Privacy Notice

Last Updated: June 6, 2024

You can find our previous Privacy Notice, effective November 16, 2022, here.

ZenLife Games Limited develops and publishes social games for the web and mobile devices. This Privacy Notice (this “Notice”) describes the ways ZenLife Games Limited (“Studio,” “us”, “our” or “we”) collects, stores, uses, discloses or otherwise processes personal information of our users (“users” or “you”) in connection with their use of our products or services, including our product offerings such as our website available at www.zenlifegames.com and Studio game(s) provided on a mobile platform or any other Studio product or service that posts or links to this Notice (each a “Service,” collectively, the “Services”). Additionally, this Notice describes the rights and choices concerning your information that may apply to you.

This Privacy Notice covers the following topics:

If you have questions regarding this Notice or our collection and use of personal information, please contact us as described in the “Contact Us” Section.

1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

When you interact with or use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services (e.g., information about how you interact with our Services) and sometimes we collect the personal information directly from you when you use our Services (e.g., information you give us when setting up your account or user profile). At times, we may collect personal information about you from other sources and third parties, including other players.

A. Information We Collect Automatically or From You Directly

Registration Information

We may offer you the option to complete a user profile that is visible to other Studio users (“Account”). If you create an Account, you may provide us your name, a username, e-mail address, a password and other information that helps us confirm that it is you accessing your Account. We may do this through in-game dialog boxes, which you may choose to skip. If you sign into the Services with Facebook Connect, we will collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards, head-to-head competition, and other similar features. Your username associated with your Account will be public and will be shown to other users. In addition, your username will allow others to access information on your user profile that is considered public or that you have designated as public in your user profile settings.

Address Book Information

We may also offer you the ability to choose to import your contacts or manually enter e-mail addresses so that you can locate your contacts and invite your contacts to join you in the Services. This information is typically collected through the use of third-party mobile device software development kits. If you choose to import your contacts or manually enter e-mail addresses, we will store those contacts for purposes of helping you and your contacts make connections through our Services. You are responsible for ensuring your sharing of this information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information.

Technical and Usage Information

When you access our Services, we may use cookies and other similar technologies to collect (i) certain technical information about your mobile device or computer system, including IP Address, mobile device ID (IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services, including the links, objects, products and benefits you view, click, or otherwise interact with (also known as “Clickstream Data”). Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. In connection with your use of certain Services, we will create and assign to your device an identifier that is similar to an account number. In addition, in certain circumstances, we may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or e-mail address. We may also infer your approximate geographic location based on your IP address.

Payment Information

When you order any good or service through the Services, including any virtual currency or virtual good, we collect certain non-financial transaction information related to these purchases, including what you purchased, the price, and the date. Your in-app purchase transactions are processed by third-party payment processors, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices), or Amazon (for purchases on Kindle devices). The third-party payment processors will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information to enable them to process your payment. The third-party payment processors may also retain this information to enable you to purchase additional items through our Services without having to re-enter your payment information each time. Please note third-party payment processors do not share your financial information, like credit card numbers, with us. In addition, please note that the third-party payment processors’ processing of transactions and collection and use of your personal information is governed by their terms of service and privacy policy, and purchases through these third parties may also be subject to additional policies. We encourage you to review the terms of service and privacy policies of those third parties to learn more about how they handle your personal information.

Information Collected by or Provided to Customer Support

When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game-play or activity on the Services, and your username or ID number. We will also store the correspondence and information within the correspondence that you choose to share with us.

Communication Preferences

We may collect information about your interests and communication preferences that you choose to provide, such as when subscribing to news or alerts.

Surveys, User Research Projects, Competitions and Promotional Events

If you choose to participate in, or fill out any forms relating to, Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, we will collect your contact information (such as your name, email, and phone number, address, and postal code) to enable you to participate in the activity and to allow us to communicate with you, as well as any other information that we request that you provide for purposes of the activities, including audio or video recordings, photos, and/or screen captures. In connection with Studio surveys and user research projects, we may also collect your opinions, responses to certain research questions, prompts, or surveys, and other personal information, consistent with the purposes of the Studio survey or user research project.

On occasion, we may also collect your shipping and billing information to send you certain rewards or incentives, such as if you are a participant in a Studio survey or user research project, a competition winner, or if you purchase our products or services. In addition, if you are a part of our event or promotion partner, we may also collect your personal information including your name, company email, and company address.

Please note that your participation in any Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, is completely voluntary.

B. Information We Collect From Other Sources

We may collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers, such as digital advertising companies; and (iii) social networking sites. We may combine this information with the information we collect from an individual directly.

C. Sensitive or Special Categories of Information

We typically do not request or seek to elicit sensitive or special categories of information, but you may choose to provide this information to us in connection with certain of the interactions described above, including when you ask for assistance from our Customer Support team. The meaning of sensitive or special categories of information varies by jurisdiction and it could include, for example, health, genetic or biometric data, or precise location information.

D. Information You Choose to Share on the Services

A number of our Services provide features including chat rooms, messaging services, and community and event forums for collaboration, peer connection, games, and information exchange purposes. Any personal information that you voluntarily choose to display on any publicly available portion of our Services, such as when you publish content, comments, or profile information, becomes publicly available and may be collected and used by others.

2. HOW WE USE YOUR INFORMATION

We use information collected through our Services for purposes described in this Notice or disclosed to you in connection with our Services. For example, we may use your information for:

Service Delivery

Create your Service accounts and allow access to our Services;
Identify and suggest connections with other Studio users;
Operate our Services;
Improve our Services;
Understand you and your preferences to enhance your experience and enjoyment using our Services;
Respond to your comments and questions and provide customer service;
Provide and deliver products and services you request;
Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Conduct and administer surveys, user research projects, competitions and promotional events that you participate in;
Prevent fraud or potentially illegal activities, and enforce our Terms of Use;
Enable you to communicate with other users; and
Fulfill any other purpose for which you provide personal information.

Marketing and Advertising

Deliver and target advertising and marketing and promotional information to you; and
Communicate with you (including via email and push notifications) about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners.

Research and Development

Create aggregate or anonymous information derived from the personal information we handle, which we may use and disclose for research, development and other lawful business purposes;
Link or combine personal information with other information we get from third parties to help understand your preferences and provide you better services; and
Analyze information to choose to provide to us in connection with Studio surveys and user research projects to gain insights into how users engage with our Services, to improve our Services, to consider developing new products or services, and other lawful purposes.

Compliance and Protection

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Protect our, your or others’ rights, privacy, safety, or property (including by investigating, bringing, making, or defending legal claims);
Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
Enforce the terms and conditions that govern the Services; and
Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Email or Push Notifications

We may occasionally send you email or push notifications through our Service to send you game updates, high scores and other service-related notifications that may be of importance to you, as well as to send marketing communications. You may at any time opt-out from receiving these types of communications by clicking on the “unsubscribe” link (or a similar link) at the bottom of our marketing emails or by turning them off at the device level through your settings.

3. SHARING OF YOUR INFORMATION

We may share information we collect with the following third parties for the specified purposes:

Category of Third Parties	Purpose(s) of Sharing	Categories of Personal Information
Service Providers	We may share your information with service providers that perform services on our behalf or enhance our Services, including platform providers, hosting services, customer support services, analytics services, and marketing partners.	Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies) Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies Internet or Network Information, such as information regarding interactions with a website, application, or advertisement Geolocation Data, such as city or county-level geolocation information Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above
Affiliates	We may share your information with our parent company(ies), affiliates, or subsidiaries.	Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies) Additional California Customer Records, such as address book information Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies Internet or Network Information, such as information regarding interactions with a website, application, or advertisement Geolocation Data, such as city or county-level geolocation information Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above
Payment Processors	We may share your information with third-party payment processors that process payments you make in our Services.	Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies) Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies
Your Specified Recipients	We may disclose your information to individuals or other third parties or publicly with your consent or at your direction.	Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies) Additional California Customer Records, such as address book information Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies Internet or Network Information, such as information regarding interactions with a website, application, or advertisement Geolocation Data, such as city or county-level geolocation information
Advertising Partners	We may share your information with advertisers, ad exchanges and other ad technology companies that require the data to select and serve relevant advertisements to you and others, and assist us in our marketing efforts, including as described in the Online Advertising section below.	Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies) Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies Internet or Network Information, such as information regarding interactions with a website, application, or advertisement Geolocation Data, such as city or county-level geolocation information Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above
Government Entities/Law Enforcement	We may share your information with law enforcement and public authorities, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.	Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies) Internet or Network Information, such as information regarding interactions with a website, application, or advertisement Geolocation Data, such as city or county-level geolocation information

** We may also share your information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us. In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, we may share your information (or it may be transferred) to our business transferees, successors, or assigns.

Because the specific information that we may share and our reasons for doing so vary depending on the circumstances, how long the information may be retained can also vary. As explained below, we and our affiliates, subsidiaries, agents, contractors, and service providers generally retain information for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless applicable law requires or permits a longer retention period.

4. ONLINE ADVERTISING

Interest-Based Advertising

To the extent we display advertising in our Services, with your consent as may be required by applicable law, we may share or we may allow online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time to enable them to play or display ads on our Services, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies, software integrations, or similar tracking technologies, which recognize the device you are using. We and our third-party partners use this information to try to make the advertisements you see online more relevant and tailored to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Such information includes the following:

Device make, model and operating system;
Device properties related to screen size & orientation, audio volume and battery;
Carrier;
Operating system;
Name and properties of mobile application through which the user interacts with the Services;
Country, time zone and locale settings (country and preferred language);
Network connection type and speed;
IP Address;
Keywords;
City- and/or country-level geolocation data;
Internet browser user-agent used to access the Services; and
Advertising ID (IDFA on iOS devices and GAID on Android devices).

A list of these advertising partners and their privacy policies is available at https://www.zenlifegames.com/third-party-data-recipients/. The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices. We encourage you to review those privacy policies to learn more about their data collection and use practices.

Social Media Widgets/Plugins

Our Service may include social media features, such as the Facebook button, Google, Instagram, Twitter, or other widgets or plugins. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. Your interactions with those features are governed by the privacy notices of those companies.

Cross-Device Linking

We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-parties who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

Opting-Out of Interest-Based Advertising

As described below, under certain conditions, you have the right to object and/or restrict the processing or handling of your personal information under applicable law.

Opt-Out through Device-Level Choices. You may limit data collection by third parties by visiting your mobile device settings and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”) or by exercising other privacy options in your device’s settings.

Opt-Out through Industry Consumer-Choice Platforms. You may also visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest-based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:

Please note that electing to opt-out will not stop advertising from appearing in your browser or applications or reduce the number of ads that you receive. You will still receive ads, but those ads may be less relevant to your interests. In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to apply your opt-out choices to that particular browser or device.

Please note that the opt-out tools described in this section are provided by third parties, not by us. We do not control and are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Opt-Out through Ads. You may also be given the option to opt-out of interest-based advertising through an icon available on the face of an ad served to you.

If you have any questions about these opt-outs or rights you may have under applicable law, you can contact us at [email protected] or by writing to us at the physical address in the “Contact Us” section.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Managing Cookies

As described in this Privacy Policy, we use cookies to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you.

Google Analytics and Advertising. We utilize certain forms of display advertising and other advanced features through Google Analytics, including, but not limited to, Remarketing with Google Analytics, the DoubleClick Campaign Manager Integration, Google Ads, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. To learn how you can opt-out of data collection by Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

You can also review your options to manage cookies by:

Opening the “Help” menu on the browser menu bar. Most browsers will tell you how you can disable or delete cookies.
Visiting your mobile device developer’s website or reviewing your device manual. Most mobile device developers will tell you how you can manage the settings on your mobile device to opt out of and/or delete cookies from your mobile device, or to limit the use of your advertising ID, reset your advertising ID, and/or opt out of targeted advertising.
Visiting https://optout.networkadvertising.org and/or http://youronlinechoices.com, or if you are in the EU http://www.youronlinechoices.eu/, for choices to opt out of advertising. You can also click on the AdChoices logo within an advertisement (where available).

If you reject all cookies, you may not be able to use certain features of our websites and other products and services.

5. SECURITY OF YOUR INFORMATION

We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.

However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.

6. DATA RETENTION

We store data on servers in the U.S. or any other country in which the Studio or its affiliates, subsidiaries, agents or contractors or service providers maintain facilities. We retain your personal information for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information pursuant to applicable law. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When we no longer require your personal information, we will look to delete, destroy, or anonymize it pursuant to our typical procedures. If this is not possible (for example, because your personal information has been stored in backup archives), then we will apply security measures to your personal information and isolate it from any further processing until deletion or destruction can occur pursuant to our typical procedures. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

7. CHILDREN’S PRIVACY

The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services. If we learn that we have unintentionally collected personal information from a child, we will delete that information. If you believe that we might have collected personal information from or about a child, please contact us at [email protected].

8. THIRD-PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party. Please note that the Studio is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.

9. TRANSFER OF PERSONAL INFORMATION OUTSIDE YOUR COUNTRY

We may transfer information that we collect about you (detailed in Section 1) to other countries or jurisdictions where we or our service providers and vendors operate for our legitimate business purpose, including our cloud storage provider located in the United State of America, and advertising partners listed above. The data protection laws and rules in these countries may be different from those in the country where you live. In these cases, we will provide appropriate safeguards to protect your personal data. This may include applying the standard contractual clauses approved by the European Commission for transfers of personal data or other safeguards recognized by applicable laws and regulations.

If you have any questions regarding potential transfers of personal information outside of the country where you live or would like to exercise your data rights in relation to such transfers, please contact us at [email protected] or write to us at the address set forth in the “Contact Us” section.

10. MANAGING YOUR INFORMATION

Subject to certain exemptions, you can manage information we receive about you, and you may have additional rights as explained in the “Specific Provisions for Certain Non-U.S. Users” and the “Specific Provisions for Certain U.S. Multistate Users.”

Information-Related Requests — If you wish to review, change, or correct the information we have about you, or to withdraw your consent to the processing of your personal information, you may send an e-mail to [email protected] making this request.

Deleting Your Account — If you would like us to delete your information, you may send an e-mail to [email protected] and place “Delete My Account” in the subject line or request to delete your information inside the app you are using. Please note that, if you proceed with the deletion of your account, you will no longer have access to the game account or services associated with your account. Other steps you should take should you wish to delete your account include disassociating your Facebook account from our mobile games, if applicable, and deleting the game from your mobile device. Please note that if you ask us to delete your account, all your progress in the game and any unused virtual items will be lost and we may not be able to restore them in the future. Please note that your information, for example records pertaining to payments or customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Acting through an Authorized Agent or Representative — In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

Response Time — In accordance with applicable law, we aim to respond to a consumer request as soon as possible after receiving that request and any necessary verification. If we require more time, we will inform you of the reason and extension period in writing.

11. SPECIFIC PROVISIONS FOR CERTAIN NON-U.S. USERS

These additional provisions apply to individual residents of those countries outside of the United States that have enacted comprehensive consumer privacy laws, including the European Union General Data Protection Regulation, the United Kingdom Data Protection Act, and each of their associated regulations, as well as amendments to those laws or additional consumer privacy laws that have been enacted or may be enacted in the future.

This section addresses the specific disclosure requirements under those laws and provides additional information about how we collect, use, share, and otherwise process personal information, the rights of covered consumers in relation to that personal information, and the ways to exercise those rights.

ZenLife Games Limited, having its registered address at c/o Calmco Secretarial Ltd., Dimostheni Severi, 21, Anna Court, 5th Floor 1080 Nicosia Cyprus, is the “data controller” responsible for the processing of personal data in connection with our Services. This means that we determine and are responsible for how your personal information is used.

Your Privacy Rights

Depending upon applicable law, you, your legal representative, and/or your next of kin have certain legal rights in connection with your personal information that we hold. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. Subject to certain exemptions, you have the right to:

Access and Correct Your Personal Information. At any time, you may request to access the personal data that we hold about you. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete, or updated, then please provide us with the necessary information to correct it.

Erase or Restrict Access to Your Information. You may request to delete or restrict access to your personal data under certain conditions. To the extent permitted by applicable law, we may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

Transfer Your Personal Data (Otherwise Known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine-readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

Right to Object and/or Restrict Processing of Your Personal Data. Under certain conditions, you have the right to object to our processing of your personal data as outlined in Sections 2, 3, and 4, above.

Right Not to be Subject to Automated Decision-Making. Under certain conditions, you have the right not to be subject to automated decision-making, if applicable.

Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data based on that consent. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

Right to Make a Complaint. In accordance with applicable law, you have the right to lodge a complaint with an appropriate regulator. The Global Privacy Assembly provides a publicly-available list of privacy authorities, which you can access here. If you have a complaint about how we process your personal data, we encourage you to contact us at [email protected] and we will endeavor to address your request.

How to Exercise Your Privacy Rights

If you wish to exercise any of these rights or any other rights that you may have under applicable law, please contact us at [email protected] or write to us at the address set forth in the “Contact Us” section.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, you may also appoint an authorized agent to exercise any rights that you may have on your behalf. If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests. In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.

If you make a request, we will typically look to respond within one month, although a longer period may be permitted. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Lawful Basis for Processing

With respect to each of the purposes for which we use your personal information (see Sections 2, 3, and 4, above), the lawful basis that we may rely upon will vary based on the nature of, and reason for, the particular use to which we are putting your personal information. However, typically we will use your personal information:

Where we need to do so to perform a contract we are about to enter into with you or have entered into with you – for example, this will be relevant where we use your personal information to provide you with the Services, to operate the Services, and to create and maintain your Account.
Where it is necessary for our legitimate interests, and/or those of a third party, and your interests and fundamental rights do not override those interests – for example, this will be relevant where we share your personal information in the context of an actual or prospective corporate event, in these cases we and any relevant third parties have a legitimate interest in enabling those parties to investigate and, where relevant, to continue to operate, all or relevant part(s) of our operations.
Where we need to comply with a legal or regulatory obligation – for example, this will be relevant where we are legally obliged to provide your personal information to authorities to comply with lawful governmental or regulatory requests.
Where we have your specific consent to carry out the processing for the purpose in question – for example, this may be relevant where we use your personal information to show you targeted online advertising, where required by law.

For questions about the lawful basis we rely on for data processing, please contact us at [email protected] or write to us at the address set forth in the “Contact Us” section.

Marketing and Advertising

From time to time, we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email or push notifications. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

Where we rely on consent to send you marketing communications, we will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the “unsubscribe” link at the bottom of our marketing emails or by updating your preferences in the settings page of the App or Service.

Data Transfers and Processing Outside Europe

If you are located in the EEA, the UK, or Switzerland, your personal information may be processed outside of those regions, including in the United States. In the event of such a transfer, we typically try to ensure a degree of protection similar to that applied in your home country is afforded to it by employing one of the following mechanisms:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the relevant authorities (e.g., by the European Commission, UK Government, and/or Swiss Federal Council).

Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal information by those relevant authorities (e.g., the United States).
- However, in these cases, we may look to use specific appropriate safeguards approved by the relevant authorities, which are designed to give personal information the same protection it has in the EEA, UK, or Switzerland – for example, standard-form contracts approved by relevant authorities for this purpose.

In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to recipients in such countries despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

If you want further information on the specific mechanism(s) used by us when transferring your personal information, please contact us at [email protected] or write to us at the address set forth in the “Contact Us” section.

12. SPECIFIC PROVISIONS FOR CERTAIN U.S. MULTISTATE USERS

These additional provisions apply to individual residents of those U.S. States that have enacted comprehensive consumer privacy laws, including the California Consumer Privacy Act of 2018 and the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, and each of their associated regulations, as well as amendments to those laws or additional consumer privacy laws that may be enacted in the future.

Your Privacy Rights. To the extent permitted under applicable law, you may be able to exercise the following rights in relation to the personal information that we may have collected about you, subject to certain limitations and requirements, including the verification of your identity and our right to retain information to comply with our legal obligations, among other circumstances.

Privacy Right	Brief Details
Know and Access your Personal Information	You may request, up to two times in a 12-month period, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information has been collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold or shared, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable, among other information required by applicable laws.
Request Deletion of your Personal Information	You have the right to request that we delete certain personal information that we may have collected from you.
Opt-Out of the “Sale” or “Sharing” of your Personal Information*	We do not sell your personal information in exchange for money or any other form of payment, nor have we done so in the last 12 months. We may “share” personal information about you for purposes of serving you with personalized ads or content, otherwise known as “interest-based advertising,” “targeted advertising,” or “cross-context behavioral advertising.” You have the right to opt-out of any future “sales” or “sharing” of your personal information as defined by applicable laws (and as explained below).
Non-Discrimination	You have the right to exercise the rights conferred on you by applicable laws without discrimination.
Data Portability	You have the right to request that we transmit certain personal information that we may have collected from you (or about you) to other entities, unless transmitting the information would not be technically feasible.
Correct Inaccurate Information	You have the right to request that we correct errors or inaccurate information in the personal information that we may have collected from you.
Limit the Use or Disclosure of Sensitive Personal Information	In certain circumstances, you have the right to limit the use of any sensitive categories of personal information. As noted above, we do not collect or seek to elicit sensitive categories of personal information.
Opt-Out of the Use of Automated Decision Making	In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your personal information.

*Right to Opt Out of the “Sale” or “Sharing” of Your Personal Information

We do not “sell” information about our users as most people would commonly understand that term or in the way that certain laws primarily define the term “sale.” We do not disclose your personal information in direct exchange for money or some other form of payment.

However, consistent with common practice among companies that operate online, we do “sell” or “share” information in the sense that we allow certain third-party advertising networks and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps, or otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Service and advertisements on our websites, on other websites or mobile apps, or on other devices you may use, to personalize content or to serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics, and market research.

To learn more about how third parties collect information automatically on our Site and the choices you may have in relation to those activities, please see our Online Advertising section, above.

How to Exercise Your Rights

As described above, we will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, you may also appoint an authorized agent to exercise any rights that you may have on your behalf. If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests. In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.

We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Collection, Use, Disclosure, Selling, and Sharing of Personal Information. The chart in the “Sharing of Your Information” Section above summarizes the categories of personal information we collect, the sources of personal information collection, the business purposes for our collection, and the categories of third parties with whom we “disclose,” “sell,” or “share” personal information. The chart describes our practices, both current and during the last 12 months.

Please see Sections 1, 2, and 3 of our Privacy Policy for additional details. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Category of Personal Information Collected	Source(s) of Personal Information	Business Purpose(s) for Collection	Categories of Third Parties to Whom We Disclose the PI for a Business Purpose
Identifiers, such as name, username, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies)	• You or your device(s) • Advertising partners • Affiliates	• Service delivery • Delivery of advertisements • Technical support • Customer support • Processing payments • Analytics • Business research & development • Marketing & promotions • Platform protection & fraud prevention • Compliance with legal obligations	• Service providers • Affiliates • Your specified recipient(s) • Government entities/law enforcement • Advertising partners shared* for interest based advertising
Additional California Customer Records, such as address book information	• You or your device(s)	• Service delivery • Analytics • Business research & development • Marketing & advertising	• Affiliates • Your specified recipients
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data	• We do not intentionally collect or seek to elicit “sensitive personal information” as defined under applicable laws	N/A	N/A
Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies	• You or your device(s)	• Service delivery • Delivery of advertisements • Analytics • Business research & development • Platform protection & fraud prevention • Compliance with legal obligations	• Service providers • Affiliates • Your specified recipients • Payment processors • Advertising partners shared* for interest-based advertising
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement	• You or your device(s)	• Service delivery • Delivery of advertisements • Analytics • Business research & development • Platform protection & fraud prevention • Compliance with legal obligations	• Service providers • Affiliates • Your specified recipients • Government entities/law enforcement • Advertising partners shared* for interest-based advertising
Geolocation Data, such as city or county-level geolocation information	• You or your device(s)	• Service delivery • Delivery of advertisements • Analytics • Business research & development • Platform protection & fraud prevention • Compliance with legal obligations	• Service providers • Affiliates • Your specified recipients • Government entities/law enforcement • Advertising partners shared* for interest-based advertising
Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above	• You or your device(s)	• Service delivery • Delivery of advertisements • Analytics • Business research & development • Platform protection & fraud prevention • Compliance with legal obligations	• Service providers • Affiliates • Advertising partners shared* for interest-based advertising

* As further described above, we “share” this information with advertising partners for interest-based advertising.

13. CHANGES TO THIS NOTICE

We may update this Notice to reflect changes to our data and information privacy practices. If we make any material changes, we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Notice for the latest information on our privacy practices. Please note that if we need to adapt the Notice to legal requirements, the new privacy Notice will become effective immediately or as required.

14. CONTACT US

Our Data Protection Officer

You may contact us or our Data Protection Officer at [email protected] or at the address below for further information.

Calmco Secretarial Ltd.
Dimostheni Severi, 21, Anna Court, 5th Floor
1080 Nicosia
Cyprus

EU and UK Privacy Representatives

We have appointed Prighter Group as our privacy representatives in the EU and UK. You can contact us through our privacy representatives at the following addresses:

For residents of the EU:
PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG
c/o ZenLife Games Limited
Kriegerstraße 44
30161 Hannover
Germany

For residents of the UK:
PrighterUK-Rep by Prighter Ltd.
c/o ZenLife Games Limited
20 Mortlake Mortlake High Street
London, SW14 8JN
United Kingdom

Additional information regarding our privacy representatives can be found at the following link: https://prighter.com/q/12377892952