PRIVACY POLICY

Last updated: June 13, 2022. Effective June 13, 2022.

1. Introduction

52games Studio Inc. (collectively, “52games Studio Inc.”, “us”, “our” or “we”) develops and publishes games for mobile devices. This Privacy Policy (this “Policy”) describes the ways we collect, store, use, and disclose the information, including personal information, and data that our users (“users” or “you”) provide through any 52games Art Ltd. game on a mobile platform (each a “Service,” collectively, the “Services”).

This Policy also describes your rights and choices concerning your information.

Please note: this Policy applies only to information collected by 52games Studio Inc. via the Services. We are not responsible for third-party sites or their content, practices, or data usage. Links to external sites do not imply sponsorship or affiliation.

If you do not agree with this Policy, please do not use our Services.

2. Information and Data We Collect from You and How We Collect It

  • Registration Information: When creating an account, you may provide name, username, email, password, and other identity-verification details. If using Facebook Connect, we collect your name, Facebook ID, profile picture, and friends list. Your username is public.
  • Contact Import: You may import contacts or enter emails to find and invite friends. We store these for connection purposes.
  • Payment Information: Purchases (including virtual goods) are processed by third-party providers who collect your name, phone, email, addresses, and full credit card details. This data may be retained for future purchases.
  • Customer Support: When contacting support, we collect your contact info, gameplay data, username/ID, and correspondence.
  • Technical and Usage Information: We collect device IP, device ID (e.g., IDFA, GAID), OS version, usage stats, and device identifiers via SDKs. We may access contacts to enable friend invites. Push notifications (game updates, scores) can be disabled in device settings.

3. How We Use Your Information

We use your information to:

  • • Create accounts and deliver Services
  • • Suggest connections with other users
  • • Operate, improve, and optimize our Services
  • • Personalize your experience
  • • Respond to inquiries and provide customer service
  • • Deliver requested products/services
  • • Send marketing, promotions, contests, and event news
  • • Communicate transactional messages (confirmations, updates, alerts)
  • • Conduct contests
  • • Enable user-to-user communication
  • • Combine with third-party data to better understand preferences

Use of Your Information by Others

Third-Party Services: We share data with vendors for hosting, payments, analytics, customer service, and marketing. Contracts ensure data protection per applicable laws.

Advertising: Ad networks may collect device data (model, OS, carrier, IP, advertising ID, etc.) to serve targeted ads.

Opt-Out Options:

Note: Opting out doesn’t stop ads; it makes them less relevant. You may need to renew opt-outs across devices or browsers.

4. How We May Disclose Your Information to Third Parties

We do not sell or share personal data except as described here:

  • With service providers performing services on our behalf
  • With our affiliates
  • For analytics and research
  • To comply with legal requests or laws
  • To report criminal activity or protect against fraud
  • To defend legal rights or claims
  • In connection with business transfers (merger, acquisition)
  • Aggregate or anonymous data may be shared with advertisers, partners, etc.
  • We use third-party analytics (e.g., Google Analytics). Learn more: Google Analytics Partners

5. Specific Provisions for EU Individuals

Applies to users in the European Economic Area, UK, or Switzerland.

  • Access & Correction: Contact us to access or correct your data.
  • Withdraw Consent: You may withdraw consent at any time.
  • Erasure or Restriction: Request deletion or restriction. We may deny if data is actively used.
  • Data Portability: Receive your data in a structured, machine-readable format and transfer it elsewhere (if technically feasible and not affecting others’ rights).
  • Right to Complain: You may lodge a complaint with a supervisory authority in your country.

Contact our Data Protection Officer at [email protected] with concerns.

6. Security Safeguards

We take reasonable measures to protect your data from unauthorized access, loss, or misuse. However, no transmission or storage method is 100% secure. We cannot guarantee absolute security against hackers or breaches.

7. Data Retention

We retain personal data as long as necessary to provide Services, comply with legal obligations, resolve disputes, and enforce agreements. Data will be deleted upon request unless required by law.

8. Our Policy Regarding Children

We do not knowingly collect data from children under 16. If we discover such data, we will delete it promptly. Contact us if you believe we have data from a child under 16.

9. Transfer of Personal Data Outside Your Country

We may transfer your data globally, including to the U.S. We ensure adequate safeguards are in place, even when destination countries have different data protection laws.

10. Lawful Basis for Processing

We process data based on:

  • Necessity for contract performance (e.g., providing Services)
  • Compliance with legal obligations
  • Protecting vital interests
  • Legitimate interests (e.g., fraud prevention, service improvement, marketing), unless overridden by your rights
  • Your consent, which you may withdraw at any time

Contact our Data Protection Officer for questions.

11. Specific Provisions for California Consumers

Under the CCPA, California residents have rights to know, delete, and opt out of the sale of personal information.

We do not sell your personal information.

How to Exercise Rights: Email [email protected] with subject line “California Rights Request”. We will verify your identity before processing.

We aim to respond within 45 days. We may deny requests if verification fails or retention is necessary (e.g., security, legal compliance).

You have the right to use an authorized agent with written permission and verified identity.

No discrimination for exercising your rights.

12. Changes to This Policy

We may update this Policy. Material changes will be notified via notice on the Services before they take effect. We encourage you to review this page periodically. Legal updates may take effect immediately.

13. Contact Us

Contact our Data Protection Officer at: [email protected]