Privacy Policy

Effective Date - 22 November, 2022

Sophun Games Ltd. (“Sophun Games”) is committed to protecting the privacy of its users (“users” or “you”). In this Privacy Policy, “Sophun Games” refers to Sophun Games Ltd. and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to Sophun Games as “we” or “us”. This Privacy Policy has been created to inform you about how Sophun Games, as the controller of your personal data, manages, makes decision in relation to, collects, stores, uses and protects the personal data you provide. This Privacy Policy applies whenever you use our “Services,” which means our games and applications, products, services, content, websites operated by Sophun Games. Also, this Privacy Policy describes how you can access and update that personal data. Please note that, unless stated otherwise, the scope of this Privacy Policy is limited only to the personal data collected by Sophun Games through your use of the Services. By using the Services, you acknowledge the use of your personal data as outlined in this Privacy Policy. Sophun Games may amend the Privacy Policy from time to time.

Information Collected

Sophun Games' primary objective in collecting user information is to provide and enhance its Services, and to enable users to enjoy its Services. When you install any of its Services, Sophun Games may collect and record the information you provide to Sophun Games, whether through the Services themselves, or through social networks or other third party services ("Account Information"). We may collect information about you directly from you and from third parties, as well as automatically through your use of our Websites, Applications or Services.

Information We Collect Directly From You and As You Play Our Games and Information We Collect About You From Facebook, or Google or other platform. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide the data that is necessary to provide a product or feature, you may not be able to use that product or feature. The data we collect depends on the context of your interactions with Sophun Games, the choices you make, including your privacy settings, and the products and features you use. When you log into our mobile application through your relevant account, you will be asked to enter your relevant email address and password. Facebook or Google controls the information collected from you during the log-in process; Sophun Games does not control the information that Facebook or Google collects from you. When you use any of our Applications (whether our mobile application or if you access our Facebook or Google application), we will collect the following information: (i) your Facebook or Google basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook or Google account); (ii) your email address; (iii) posts to your Wall; (iv) posts in your news feed; and (v) other Facebook or Google data at any time even if you are not using Facebook or Google. Please note, if you allow Sophun Games to have access to this information, then Sophun Games will have access to this information even if you have chosen not to make that information public. For information about how Facebook or Google or other platforms may disclose your information, including any information you make public, please consult the Facebook or Google or other platform Privacy Policy. We have no control over how Facebook or Google or other platforms use or disclose the personal data you provide to it. We store the information that we receive from Facebook or Google, or other platforms along with other information that we collect from you or receive about you. We also collect information you provide to us and the content of messages you send to us, such as the feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.

Information We Collect Automatically. Cookies.

Like many websites, Sophun Games may use "cookies" to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Services may send cookies to a computer or a mobile device when a user accesses or views the Services. Information contained in a cookie may be linked to personal data for purposes such as improving the quality of Sophun Games' service, tailoring recommendations to interests, and making the Services easier to use. Third party advertisers on the Services may also place or read cookies or other technologies on your browser, and those practices are subject to their own policies. We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.

For more information on how to limit the types of cookies you allow, please see “Opting out of Cookie Tracking” section.

The information types collected in accordance with the Services may vary depending on the activity, and may include:

Your name;

Your social network or third party service user identification number; Your mobile device’s unique identifier (UDID);

Transaction identifiers for purchases; Your email address;

Your profile picture; Your phone number; or

Any other relevant information included in your application, social network or other online profile. Additionally, Sophun Games may acquire information from you through:

Your access and participation in message boards on a Service;

The contents of your Customer Support requests and messages; or

Your purchase of a virtual product of any type. Please note that because a third party site manages the purchases of virtual goods offered by the Services, Sophun Games does not have access to your credit card details or any other billing information.

Sophun Games may collect information about your use of its Services both in the course of game play and software usage. Sophun Games may also invite you to share information about yourself, which may include but is not limited to:

Your age or date of birth; Your gender;

Information about the hardware you may own;

Your favorite websites, friend information and fan pages; or

Any other information included in your application, social network or other online profile.

Other information Sophun Games may collect includes your language, zip code, area code, location, and the time zone where the Services are used, as well as information about your computer, mobile device, software, platform, incident data, Internet Protocol (IP) address, network Media Access Control (MAC) address and connection, browser type, browser language, referring pages, exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity, so that Sophun Games can better understand customer behavior and improve its products, services, and advertising. The Service may also record game play information such as your game session duration or your high scores. In addition to the information collected as described above, you may choose to share additional information about yourself throughout the Service, such as on message boards and in games. Any actions you perform with other players are considered public, and are solely at your discretion. If non-personal data is collected for an activity that also requires personal data, Sophun Games may combine your non-personal data with your personal data in an attempt to provide you with a better user experience, to improve the value and quality of the Services, and to analyze how its Services are used. Sophun Games may also receive either non-personal or public information from third parties in connection with market and demographic studies and/or data that Sophun Games may use to supplement personal data provided directly by you.

Payment Information

For Sophun Games' policy regarding the purchase of “virtual items”, “coins” or other “virtual currency”, please see Sophun Games' Terms of Service. When you play Sophun Games' games or access any of our other Services on connected third-party applications or platforms (like Facebook, Apple, Google, etc), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, Sophun Games does not receive your financial information (like credit card numbers), but may receive non-financial information related to your purchases, like your name, approximate physical location, and the items purchased.

The information Sophun Games receives depends on the Sophun Games' game you’re playing and the third-party application.

Customer Support Correspondence

When you ask for help from our Customer Support team, we may collect and store the contact information you give them (i.e, your name and e-mail address, phone number), information about your game play or activity on our Services, and your social network or service user identification number (if any). We will also store the communications you have with our Customer Support team and any additional information in those communications in order to provide support and improve the Services.

How Sophun Games Uses Your Information

Sophun Games uses your information to fulfill your specific requests, purchase orders, and to send you purchase confirmation and other account-related information. In carrying out these purposes, we combine the data we collect to give you a more personalized experience. However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number. In addition, the personal data you provide will allow Sophun Games to send you messages regarding, amongst other things, new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest. You may opt out of these communications at any time. Sophun Games may also use personal and non-personal data, both individually and combined together, to better understand the behavior and preferences of its customers, to troubleshoot technical problems, to serve static and dynamic advertising, to enforce its Terms of Service, to ensure proper functioning of its products and services, as well as to help improve Services and their content. In addition, Sophun Games may combine non-personal data with personal data, such as an email address, to administer loyalty programs, tailor its offerings, web pages or game play experience to you. By use of friend finder tools, whether directly through the Service or through a social network or gaming service, you acknowledge that use of these friend finder tools will help you find your contacts and will also allow your contacts to associate your Service account (and related gaming entitlements, including games played) with your social networking profile and/or email address. Your resulting friends’ list will be subject to this Privacy Policy. If you choose to use a referral service to "tell a friend" about the Services, Sophun Games may ask you for your friend’s name and email address. Sophun Games will send your friend an email on your behalf or a text message inviting him or her to visit the relevant site or check out the Services. Sophun Games stores your friend's name and email for a short period for the sole purpose of sending this email, and for redundancy checking,

to be sure that your friend does not receive multiple copies of the same email message. Sophun Games does not keep or use this information for any other purpose. If you enter into a sweepstake, contest, or similar promotion, Sophun Games may use the information you provide to administer those programs. Your participation in tournaments or other online gaming events is conditional upon you granting Sophun Games permission to collect, use, store, transmit and publicly display statistical data, such as your scores, rankings and achievements, generated through your participation. In all cases of data access and collection, the information you provide will not be disclosed, rented, loaned, leased, sold, or otherwise voluntarily distributed to unaffiliated third parties other than in the circumstances described in this Privacy Policy, and will be used solely for the purpose of providing you with and improving the Services and for any other purpose stated herein.

Sophun Games will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that Sophun Games no longer uses your information, contact Sophun Games at the email address provided in the Contact Us section below. Note that there may be instances where Sophun Games is legally required to retain your information.

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:

1. you have provided your consent to us using the personal data;
2. our use of your personal data is in our legitimate interest as a business - in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in "Your rights" section below;
3. our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you, including the terms and conditions which apply to your use of the Services;
4. our use of your personal data is necessary to comply with a relevant legal or regulatory obligation.

Legitimate Interests, you may object to that processing by contacting us (see "Your rights" section below).

Security of your information

The personal data that you provide to Sophun Games is stored and protected by protocols and procedures designed to ensure industry-standard security of such data such as firewalls and data encryption. However, no server, computer or communications network or system or data transmission over the internet can be guaranteed to be 100% secure. As a result, while Sophun Games strives to protect your personal data, Sophun Games cannot ensure or warrant the security of any personal data you transmit to Sophun Games or through the Services.

By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security privacy, and administrative issues related to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you.

Access through Social Network Services or Mobile Devices or Platforms

By accessing the Services through a social network, mobile device or other third party platform or service, or by connecting to such a third party network, platform or service via the Services, you are acknowledging that Sophun Games will collect, store, and use in accordance with this Privacy Policy any and all information that you agreed that the social network, mobile device or other third party platform could provide to Sophun Games through the social network/mobile device/third party platform Application Programming Interface (API) based on your settings on the third party social network, mobile device or platform. Your acknowledgment commences when you connect with the third party network, platform or service via the Services, and/or when you connect with the Services, or “accept” or “allow” (or similar terms) the Services to access your information through a social network, mobile device or other third party platform or service. Sophun Games may also collect or receive information about you from other Service users who choose to upload their email contacts. This information will be stored by Sophun Games and used primarily to help you and your friends connect. If you play Sophun Games’ games on your mobile device, in addition to your device identifiers, we may also collect:

1. the name you have associated with your device;
2. your telephone number;
3. your country;
4. your specific geolocation;
5. your mobile contacts;
6. information about Sophun Games and other third-party apps you have on your device.

If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password.

Third Party Service Providers

Sophun Games may employ third party companies and individuals to facilitate its Services, to provide the Services on its behalf, to perform tasks (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services, etc.), or to assist Sophun Games in analyzing how its Services are used. From time to time, Sophun Games employs third party contractors to collect personal data on its behalf to provide email delivery, product, prize or promotional fulfillment, contest administration, or other services through the Service. When requesting these services, you may be asked to supply your name, mailing address, telephone number and email address to its contractors.

Sophun Games may ask some third-party contractors, such as credit agencies, data analytics or market research firms, to supplement the personal data that you provide to Sophun Games for its own marketing and demographic studies, so that Sophun Games can consistently improve its sites and related advertising to better meet its visitors' needs and preferences. To enrich its understanding of individual customers, Sophun Games may tie this information to the information you provide to it. If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.

Message Boards and Chat Rooms

Note that certain information you post and communicate through the Services or a third party site or service is public information for which you have no expectation of privacy. You may choose to disclose information about yourself in the course of contributing user generated content to Sophun Games sites or Services or in its chat rooms, blogs, message boards, user “profiles” for public view, or in similar forums on its sites through mobile services and/or through third party sites or services. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality. You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. Please see Sophun Games’ Terms of Service or the Application End User License Agreement at Terms of Service (as applicable) on this point, and for other guidelines about posting content through any Service.

Information You Generate Using Our Communication Channels

You may be able to take part in certain activities on our Services that let you communicate or share information not just with Sophun Games, but also with other Sophun Games’ players. These include:

1. participating in player forums and message boards;
2. posting public comments to other players' profiles or gameboards;
3. sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts;
4. chatting with other players;

You acknowledge that we may access in real-time, record, remove and/or store archives of these communications, comments, photos and drawings on Sophun Games' servers to make use of them to protect the safety and well-being of our players and Sophun Games' rights and property in connection with Sophun Games' Services; to conduct research; to operate, improve, personalize and optimize our Services and our players' experiences, including through the use of analytics; and to manage and deliver contextual advertising.

Browser Use

Note that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Sophun Games has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

Reasons We Share Personal Data

We share your personal data in accordance with this Privacy Policy to complete any transaction or provide any product you have requested or authorized. When you provide payment data to make a purchase, we will share the payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction. In addition, we share personal data among Sophun Games-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described “Third Party Service Providers” section. For example, companies we have hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Additionally, Sophun Games may sell, transfer or otherwise share some or all of its assets, including your Personal data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. In the event that Sophun Games undergoes a business transition, like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may transfer all of your information, including personal data, to the successor organization in the transition. We will make reasonable efforts to let you and other players know of the business transition before transferring your personal data. Finally, we will access, transfer, disclose, and preserve personal data, when we have a good faith belief that doing so is necessary to:

1. comply with applicable law or respond to a valid legal process, including from law enforcement or other government agencies;
2. protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;
3. operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks;
4. establish, exercise or defend legal rights and claims.

Your Consent

Where personal data is processed on the basis of your consent, you have the right to withdraw your consent at any time by contacting us or otherwise using other mechanisms provided to you. The effect of withdrawing your consent will be that your information will no longer be used for the purpose which was previously based on consent. Withdrawing your consent does not affect the lawfulness of processing carried out prior to the withdrawal of your consent.

Friends and Other Players

The Services support and often encourage you to interact with other players. If you play through a social network or register through a social network, your social network friends will see your name, profile photo and descriptions of your game activity. Similarly, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity, communicate with you within our Services, and view your game profile, which may include your name or a “game name” and your profile photo. Other players may also be able to send you game requests or even friend requests.

Third Party Advertising Including Tailored Advertising and Analytics

We do not actively share personal data with third party advertisers for their direct marketing purposes unless we notify you to the contrary prior to such disclosure. When advertisers or ad networks place ads in our Services, they may collect or we may share the following types of information from within our Services:

1. performance data (e.g. number of clicks on an advertisement);
2. information about you and other players collectively that is not intended to specifically identify you;
3. certain technical information (for example, IP addresses);
4. your social network ID;

and other contextual data about your game play (for instance, your level). The information collected may be used to offer targeted advertising (behavioural advertising), and/or undertake web analytics. Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time. Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by Sophun Games or the social network through which you are playing Sophun Games’ games. If you do not want to receive tailored in-application advertisements from third parties, please see "Your rights" section.

Third Parties Operating Under Their Own Policies

We may share collected information with third parties operating under their own policies for the purposes of developing and delivering our Services, displaying advertisements, conducting analysis or research and for measuring advertising campaign performance.

For example, some of Sophun Games’ games or applications may be made with Unity software and/or using Unity services. If that is the case, Unity may access and operate information about you and your use of our Services (e.g. “Monetization Services Data” as it is defined in the Unity Terms of Monetization Services) as contemplated in the terms and conditions for Unity services (available at https://unity3d.com/legal) and as set out in the Unity Privacy Policy (available at https://unity3d.com/legal/privacy-policy). Please review terms and conditions for Unity services and Unity Privacy Policy to learn more about its data processing practices, use of cookies, opt-out instructions for their services and other similar procedures.

Also some of our applications may use RTB House technology. Please review RTB House privacy policy available at https://www.rtbhouse.com/privacy-center/services-privacy-policy tolearn more about its data processing practices.

We may work with AppLovin to deliver ads in our mobile applications. For more information about AppLovin’s collection and use of your information visit: https://www.applovin.com/privacy/

Your Rights

Subject to certain exemptions, and in some cases dependent on the legal basis which we rely upon for the relevant processing activity (see “How Sophun Games Uses Your Information” section), you have certain rights in relation to your personal data. If you wish to exercise any of these rights, please contact Sophun Games at contact@sophun.games. In some cases, Sophun Games may ask you to submit additional information (for example, your first name, last name, your social network ID for the social network from which you access our Services, etc.) in order to identify you as the user of Sophun Games’ Services and data subject before responding to your requests. We reserve the right to charge a fee or refuse to comply with a request where permitted by law, for example if your request is manifestly unfounded or excessive. To the extent permitted by applicable data protection laws, the response period to your request may be extended where necessary, taking into account the complexity and number of the requests.

Access and Correction

You can receive confirmation from us if about whether we are holding personal data about you and can receive access to a copy of the information. You can also correct and complete incorrect information.

Deletion and Restriction

You can request that we that we temporarily or permanently stop processing all or some of your personal data or demand the deletion of your personal data (subject to certain exemptions). You can request the deletion of your Account Information by dissociating or removing the Sophun Games application from your social network or third party service account in accordance with the instructions provided by the social network or third party service.

Data Portability

You have the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service, but only in relation to personal data used on the basis of consent or the performance of a contract (see “How Sophun Games Uses Your Information” section).

Right to Object

You can withdraw your consent at any time and also have the right to object to our reliance on our legitimate interests as the basis of our processing of your personal data that impacts your rights. Right to complain to supervisory authority You have a right to lodge a complaint with your local supervisory authority for data protection if you have concerns about how we are processing your personal data.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

Manage Information We Get from a Third-Party Application

To manage the information Sophun Games receives about you from a third-party application or platform where you play our games, like Facebook, Google, Apple etc. you will need to follow the instructions for the third-party application for updating your information and changing your privacy settings. To review and update information associated with your Sophun Games game profile in certain games, visit the “settings” page in that game. You also can manage some aspects of information collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.” Once Sophun Games receives your information from a third-party application or your mobile device, that information is stored and used by Sophun Games in accordance with this Privacy Policy. You may access and update that information as described herein.

Opting Out of Geolocation

If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device's settings for the relevant application or the “settings” page for the relevant game.

Opting Out of Promotional Emails from Sophun Games

If you want to stop receiving promotional e-mails from Sophun Games, click on the "unsubscribe" link in any promotional email from Sophun Games. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective.

Opting Out of Other Communications

When you install our apps on your mobile device you can choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.

Opting Out of Third-Party Tailored Advertising

If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising, you may visit the following websites:

1. Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
2. Your Online Choices UK website for EU-based advertising.

These opt-out tools are provided by third parties, not Sophun Games. Sophun Games does not control or operate these tools or the choices that advertisers and others provide through these tools. In addition, if you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Sophun Games. Sophun Games does not control or operate these tools or the choices that advertisers and others provide through these tools. Please note that you may still receive advertisements from third parties within Sophun Games’ games even if you opt out of tailored advertising but they will not be based on your activity across unrelated web sites or apps.

Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Most internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to reject cookies, while you can still use Sophun Games Services, your access to some functionality and areas of our Services may be restricted and you may lose some of the features and functionality of our Services because Sophun Games cookies are necessary to track and enhance your game activities. You can find further information on managing or rejecting cookies for different web-browsers on www.aboutcookies.org or the settings of popular Internet browsers:

Cookie settings in Chrome

Cookie settings in Firefox

Cookie settings in Opera

Cookie settings in Internet Explorer

Cookie settings in Safari web and iOS

Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

Do Not Track. Currently we do not process or respond to web browsers’ “do not track” signals or other similar transmissions.

Your California Rights

If you are a California resident please review our California Consumer Privacy Act Notice below, which is incorporated as part of this Privacy Policy for California residents only.

Links

The Services may contain links to other websites or applications. The fact that the Services links to a website or application, or presents a banner ad or other type of advertisement does not mean that Sophun Games endorses or authorizes that third party, nor is it a representation of any affiliation with that third party. If you click on a link to a third-party site or application, including on an advertisement, you will leave the Sophun Games site you are visiting or application you are running, and will go to the site or application linked to.

These third party websites and applications may place their own cookies or other files on your computer or mobile device, and may collect data or solicit personal data from you. Other sites and applications follow different rules regarding the use or disclosure of the personal data you submit to them. Because Sophun Games cannot control the activities of third parties, it cannot accept responsibility for any use of your personal data by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as Sophun Games. You are therefore encouraged to read the privacy policies or statements of other websites and applications you visit before providing any personal data.

Children Policy

Unless written otherwise, you may not use our Services if you are under 13 years of age (or under 16 years of age, if you are located in the EEA and Switzerland, or under the age of majority where you are located) (collectively, “Children”), in which case you must not use any of our Services, or submit personal data in the Services or to Sophun Games (for example, your name, address, telephone number, or email address). Sophun Games does not knowingly collect personal data from Children. Children may not register for an account or provide any personal data to Sophun Games. Sophun Games respects the privacy of parents and Children, and is committed to complying with the Children’s Online Privacy Protection Act ("COPPA"). If a parent believes that his or her Child has submitted personal data to Sophun Games, he or she can contact us via email:contact@sophun.games. If Sophun Games learns that a Child has provided it with personal data, Sophun Games will take steps to delete such information as soon as possible. We recognize the importance of safeguarding the privacy of Children, and encourage parents to check and monitor their children's use of online activities regularly. By using our Services, you represent and warrant that you are a person who is over the minimum legal age to consent to the collection and processing of personal data under applicable law where you are located or whose parent or legal guardian have acknowledged and understood our Terms of Service and Privacy Policy. You agree that you will not knowingly allow any Child to use or access the Services without a parent or legal guardian supervising him or her.

Contacting Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to contact@sophun.games.

Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Kingdom. Disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the UK Courts although Sophun Games retains the right to bring proceedings against you for breach of this Privacy Policy in your country of residence or any other relevant country.

16 Great Queen Street, Covent Garden, London, United Kingdom WC2B 5AH.

California Consumer Privacy Act Notice

Effective January 1, 2020

Scope of Notice

This California Consumer Privacy Act Notice ("Notice") supplements the information contained in our Privacy Policy. The provisions contained in this Notice provide additional information to a our Privacy Policy bout how we collect, use, disclose and otherwise process personal information of our users ("consumers", "players" or "you") who are individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 ("CCPA"). For such consumers, provisions of this Notice supersede any other possibly divergent or conflicting provisions contained in our Privacy Policy.

Unless otherwise expressly stated, all terms in this Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA. This Notice is in compliance with the CCPA.

Categories of Personal Information Collected

"Personal Information" in this Notice, as in the CCPA, refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a certain consumer or household.

In particular, the following categories of Personal Information we collected within the last twelve (12) months, the sources of collection, and the business purposes for collection are indicated in the list below.

We may use and/or disclose the Personal Information we collect for one or more of the following business or commercial purposes:

1. Customer service
2. Payments processing
3. Operate our business and games
4. Internal analytics and reporting
5. Customer support
6. Internal research
7. Game mechanics or functionality
8. Facilitate players' social interactions
9. Debugging existing intended functionality
10. Product development/improvement
11. Maintaining and enhancing service
12. Auditing Player interaction & transactions
13. Marketing, including direct marketing (email, etc.)
14. Advertising
15. Detecting/Protecting against security events
16. Player acquisition.

Disclosure of Personal Information

In the last twelve (12) months we have disclosed the following categories of Personal Information: Identifiers, California Customer Records (Cal. Civ. Code 1798.80(e)), Protected Classification Characteristics, Commercial Information, Internet/Network Information, Geolocation Data, Inferences.

As described in the Privacy Policy, we share Personal Information within Sophun Games group of companies and with a variety of recipients for business and commercial purposes. In addition to the categories of recipients identified in the Privacy Policy, we disclose Personal Information to, or allow access to Personal Information by, the following categories of recipients:

1. Customer Service Vendors;
2. Cloud Storage Providers;
3. Payment and Auditing Processors;
4. Security Safety Vendors and Service Providers;
5. Social Media Services;
6. Advertising and Marketing Partners.

We also may share Personal Information with your social network friends and other users, and successor organization in the transition of Sophun Games’ sale, merger, acquisition, etc. Sophun Games does not "sell" Personal Information about our players as most people would typically understand that term. However, we may allow certain third-party advertising partners to collect information about consumers through our games and our website for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. To the extent this practice may be interpreted to constitute a "sale" under the CCPA, please see our Opt-Out section below for more information (Right to Opt-Out of Sale of Personal Information – Do Not Sell My Info)

Online Advertising

The following describes the categories of Personal Information we may sell for business purposes. These are also the categories of information we might have sold in the past twelve (12) months.

When we serve you personalized video ads, we may sell identifiers such as resettable identifiers provided by your mobile device’s operating system with ad networks, social media companies and other third-party businesses in the ad ecosystem. The typical resettable advertising IDs are GAID (Android) and IDFA (Apple) and they are considered Personal Information under the CCPA. These third parties may use your Personal Information:

1. to serve relevant ads on our site, on other websites or mobile apps, or on other devices a player may use;
2. to personalize content; and
3. to perform other advertising-related services such as reporting, attribution, analytics and market research.

These third parties may use this Personal Information for their own commercial purposes in accordance with their own privacy policies, which may include providing this information to additional third parties, including other advertising networks.

Financial Incentives

In each of the following financial incentives, which we offer on some, but not all games, we may grant you virtual currency or other virtual items across the variety of our games that you play. Such items and currency are virtual and have no monetary or cash value and cannot be used outside of the applicable game. For further details, refer to section “Virtual Items” of the Terms of Service.

You have a right to withdraw from the financial incentive at any time. For example, you may choose not to watch in-game advertisements or disconnect Facebook account or Apple ID through user settings. Also you may submit a consumer request as described below.

Your California Privacy Rights Right to Know

You have the right to request the disclosure of certain information to you about our collection and use of your Personal Information over the twelve (12) months preceding your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of Personal Information we have collected about you;
2. The categories of sources from which the Personal Information is collected;
3. Our business or commercial purpose for collecting Personal Information;
4. The categories of third parties with whom we share, sell Personal Information, if any; and
5. The specific pieces of Personal Information we have collected about you.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

1. Delete your Personal Information from our records; and
2. Direct any service providers to delete your Personal Information from their records. Please note that we may not delete your Personal Information if it is necessary to:
3. Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
4. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
5. Debug to identify and repair errors that impair existing intended functionality;
6. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
7. Comply with the California Electronic Communications Privacy Act;
8. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
9. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
10. Comply with an existing legal obligation; or
11. 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 Sale of Personal Information – Do Not Sell My Info

You have the right to opt-out of sale of your Personal Information. As described above we do not "sell" Personal Information about our players as most people would typically understand that term. But given that some practices may be interpreted to constitute a "sale" under the CCPA, you have the rights as described below.

To exercise your right to opt-out, please contacting us at contact@sophun.games.

Once you make an opt-out request, you may change your mind and revoke your opt-out request any time by contacting us at contact@sophun.games.

If you do not want to receive interest-based in-application advertisements on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.” To Limit Ad tracking on iOS Devices please follow the link Limit Ad Tracking. To opt out of personalized ads on Android devices follow the link Opt-out of Personalized Ads.

To prevent third parties from delivering tailored web and mobile web advertising, you may also visit the opt-out tools provided by the Advertising Alliance and the Digital Advertising Alliance, or download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with controls regarding the collection and use of cross-app data for behavioral advertising.

These opt-out tools are provided by third parties, not Sophun Games. Sophun Games does not control or operate these tools or the choices that advertisers and others provide through these tools.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

1. Deny goods or services to you;
2. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
3. Provide a different level or quality of goods or services to you; or
4. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

Right to Designate an Authorized Agent to Submit CCPA Requests on Your Behalf

You may also designate an authorized agent to exercise these rights on their behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.

How to Exercise Your Rights under CCPA

You may make a verifiable consumer request to exercise your right to know and right to deletion under the CCPA by:

1. contacting us at contact@sophun.games with the subject line "California Rights Request"; or
2. submitting your request via Support or Contact us section within the game. The verifiable consumer request must:
3. provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
4. describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will verify your request by attempting to match two or three identifying pieces of information you provide us in connection with the request you make, to Personal Information we already maintain about you. We may ask to verify your request through the account's existing authentication methods (if applicable). We will take all reasonable precautions to verify your identity in connection with fulfilling our responsibilities under the CCPA. We will evaluate each request based on the individual submitting the request and the category of information related to the request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. Although we try to limit the Personal Information collected in connection with a request to exercise the right to know and the right to deletion to that Personal Information, certain requests may require us to obtain additional Personal Information from you. We may use verification by email or other methods to verify your identity and request.

We will confirm receipt of your verifiable request within ten (10) business days and provide information about how we will process your request. We endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Minors Under Age 16

We do not sell Personal Information of players we know to be less than sixteen (16) years of age, unless we receive affirmative authorization (the "Right to Opt-In") from either the minor who is between thirteen (13) and sixteen (16) years of age, or the parent or guardian of a minor less than thirteen (13) years of age.

Shine the Light

You may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us using the methods described above.

Updates

We may update this Notice from time to time. When we make changes to this Notice, we will change the date at the beginning of this Notice. If we make material changes to this Notice, we may notify you by email to your registered email address, by prominent posting on our online services, or through other relevant communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. You are responsible for periodically checking this Notice for any changes.

Contact Us

If you have any questions, comments or concerns regarding this Notice, our Privacy Policy and/or practices, please send an e-mail to contact@sophun.games.