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Policy Effective: Jan 1 2020

This Privacy Policy describes the personal data we collect and why, how we use that data and your rights.

This Privacy Policy applies to Absolute Games' games, websites and related services, which we here collectively call the “Service”. This Privacy Policy may be periodically updated. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

For purposes of data protection laws, Absolute Games LLC. is the “data controller” of your personal information. We will refer to countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland collectively as the “European Countries” in this Privacy Policy.

1. Contact Us

If you have any questions about data protection, or if you have any requests for resolving issues with your personal data, please contact us inside the game as that is usually the fastest channel of response.
Absolute Games
375 North Stephanie Street, Building 17
Las Vegas, NV 89014
email: support@absolutegames.com

2. The Data We Collect

A. Data you provide us:

• Contact information (such as name and email address)
• Your messages to the customer support
• Other data you choose to give us (such as data to transfer progress or identify a lost account)

B. Data we collect automatically:

• Data about your account and game progress
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
• Data about your device, such as device name and operating system, browser type and language
• Data we collect with cookies and similar technologies (see more below)
• General location data
• Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

C. Data we collect from our partners:

• Data we receive if you link a third party tool with the Service (such as Apple, Amazon, Facebook or Google)
• Demographic data (such as to determine the coarse location of your IP address)
• Data to fight fraud (such as refund abuse in games or click fraud in advertising)
• Data from platforms that the games run on (such as to verify payment)
• Data for advertising and analytics purposes, so we can provide you a better Service

3. Why Do We Collect Your Data

A. To make the Service work
We process data necessary to:

• Create accounts and allow you to play our games and use our Service
• Operate the Service
• Verify and confirm payments
• Provide and deliver products and services you request
• Send you Service-related communications

B. To make the Service better
To provide an excellent Service for our players, we collect and process necessary data to:

• Create and update player profiles
• Improve the Service and player experience
• Provide social features as part of the Service
• Customize your Service experience
• Respond to your comments and questions and provide player support
• Provide you offers in the Service as well as in other websites and services, and by email
• Send you related information, such as updates, security alerts, and support messages

C. To show ads
To show you personalized advertisements in the Service as well as in other websites and services (including email) we process necessary data to:

• Track the content you access in connection with the Service and your online behavior
• Deliver, target and improve our advertising and the Service
• For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.

D. To protect
Making sure the Service is fun and fair is important to us. In order to keep the Service protected, to fight fraud and ensure acceptable use otherwise, we process necessary data to:

• Analyze and monitor use of the Service and its social features
• Take action against fraudulent or misbehaving players

D. To verify
In all of the above cases and purposes, we may verify, categorize and store all collected data.

4. Who Can See Your Data

Apart from Absolute Games, your data can be accessed by others in the following situations:
A. Other Users
Other players and users may read the messages you have posted publicly to third party services.
B. Partners Working For Absolute Games
Absolute Games has partners to perform services for us. These partners process your data only at and according to Absolute Games's instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
C. Other companies and public authorities
In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
D. Advertising
The Service may contain advertisements from “Third-Party Services,” meaning companies other than Absolute Games may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.

5. International Data Transfer

IMPORTANT: When you use our Services, your personal information may be sent to the United States and possibly other countries.
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

6. Your Rights and Options

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A. Opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting 'limit ad tracking' (Apple iOS) or 'opt-out of interest based ads' (Android).
B. Access the personal data we hold about you
If you request, we will provide you a copy of your personal data in an electronic format.
C. Your other rights.
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by not using the Service. To contact us, please send us a message inside the game, or to support@absolutegames.com.
We will respond to all requests within a reasonable timeframe. You may also contact your local data protection authority for unresolved complaints.

7. California Privacy Rights

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information
When California Consumers access the Absolute Games websites, purchase Absolute Games products, contact Absolute Games, visit one of our physical locations, seek employment with Absolute Games, or become a Absolute Games employee, we collect the following Personal Information.

Categories of consumer’s Personal Information collected	Business or commercial purposes for which the information was collected	Categories of sources from which that information was collected	Categories of third parties with whom the business shares personal information	Personal Information disclosed or sold to third parties for a business or commercial purpose in the preceding 12 months
Identifiers Alias Email Address Account Name Unique Personal Identifier Online Identifier	To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute; To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute; To enforce the Terms of Service or Use of any of our websites, applications or services; To prevent fraud; To ensure minors do not unlawfully enter our facilities; To provide you with the products and services you request, view, engage with, or purchase; To communicate with you regarding your account or transactions with us; To send you offers and promotions for our products and services; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; and To investigate and prevent activities that may violate our policies.	This information is collected directly from you.	Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Commercial Information Products or service purchased, obtained or considered Purchasing or consuming histories or tendencies	To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute; To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute; To enforce the Terms of Service or Use of any of our websites, applications or services; To provide you with the products and services you request, view, engage with, or purchase; To communicate with you regarding your account or transactions with us; To send you offers and promotions for our products and services; To provide you with targeted advertising based on your activity on our sites; To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; and To investigate and prevent activities that may violate our policies	This information is collected directly from you or by logging our interactions with you.	Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Internet or Electronic Network Activity Information Browsing history Search history Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement Internet Protocol address Device ID Cookies Unique Personal Identifier Online Identifier Beacons Pixel Tags Mobile Ad Identifiers	To enforce the Terms of Service or Use of any of our websites, applications or services; To prevent fraud; To provide you with targeted advertising based on your activity on our sites; To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; and To investigate and prevent activities that may violate our policies	We collect your internet or other electronic network activity information from your interactions with our website.	Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).	Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Geolocation Data Location information Device location information	To enforce the Terms of Service or Use of any of our websites, applications or services; To prevent fraud; To provide you with targeted advertising based on your activity on our sites; To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; and To investigate and prevent activities that may violate our policies	We collect your geolocation information from your interactions with our website.	Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

Individual Rights
Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that Absolute Games disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

• Category of personal information collected,
• Categories of sources from which that information was collected,
• The business or commercial purpose(s) for which the information was collected,
• The categories of third parties to whom Absolute Games sold or disclosed the category of personal information for a business purpose, and
• The business or commercial purpose for which Absolute Games sold or disclosed the category of personal information.

Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

• Specific pieces of Personal Information collected about you.

Absolute Games does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless Absolute Games determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

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Right of Deletion
You have the right to request that Absolute Games and our service providers delete any Personal Information about yourself that Absolute Games has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Submitting Requests
You may submit a request through a webform available by emailing us at ccpa@absolutegames.com or send us a request to our support center inside our game.

Verifying Requests
Absolute Games provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. Absolute Games must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Absolute Games reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Authorized Agent
You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Absolute Games requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Absolute Games. Failure to do so may result in Absolute Games denying your request.

Right to Equal Service
Absolute Games will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

• Denying goods or services to you.
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to you.
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

8. California Privacy Rights: Shine the Light

Under California’s “Shine the Light” law, California residents who provide certain personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information please contact us at the information provided below. We will provide the requested information to you pursuant to the contact information provided to us.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

9. How Do We Protect Your Data

A. Security Safeguards
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
B. Data retention
We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

10. Age Limits

Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.
Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA, or obtain legally valid parental consent.
If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us.

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