In this section, we provide additional information about how we handle personal data about California residents as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal that is exempt under the CCPA.
A. Categories of Personal Data Under the CCPA
(Last Updated: 11 November 2021)
In this section we describe, generally, how we have collected and disclosed personal data about you in the prior 12 months (from the Last Updated date above). As noted above the data that we collect about you varies on your relationship with us. As described in sections “2.1 Individual Customers – A. Sources of Personal Data”, “2.2 Representatives of Our Existing Or Prospective Corporate Customers, Business Partners and Vendors – A. Sources of Personal Data”, “2.3 Website Visitors”, and “2.4 Visitors to Our Premises – A. Sources of Personal Data” above, we may collect personal data from the following sources:
- directly from you;
- social networks;
- operating systems and platforms;
- entities conducting networking events;
- publicly available sources;
- advertising networks;
- data analytics providers;
The table below identifies the categories of personal data (as defined by the CCPA) we have collected about you, as well as how we have sold or disclosed for a business purpose such information. For more information about the business and commercial purposes for which we collect, and sell personal data, please see sections “2.1 Individual Customers – C. Why Do We Collect Your Personal Data and What Are Our Lawful Bases For It”, “2.2 Representatives of Our Existing Or Prospective Corporate Customers, Business Partners and Vendors – C. Why Do We Collect Your Personal Data and What Are Our Lawful Bases For It”, “2.3 Website Visitors – C. Why Do We Collect Your Personal Data and What Are Our Lawful Bases For It”, “2.4 Visitors to Our Premises – C. Why Do We Collect Your Personal Data and What Are Our Lawful Bases For It” and “3. Who Do We Share Your Personal Data With” above.
Under the CCPA, a “sale” includes disclosing or making available to a third party personal data, in exchange for monetary compensation or some other value or benefit. While we do not disclose personal data in exchange for monetary compensation, we may make certain categories of personal data available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content.
We may share your information with other players (your in-game nickname and avatar only), our business partners, service providers, affiliates and subsidiaries, advertising and promotional agencies and networks, consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you.
| Personal Data Collected | Categories of Entities to Whom We May Disclose or Sell this Information | |
|---|---|---|
| Categories | Description | |
| Identifiers | Includes direct identifiers, such as email address, IP address, device ID and other online identifiers. |
- Affiliates and Subsidiaries - Other Players (username and profile only) - Service Providers - Business Partners - Advertising Agencies (Advertising identifier and IP address only) |
| Customer Records | Includes personal information, such as advertising ID in order to understand which others of our products and services individuals have purchased and/or played. | Affiliates and Subsidiaries |
| Commercial Information | Includes records of products or services purchased. | Affiliates and Subsidiaries |
| Usage Data | Includes ad views, browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads. |
- Affiliates and Subsidiaries - Service Providers - Business Partners - Advertising Networks |
| Geolocation Data | Includes location information about a particular individual or device. |
- Affiliates and Subsidiaries - Service Providers - Business Partners - Advertising Agencies - Advisors and Agents - Government Entities and Law Enforcement |
| Tech device data | Includes device language setting, OS version, device model, user agent (browser version), connection type, carrier etc. | Affiliates and Subsidiaries |
| Player activity data | Date and time when the user has opened the app, finished the tutorial, in-game progress, etc. |
- Affiliates and Subsidiaries - Service Providers |
California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to your personal data:
Do-not-sell (opt-out): to opt-out of our sale of your personal data. While we may “sell” personal data as defined by the CCPA, we do not sell personal data about California consumers who we know are younger than 16 years old.
Right of deletion: to request deletion of their personal data that we have collected about you and to have such personal data deleted (without charge), subject to certain exceptions.
Right to know: with respect to the personal data we have collected about you in the prior 12 months, to require that we disclose the following to you (up to twice per year and subject to certain exemptions):
- categories of personal data collected;
- categories of sources of personal data;
- categories of personal data about you we have disclosed for a business purpose or sold;
- categories of third parties to whom we have sold or disclosed for a business purpose your personal data;
- the business or commercial purposes for collecting or selling personal data; and
- a copy of the specific pieces of personal data we have collected about you.
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising your rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA requests through one of the following methods:
- Through the game; or
- By contacting us via as set forth in the Who is Responsible for Processing Your Data and How to Contact Us section above.
When you submit any request, we will take steps to verify your request by asking you some questions about in-game experience (such as current level, the name of the in-game pet, etc) and matching the information provided by you with the information we have in our records. You must answer the questions to verify your request. In some cases, we may request additional information in order to verify your request or wh ere necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us via as set forth in the Who is Responsible for Processing Your Data and How to Contact Us section above. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
For more information about our privacy practices, you may contact us as set forth in the Who is Responsible for Processing Your Data and How to Contact Us section above.