: Our systems may not recognize Do Not Track (DNT) headers or similar mechanisms from some or all browsers.
  • You may also choose to prevent your mobile device's advertising identifier from being used for interest based advertising or you may reset your mobile device's advertising identifier. For iOS devices, you can manage your advertising preferences under Settings>Privacy>Advertising. For Android devices, you can manage your advertising preferences under Google Settings>Ads.
  • E-mail Communications and Newsletters. You may also opt out of receiving newsletters and other promotional materials from KingsIsle by notifying us at the information contained in the "ABOUT US AND HOW TO CONTACT US" section above.

SECURING YOUR INFORMATION

KingsIsle will take reasonable steps to protect your personal data, according to its sensitivity, as it is collected and transmitted between your computer or device and our online resources and servers, as well as to protect your personal data in our possession from unauthorized access, disclosure, alteration or destruction. It is your personal responsibility to secure your own copies of your passwords and related access codes for our Mobile Games/Apps.

CONSENT TO PROCESSING YOUR INFORMATION IN THE UNITED STATES AND ELSEWHERE

Our Mobile Games/Apps are owned and operated by KingsIsle in the United States, but the information you provide will be accessible to our affiliates, vendors, and suppliers in other countries. Furthermore, if you are visiting our Mobile Games/Apps from a country other than the United States, any information we collect or you provide will necessarily result in the transfer of information across international boundaries. The level of legal protection for such information is not the same in all countries; however, we will take the security measures described in this Privacy Statement in an effort to keep your information secure. By using our Mobile Games/Apps, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

IMPORTANT INFORMATION REGARDING CHILDREN

Our Mobile Games/Apps are intended for general audiences and we do not knowingly collect any personal data from children under the age of 13 (in the United States) or 16 (in Europe) on our Mobile Games/Apps.

LINKS TO THIRD-PARTY WEBSITES AND SHARING INFORMATION IN FORUMS
Links to Third-Party Websites

Our Mobile Games/Apps may contain links to other websites operated by third parties that may be of interest to you (including links embedded in advertising appearing on components of our Mobile Games/Apps or related applications). When you follow a link and leave our Mobile Games/Apps, you do so at your own risk because we do not control such third-party websites. In addition, different Websites have different privacy statements associated with the use of those sites. Please check the privacy statement of the specific website you are visiting to understand the privacy practices associated with that website. KingsIsle is not responsible for the content or privacy practices of third-party websites.

Public Forums

Our Mobile Games/Apps may also include forums, chat functionality or other features where you can exchange information or otherwise interact with other users of our Mobile Games/Apps. When you do so, you understand that all information transmitted will be made available to and accessible by KingsIsle and applicable users. You have no expectation of privacy in connection with such communications. KingsIsle is not responsible for whether or how such third parties utilize the information you post or share through such features.

YOUR RIGHTS

You have various rights with respect to the collection, use, transfer and processing of your personal data, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified by KingsIsle or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the contact information provided in the "ABOUT US AND HOW TO CONTACT US" section above.

Access Right

You have the right to obtain confirmation as to whether or not your personal data is being processed by KingsIsle. Where we are processing your personal data, you have the right to access the data and to obtain certain information about the processing of such data.

Right to Rectification

You have the right to obtain rectification of any personal data that is inaccurate or incomplete, including by means of providing a supplementary statement, subject to any limitations or exceptions under applicable law.

Right to Erasure

You have the right to have your personal data erased in certain circumstances, subject to any limitations or exceptions under applicable law.

Right to Restriction of Processing

If you reside in the European Union (or if otherwise required under applicable law), you have the right to restrict the processing of your personal data where one of the following applies:

  • The accuracy of the personal data is contested.
  • The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead.
  • KingsIsle no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims.
  • Where the processing is based on KingsIsle's (or a third party's) legitimate interest and you have objected to processing (as described below).

Right to Object

If you reside in the European Union (or if otherwise required under applicable law), you have the right to object (on grounds relating to your particular situation) at any time to the processing of your personal data for direct marketing purposes or where the processing is based on KingsIsle's (or a third party's) legitimate interest. When objecting to processing based on our legitimate interest, KingsIsle will no longer process your personal data unless KingsIsle demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Withdraw Consent

Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.

Right to Data Portability

If you reside in the European Union (or if otherwise required under applicable law), you have the right to receive your personal data, which you have provided to KingsIsle, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another entity without hindrance from KingsIsle, subject to any limitations or exceptions under applicable law.

Right Not to Be Subject to Solely Automated Decisions

If you reside in the European Union (or if otherwise required under applicable law), you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.

Right to Submit a Complaint to Supervisory Authorities

If you reside in the European Union (or if otherwise required under applicable law), you have the right to lodge a complaint with an applicable data protection authority. If you reside in Europe, you have the right to lodge such a compliant in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.

California Residents: If you are a California resident, please see our California Privacy Policy below for additional information regarding your rights under California law, including how to exercise such rights.

RETAINING YOUR PERSONAL DATA

We generally retain personal data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain information for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period.

CHANGES TO THIS PRIVACY STATEMENT

KingsIsle may update this Privacy Statement periodically. KingsIsle reserves the right to modify, add or remove portions of this privacy statement at its discretion. If we decide to change this Privacy Statement, we will post those changes at this Mobile Game/Apps so you always will know what information we gather, how we might use that information, and whether we will disclose it to anyone. If the changes we make to the Privacy Statement are material, we also may post a notice on the KingsIsle Website (www.kingsisle.com) prior to the effective date of the change, or, in some cases, may provide notice of the changes by e-mail.

This Privacy Statement was effective on, and last updated on September 25, 2020.

Supplemental Privacy Policy for California Consumers

Last updated: September 25, 2020

This Supplemental Privacy Policy for California Consumers (“California Privacy Policy”) provides additional information required under the California Consumer Privacy Protection Act (CCPA) regarding the personal information we collect from and about California residents, and describes the rights granted to California residents under the CCPA.

This California Privacy Policy applies to information collected from or about California residents only. This California Privacy Policy is broader in scope than our Privacy Statement because it applies to any and all personal information about California residents collected by KingsIsle, including personal information collected in connection with our Online Games and Services and Mobile Games/Apps, as well as personal information collected online and offline.

Definitions Specific to California Privacy Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to KingsIsle’s other Privacy Statements, including the following terms:

Personal information” (regardless of whether such term is capitalized or not) means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information obtained from government records or deidentified or aggregated consumer information.

Sell,” “selling,” “sale,” or “sold” (regardless of whether such terms are capitalized or not) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer‘s personal information by the business to another business or a Third Party for monetary or other valuable consideration.

Service Provider” means certain for-profit legal entities that process information on behalf of KingsIsle and to which we disclose your personal information for a defined business purpose pursuant to a written contract that prohibits this service provider from retaining, using, or disclosing your personal information for any purpose other than for the specific purpose of performing the services specified in the contract with us.

Third Party” means another business that collects or receives your personal information, other than a Service Provider.

All other capitalized terms used but not defined in this California Privacy Policy shall have the meanings ascribed in our Privacy Statements.

Personal Information Collection and Use

KingsIsle has collected the following categories of personal information about California consumers in the preceding twelve (12) months:

  • Identifiers and contact information, including full name, player/user ID, postal address, telephone number, email address, date of birth, account name, IP address, online identifier, social network or platform account username/handle, device ID, and mobile advertising ID.
  • Commercial information, including games played, in-app purchases and other products and services purchased, survey responses, content posted on forums and discussion boards, Online Games and Services preferences, Mobile Game/App preferences, in-game activities, character development and character interaction, and other purchasing and consuming histories and tendencies.
  • Financial information, including credit or debit card number and payment amounts.
  • Internet activity information, such as log data, browsing history, cookie data, referring/exiting URL, clickstream data, time spent on our Online Games and Services and Mobile Games/Apps, and other information regarding user interaction with our Online Games and Services, Mobile Games/Apps, other websites and apps, emails, and advertisements.
  • Geolocation data, including approximate or precise device location.
  • Physical/demographic information, such as age (or age group) and gender.
  • Photographs, such as a player/user profile photo.
  • Written signature, such as a signature on a parental consent form.
  • Inferences drawn from any of the information listed above to create a profile about a California consumer reflecting the individual’s preferences, characteristics, behavior, or abilities.

KingsIsle collects the categories of personal information identified above from the following categories of sources:

  • You (directly from consumer/user).
  • Parents and legal guardians.
  • Your computer and mobile device (automatically) when you visit or interact with our Online Games and Services and Mobile Games/Apps.
  • Social media platform providers.
  • Payment processors and other financial institutions.
  • Vendors who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
  • Vendors who assist with fraud prevention, detection, and mitigation.
  • Network advertising partners.
  • Mobile app store/marketplace providers (e.g., Apple, Google).
  • Vendors who assist with our information technology and security programs
  • Data aggregators and public databases.
  • Internet service providers.

KingsIsle collects the categories of personal information identified above for the following purposes:

  • Creating and managing your account.
  • Providing you with customized content, targeted offers, and advertisements.
  • Contacting you regarding polls and surveys.
  • Addressing problems and reviewing the usage and operations of our Online Games and Services, Mobile Games/Apps or business, and improving our content, products, and services.
  • Fulfilling and tracking purchases and processing payments.
  • Providing you with access to forums and chat rooms.
  • Responding to your inquiries and contact you.
  • Engaging in direct marketing activities, including to personalize your experience on our Online Games and Services and Mobile Games/Apps, and to deliver content and product offerings relevant to your interests, including targeted offers and ads through our Online Games and Services, Mobile Games/Apps, third-party websites and games, and via email or text message.
  • Maintaining the safety, security, and integrity of our Online Games and Services, Mobile Games/Apps, products, databases, and other technology assets.
  • Internal administrative purposes, such as auditing, data analysis, and research to improve our products, services, and customer communications. This includes processing for purposes of statistical analysis.
  • Developing new products or services, and improving existing products and services.
  • Remembering your preferences on our Online Games and Services and Mobile Games/Apps.
  • Tracking accurately numbers of users or referring websites or advertisements to our Online Games and Services and Mobile Games/Apps.
  • Keeping track of your in-game activities, character development and character interaction.
  • Allowing our Online Games and Services and Mobile Games/Apps to interact with third party social networks or platforms (where you have chosen to allow such interaction).
  • Identifying you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with our Online Games and Services, Mobile Games/Apps, and advertisements.
  • Comply with laws and regulations.
  • Monitor, investigate, and enforce compliance with and potential breaches of policies and procedures and legal and regulatory requirements.
  • Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons
  • Exercise or defend the legal rights of KingsIsle and its employees, affiliates, customers, contractors, and agents.

Personal Information Disclosures

In the preceding twelve (12) months, KingsIsle has disclosed for a business purpose the categories of personal information identified below to the associated categories of Third Parties listed.

CATEGORIES OF PERSONAL INFORMATION DISCLOSED TO THIRD PARTIES IN PRECEDING 12 MONTHS

CATEGORIES OF THIRD PARTIES TO WHOM
PERSONAL INFORMATION IS DISCLOSED

Identifiers and Contact Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Internet service providers.

Third Parties who deliver our communications, such as the postal service and couriers.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Other users/players.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Commercial Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Other users/players.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Financial Information

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Internet Activity Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Internet service providers.

Third Parties who deliver our communications, such as the postal service and couriers.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Geolocation Data

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Internet service providers.

Third Parties who deliver our communications, such as the postal service and couriers.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Physical/Demographic Information

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Mobile app store/marketplace providers (e.g., Apple, Google).

Other users/players.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Photographs

Social media platform providers.

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Other users/players.

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Written Signature

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Payment processors and other financial institutions.

Parents and legal guardians.

Consumer reporting agencies.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

Inferences

Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.

Network advertising partners.

Third Parties who assist with our information technology and security programs.

Third Parties who assist with fraud prevention, detection, and mitigation.

Parents and legal guardians.

Our lawyers, auditors, and consultants.

Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law.

KingsIsle does not sell personal information about California consumers. Without limiting the foregoing, KingsIsle has no actual knowledge that it sells the personal information of minors under 16 years of age.

Your California Rights

If you are a California resident, you have the following rights under the CCPA with respect to your personal information:

  • Right to Notice. Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it.
  • Right of Access (“Request to Know”). You have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of personal information disclosed or sold, and the categories of third parties with whom we shared or sold the personal information. You also have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
  • Right to Deletion (“Request to Delete”). You have the right to request that we delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right to Opt-Out of the Sale of Personal Information. KingsIsle does not sell your personal information as the term is defined based on our understanding of the CCPA. We have not sold any personal information to third parties for business or commercial purposes in the 12 months prior to the effective date of this California Privacy Policy.
  • Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.

You can exercise your rights by contacting KingsIsle as described in the Contact Us section below.

Request Verification

We value the security and confidentiality of your personal information. Therefore, if you submit a Request to Know or Request to Delete, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully. Along with your request, we will ask that you provide us with certain information previously collected from you, such as your email address, phone number, postal address, or other information as appropriate.

Authorized Agent

If you are making any of the requests above as an authorized agent, we will require notarized written authorization or a notarized Power of Attorney. Additionally, we will seek to verify your identify in the manners stated above (depending on the request type). To make a request using an authorized agent, please email us at Privacy@KingsIsle.com.

Additional Information

We will maintain records of requests that are made that include the date of request, nature of request, manner in which the request was made, the date of our response, the nature of our response, and the basis for any denial of the request if it is denied in whole or part.

You are not required to create an online account with us in order to exercise your rights.

Contact Us

If you have any questions or concerns about KingsIsle’s privacy policies and practices, please contact us at the contact information listed below:

U.S. Mail

KingsIsle Entertainment, Inc.

Attn: Privacy Department

P.O. Box 5997

Round Rock, TX 78683

United States

Email

Privacy@KingsIsle.com